How the Dutch gender care guideline was developed without health insurers, and why ‘informed consent’ is being redefined

Anyone looking up a gender care guideline in the Netherlands assumes it was developed through the usual process: doctors, patients, scientists and insurers working together to draft a document and hold one another to account. An international overview by investigative journalist Bernard Lane, published on 23 September 2026 in his newsletter Gender Clinic News, raises questions about the Dutch process: advocacy groups were closely involved in drafting the 2019 Quality Standard for Transgender Care, while health insurers were excluded from the process.

What Lane reports: WOB documents and a missing party

Lane bases his account on documents released following a request under the Government Information (Public Access) Act. They reportedly show that advocacy groups played a guiding role in the development of the Quality Standard for Transgender Care—the document that has since determined when people in the Netherlands can access puberty blockers, hormones and surgery. Health insurers, who would normally be involved because they pay the bill and therefore have an interest in well-founded indications for treatment, were not at the table. This is striking: in virtually every other Dutch guideline for expensive or irreversible care, insurers are involved precisely to prevent a single interest group from setting the standard. The positions taken by an advocacy group such as Transgender Netwerk in this debate are outlined on genderbeleid.nl, in the critical dossier on Transgender Netwerk.

Informed consent: treat first, understand later?

The second element Lane describes in relation to the Netherlands touches on the heart of what this network stands for: informed consent. Researchers connected to Amsterdam UMC, including child and adolescent psychiatrist Annelou de Vries, are said to use an argument in conversations and publications that turns informed consent on its head: a young person can only truly understand the consequences of puberty blockers or hormones by undergoing them. Taken seriously, this undermines the entire concept of prior informed consent—which assumes precisely that someone sufficiently understands what they are choosing before taking an irreversible step, not afterward.

This is no minor detail. Part of the criticism of the Dutch Protocol after three decades of research is precisely that the evidence for long-term effects has remained weak—if consent is conceptually undermined from the outset, the weak evidence base becomes even harder for parents and young people to understand.

Not an isolated incident, but a pattern

Lane does not present the Netherlands as an isolated case. His overview describes similar tensions worldwide: in the United States, endocrinologist Richard Santen points out that nine out of ten authors of the Endocrine Society guideline and 117 of the 121 authors of the WPATH guideline had financial or professional interests in the care they recommended—compared with the fully independent composition of the British Cass Review. In South Africa, a patient organisation called for a guideline to be withdrawn following criticism of WPATH’s role in it, and the journal itself acknowledged that peer review had been absent. The picture that emerges is that guidelines directly influencing care are more often developed internationally with too little challenge from outside their own circle than with too much.

For child protection and careful diagnosis, that challenge is not a side issue but a prerequisite—see also what is needed for careful diagnosis in minors. A guideline developed without the party paying the bill, and redefining prior consent as something that only emerges afterward, lacks precisely the checks that should provide that safeguard.

Anyone specifically exploring how informed consent should work legally and ethically for minors will find a detailed analysis on dutchprotocol.nl, in the dossier on ethical criticism and informed consent.

Distinguishing between source and interpretation

Lane reports what the WOB documents and statements by the researchers involved show; he does not himself draw a legal conclusion about the Quality Standard. The conclusion that the absence of insurers and the redefinition of informed consent pose a risk to careful decision-making is our interpretation of those facts—not a judgment already formulated in those terms in the source material itself.

Sources

Bernard Lane, "Biased brains", Gender Clinic News, 23 September 2026: genderclinicnews.com/p/biased-brains.