Policy by country
How do different countries deal with gender care and policy? A comparative overview.
Over the past fifteen years, policy around gender care in Western countries has shifted considerably. Whereas the so-called gender-affirmative model was long presented as the standard — with social transition, puberty blockers and cross-sex hormones, including in minors — several European countries have been adopting a more cautious course since 2020. The reasons: a weak scientific underpinning of early interventions, rising detransition reports, and an explosive increase in adolescent referrals that does not match earlier clinical patterns.
Sweden, Finland, Norway and Denmark have substantially revised their practice. The UK Cass Review of 2024 led to a change in NHS policy and a ban on puberty blockers outside research settings. The United States has a strongly polarised policy that differs by state. The Netherlands and Belgium cling to a variant of the original Dutch Protocol, even though the international evidence base for that protocol is under heavy fire.
Per country, not only medical policy differs, but also legal recognition, access to care, age limits, the information provided to parents and patients, and the surrounding political climate. The overviews below offer a comparative perspective — essential context for anyone who wants to place Dutch policy within the international development.
Why the international comparison matters
Dutch gender care presents itself in the professional literature as setting the direction — the 'Dutch Protocol' is a proper noun in international guidelines. At the same time, various countries have structurally revised their national care since 2020, often on the basis of the same studies that Amsterdam UMC relies on. A comparison shows who read what and who decided what.
Four groups of countries
International policy falls roughly into four categories:
- Scandinavian reorientation: Sweden (Karolinska, 2021), Finland (COHERE, 2020), Norway and Denmark have reduced puberty blockers in minors to an exception basis after systematic literature reviews assessed the evidence as weak.
- UK course change: the United Kingdom closed Tavistock GIDS in 2024 and is fundamentally reforming paediatric care after the Cass Review.
- Continental caution: France's HAS report (2025), Germany's scientific committees and Italian advisories argue for more caution with minors.
- Affirmative model: the United States (in liberal states), Canada, Spain, Belgium and the Netherlands largely stick to affirmative care models, although various US states have introduced age limits for irreversible care.
What the comparison reveals
The fact that a patient in Sweden receives different care than in the Netherlands, while both countries can read the same literature, undermines the idea that the care guideline follows neutrally from the evidence. Policy formation plays a role — political pressure, institutional culture, advocacy. Anyone who puts the guidelines per country side by side does not see four interpretations of the same evidence but four different risk assessments.
Legal differences
In addition to medical differences, legal arrangements vary widely. UK case law (For Women Scotland, 2025) established that 'sex' in the Equality Act means biological sex. Hungary and Slovakia introduced more restrictive legislation. Argentina and Ireland have broad self-identification models. The Netherlands sits with the Transgender Act somewhere in between — an arrangement with sex change by declaration, but without the full legal consequences that Spain or Scotland briefly introduced.
What follows
The international convergence is asymmetric: countries that revise their paediatric care rarely fully reverse it, but do add a degree of caution. Countries that remain affirmative experience increasing legal pressure through lawsuits by detransitioners. Whether the Netherlands follows this movement or positions itself as the leader of the other camp is a political choice that becomes unavoidable within five years.
Netherlands
Gender care in the Netherlands
The Netherlands was a world leader in gender care for young people through the Dutch Protocol. Read about the current state of affairs, tightening of policy…
Gender care in Belgium
Overview of gender care in Belgium: legislation, specialised centres, puberty blockers and the debate over medical treatment of minors.
Gender care in the United Kingdom
The UK has thoroughly revised gender care for minors after the Cass Review. Read about the closure of GIDS and the ban on puberty blockers.
Gender care in Sweden
Sweden severely restricted gender care for minors in 2022-2023. Puberty blockers are barely prescribed anymore. Read about the policy change.
Gender care in Finland
Finland restricted gender care for minors as early as 2020. Psychotherapy comes first; medical treatments apply only to exceptional cases.
Gender care in Denmark
Denmark severely restricted gender care for minors in 2023-2024. Read about the policy change, guidelines and comparison with neighbouring countries.
Gender care in Norway
Norway revised gender care for minors in 2023-2024. Puberty blockers are no longer routinely available. Read about the policy change.
Gender care in Germany
Germany introduced the Selbstbestimmungsgesetz for legal sex change in 2024. Read about medical gender care, reimbursement and guidelines.
Gender care in the United States
Gender care in the US is highly divided by state: more than twenty states ban gender care for minors, while other states actively protect it.
Gender care in Australia
Gender care in Australia varies widely by state. Read about the historical judicial approval requirement, recent tightening and state differences.
Gender care in Austria
Gender care in Austria: providers in Vienna and Innsbruck, legal recognition since the 2018 Constitutional Court ruling.
Gender care in Poland
Limited access to transgender care in Poland and the legal route via a procedure against the applicant's own parents.
Gender care in Portugal
Gender care in Portugal: 2018 self-determination law, hospital care and access for young people.
Gender care in New Zealand
Gender care and legal recognition in New Zealand: self-declaration since 2023 and the organisation of care.
The Cass Review explained
The Cass Review (2024) examined gender care for minors in England. Read the findings, recommendations and international impact of this report.
EU policy and transgender rights
The European Union and transgender rights: the LGBTIQ Equality Strategy, Court of Justice case law and non-discrimination directives.
Gender care in Canada
Organisation of transgender care in Canada: provincial differences, age limits and Canadian Pediatric Society guidance.
Gender care in France
Gender care in France: position of the Académie nationale de médecine, age limits and political debates in parliament.
Gender care in Ireland
Access to gender care in Ireland: the National Gender Service, waiting times and referral to foreign centres.
Gender care in Italy
Italian gender care: ONIG guidance, the legal framework (Law 164/1982) and regional differences in access.
Gender care in Spain
Spanish gender care and the Ley Trans (2023): self-declaration, regional UTIG units and age limits.
Gender care in South Africa
Transgender care in South Africa: legal recognition since 2003 (Act 49), and limited access in the public health system.
Gender care in Switzerland
Swiss gender care: cantonal differences and simplified registration changes since 2022.