France, Germany, U.K. Disagree Over Transgender Care
A comparison of national guidelines and priorities
In April 2024, the U.K. National Health Service published a widely-cited report on gender identity healthcare policy, led by Dr. Hilary Cass. In April 2025, the U.S. Department of Health and Human Services is expected to issue its own report on the topic. The Cass report is well known in the U.S. media. Two other recent comprehensive nationwide trans youth care guidelines have also recently been released. These two additional reports are not written primarily in English, however, so their coverage in the U.S. and U.K. has been more scant. The present primer has been prepared for journalists on deadline and policy and medical professionals seeking quickly accessible context.
Please note: This table was prepared as an advance backgrounder and so does not contain information or perspectives on the anticipated U.S. HHS report.
| Aspect | German/Austrian/Swiss Guidelines (2025) | Cass Review (2024 UK) | French Guidelines (2024) | Key Implications |
|---|---|---|---|---|
| Development Process | 26 medical societies + patient groups across DACH region. Emphasizes "depathologization" of trans care. | NHS England-commissioned with no trans healthcare specialists on core team. Independent Yale review of Cass revealed "high risk of bias." | French Society of Pediatric Endocrinology and Diabetology (SFEDP) developed its consensus statement through multidisciplinary, evidence-based approach for trans adolescents. | Continental guidelines counter Anglo-American politicization of care. |
| Methodology | Based mainly on the expert opinions and clinical experience of doctors in absence of long-term data. | Research review that dismissed transition outcomes and "transgresses medical law and policy," per NEJM review. | Adapted scientific evidence and international standards to French context, emphasizing individualized, supportive care. | EU approaches emphasize clinical expertise; Cass emphasizes theoretical risks. |
| Medical Interventions | Blockers from early puberty with assessment, hormones possible for teenagers in special cases. Decisions made individually and with consent. | UK indefinite ban on puberty blockers, despite report's condemnation from experts around the world. | Hormones considered at 14-16, though based on assessed readiness, not age. Gamete preservation strongly recommended. | EU guidelines align with global WPATH standards; Cass diverges from consensus. |
| Youth Autonomy | Prioritizes autonomy and flexibility, not gatekeeping. "Young people should be able to understand that they themselves decide and have the possibility, within certain limits, to try something and also to stop again." | Requires multi-year assessments through NHS, complicated by central approval barriers. | Early intervention model, citing 73% lower odds of self-harm or suicidal thoughts. | Contrast between immediate care access vs institutional barriers. |
| Psychotherapy Role | "People with gender incongruence/gender dysphoria should be offered psychosocial support, counseling, and, if necessary, psychotherapy to help them cope with and overcome the effects of trans-negativity and transphobia." | Therapy as primary intervention to explore "underlying causes." | Rejects mandatory counseling before medical care. | Fundamental disagreement concerning role of therapy as complement to other interventions or as singular potential gatekeeper. |