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.