On 29 May 2024, the Government introduced two pieces of regulation which restrict how trans children and young people under 18 years old can access some medications (GnRH analogues) which delay the effects of puberty as a result of a diagnosis of gender incongruence or gender dysphoria.

These medicines consist of or contain buserelin, gonadorelin, goserelin, leuprorelin acetate, nafarelin or triptorelin. We will call these GnRH analogues throughout this information to prevent confusion with other medications. 

This legislation applies in England, Wales and Scotland. 

Following the Government’s announcement, NHS England wrote to the parents and guardians of all young people on the waiting list for the NHS Children and Young People’s Gender Service explaining how the restrictions would apply in practice. You can read this letter here.  

The restrictions primarily affect two groups of young people: 

• Young people whose prescriptions are provided by healthcare professionals registered in the European Economic Area (EEA) 

• Young people who did not receive a first prescription for this type of medication before 3 June 2024 and are accessing, or considering, private healthcare. 

In response to the new restrictions, the letter from NHS England, and questions we’re receiving from those Mermaids supports, we sought advice from some legal experts to provide much-needed clarity.  

We remain extremely disappointed by this legislation and the harm it is causing to trans young people. TransActual, in partnership with the Good Law Project, have issued a legal challenge to the decision which has now been accepted by the courts for an urgent hearing.  

Frequently Asked Questions 

Do the restrictions affect me if…

I am accessing GnRH analogues via NHS Prescriptions 

Any young person being prescribed GnRH analogues by the NHS, whether through the gender service endocrine pathway or their GP, is unaffected by these restrictions.  

GPs in England, Wales and Scotland cannot start new prescriptions after 26 June 2024.  

I am accessing GnRH analogues via a UK-based private provider 

Any young person already being prescribed any medication by a private healthcare provider who is registered to prescribe in the UK is also unaffected by these restrictions.  

I am accessing GnRH analogues via an EEA-based health professional 

Any young person being treated by a provider and receiving prescriptions issued by a professional registered in the European Economic Area (EEA) will no longer be able to have them dispensed in England, Wales or Scotland. 

I am 18 years old or older and accessing GnRH analogues via any of the above routes 

These regulations do not affect you.  

If a young person started treatment with an EEA provider before 3 June 2024, can they continue this treatment with a UK registered prescriber? 

In principle, yes. If a young person can identify a prescriber. In practice, this is likely to be very difficult because: 

• There are very few providers who treat under 18s, either on the NHS or privately 

• The new regulations restrict how NHS GPs are permitted to prescribe GnRH analogues 

Are these changes permanent? 

The restrictions on prescriptions from providers registered in the EEA are a temporary order which expires on 2 September 2024. For this to be made permanent, a new statutory instrument must be laid before Parliament.  

The changes to how GPs can prescribe these medications are permanent. 

Do these changes affect all drugs which block the effects of puberty? 

No. These changes only affect GnRH analogues, defined as “a medicinal product that consists of or contains buserelin, gonadorelin, goserelin, leuprorelin acetate, nafarelin or triptorelin”. Other drugs which could block the effects of puberty are not affected.  

What could happen to me if I obtain these medications through another source? 

The explanatory notes to the restrictions explain that: 

“From the 3 June 2024 a breach of the Order is a criminal offence under the Medicines Act 1968. This also applies to possession, where the individual had reasonable cause to know that the medicine had been sold or supplied in breach of the ban. 

A person guilty of breaching the Order is liable on summary conviction to a fine of up to £400, or on conviction on indictment to a fine and/or to imprisonment for a term of up to two years.” 

For pharmacists, it is also an offence to dispense puberty blockers which are not exempt from the restrictions and “breaching the Order would provide the relevant regulator with evidence for a fitness to practice investigation”.  

In addition, NHS England has stated that no one should buy GnRH analogues from unregulated sources, such as the internet, friends or from street dealers. Unregulated medications can have potentially dangerous short and long-term side effects and even prescription drugs can be dangerous unless prescribed and managed by an appropriate healthcare professional. 

Where a child or young person is accessing GnRH analogues from unregulated sources, healthcare professionals may be required to explore safeguarding procedures. This does not necessarily mean making a child protection referral. 

If a previous prescription of GnRH analogues has been issued in a name which isn’t in someone’s legal name, can future prescriptions be issued in the legal name? 

The Order states that anyone to whom GnRH analogues are being supplied needs to produce a UK birth certificate or current national identity document which verifies their age and identity.  

A national identity document includes a passport, driving license (full or provisional), birth certificate, biometric residence permit or adoption certificate.    

If the individual’s name on their UK birth certificate or current national identity document does not align with the name used for previous prescriptions, individuals will need to be able to illustrate that they are the same person. They may do this by showing their Deed Poll and their UK birth certificate, for example.  

If a 16/17-year-old is prescribed a GnRH analogue as part of hormone replacement therapy (HRT) are they affected? 

If the GnRH analogue is prescribed “for the purpose of puberty suppression in respect of gender dysphoria, gender incongruence or both” it would fall in scope and be banned if prescribed by a non-UK prescriber. 

If the prescription is part of a programme of HRT (also prescribed estrogen/testosterone), which includes a GnRH analogue to suppress hormones produced by their own body, young people should speak with their prescriber to understand how the new regulations affect them.  

What should I do if I’m worried or have questions? 

If you are already working with a healthcare provider, they are probably best placed to provide you with advice or information about your options. If you, or someone you care about, is affected by these restrictions, please do reach out for support. Our helpline is open Monday to Friday, 1pm to 8.30pm.  

Mermaids will continue to campaign for access to timely, supportive and holistic healthcare free at the point of use for all trans young people who need it.