Policy by country

Q: Which countries have restricted puberty blockers for minors?

Sweden, Finland, Norway and Denmark have reduced puberty blockers for minors to exceptions, after systematic literature reviews that rated the evidence as weak. In the United Kingdom a ban outside a research setting has applied since 2024. The Netherlands and Belgium hold on to a variant of the original Dutch Protocol.

Q: Which countries have introduced self-identification?

Argentina and Ireland have broad models for self-identification, Spain introduced one in 2023 and Germany in November 2024. In Scotland the British government blocked a similar law. In the Netherlands self-identification has not been introduced: the bill was withdrawn in 2025. Here the Transgender Act of 2014 applies, under which an expert statement is required to change the registered sex.

Q: Why does gender care differ so much from country to country?

Because countries weigh the same evidence differently. A patient in Sweden receives different care from a patient in the Netherlands, while both countries can read the same studies. Besides the evidence, political pressure, the culture within institutions and advocacy play a part. Anyone who puts the guidelines side by side therefore sees mainly different assessments of the risk.

Q: What did the UK Supreme Court decide about the word woman?

The UK Supreme Court determined in April 2025 in the For Women Scotland case that the words woman and sex in the British equality legislation, the Equality Act, refer to biological sex. The ruling is important for facilities that are separated by sex. In the Netherlands a comparable ruling on the concept of sex in the Algemene wet gelijke behandeling has not yet been given.

How do different countries deal with gender care and gender policy? A comparative overview.

Over the past fifteen years policy on gender care in Western countries has been very much in flux. Whereas the so-called gender-affirmative model was long presented as the standard — with social transition, puberty blockers and cross-sex hormones, also for minors — several European countries have been pointing to a more cautious course since 2020. The reasons: weak scientific support for early interventions, rising reports of detransition, and an explosive increase in adolescent referrals that does not fit earlier clinical patterns.

Sweden, Finland, Norway and Denmark have substantially revised their practice. The British Cass Review of 2024 confirmed the change of course at the NHS, which since March 2024 has prescribed puberty blockers only within research. The United States has a strongly polarised policy that differs from state to state. The Netherlands and Belgium adhere to a variant of the original Dutch Protocol, even though the international evidence base of that protocol is under heavy fire.

What differs from country to country is not only medical policy, but also legal recognition, access to care, age limits, the information given to parents and patients, and the political climate around it. The overviews below offer a comparative perspective — indispensable 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 name in international guidelines. At the same time, several countries have structurally revised their national care since 2020, often on the basis of the same studies on which Amsterdam UMC relies. 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 for minors to an exceptional basis after systematic literature reviews that rated the evidence as weak.
British change of course: the United Kingdom closed Tavistock GIDS in 2024 and is fundamentally reforming paediatric care following the Cass Review.
Continental restraint: France's HAS report (2025), Germany's scientific committees and Italian advisory opinions argue for more caution with minors.
Affirmative model: the United States (in liberal states), Canada, Spain, Belgium and the Netherlands largely hold on to affirmative care models, although several American states have introduced age limits for irreversible care.

What the comparison reveals

The fact that a patient in Sweden receives different care from a patient in the Netherlands, while both countries can read the same literature, undermines the idea that the care guideline follows neutrally from the evidence. Policy-making plays a part — political pressure, institutional culture, advocacy. Anyone who puts the guidelines of the different countries 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. British 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. With the Transgender Act, the Netherlands sits somewhere in between — a model in which registered sex is changed on the basis of an expert statement, but without the full legal consequences that Spain has had since 2023 and that Scotland wanted to introduce.

The legal file on the Transgender Act and self-identification is on zelfidentificatie.nl.

What follows

The international convergence is asymmetrical: countries that revise their paediatric care rarely reverse it completely, 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 front runner of the other camp is a political choice that will become unavoidable within five years.