Irregular regulator

Australia’s health profession watchdog looks very much like a willing victim of capture by gender ideology

When your view is skewed by gender ideology … Photo by Girl with red hat on Unsplash

Inside info

The Australian Health Practitioner Regulation Agency has uncritically embraced the contentious gender-affirming worldview as part of developing its “LGBTQIA+ Equity and Inclusion Strategy”, judging by documents obtained under Freedom of Information law.

Joe Goddard-Williams, state manager for Victoria and co-chair of the steering committee for the strategy, has been upfront about a personal interest.

On social media Mx Goddard-Williams said: “As a masculine-identified queer person, like many other LGBTQIA+ people, I’ve had trouble finding safe and inclusive support across healthcare and other institutions. Really proud of the work AHPRA is doing to be an accessible and safe regulator for LGBTQIA+ people.”

The AHPRA website said: “Joe did a Master of Critical Theory in the UK before moving into regulation …”

In the FOI documents, steering committee minutes from December 2024 cite a workshop, with the comment, “We heard about the importance of gender-affirming care.”

“AHPRA not only responds to complaints, but we also set the standards for practitioners. If we get the standards right, and ensure more identity-affirming care, we won’t receive the complaints in the first place,” the minutes for an October 2024 meeting say.

This suggests that AHPRA’s fidelity to the affirmative model is not limited to its LGBTQIA+ strategy but extends to the setting of standards for practitioners and the handling of complaints against them.

A 2025 summary document for the strategy refers to case studies of regulatory action against “several practitioners who displayed conduct that breaches professional standards and codes of conduct, pertaining to derogatory and inappropriate comments directed towards LGBTQIA+ people”.

Although heavily redacted, the FOI documents reveal that AHPRA sought “validation” and “feedback” on its draft strategy from the lobby group Transgender Victoria, which was paid at the rate of $495 an hour.

In a February 2025 email to the lobby group, steering committee co-chair Joe Goddard-Williams says: “I’m reaching out because AHPRA is developing our first LGBTQIA+ equity and inclusion strategy for our regulatory scheme.”

“As you know, we regulate close to a million health practitioners as well as employ around 1,500 people, so our strategy is focussed on becoming a safe regulator and employer for LGBTQIA+ people.” [Emphasis added]

Transgender Victoria claims that puberty blockers are “well-researched”. In fact, according to multiple systematic reviews—the “gold standard” for checking the quality of research said to support a treatment—the evidence for this use is weak and uncertain.

Also consulted by AHPRA were trans rights organisations such as ACON and Thorne Harbour Health, both of which have launched gender clinics that offer irreversible cross-sex hormones to young people. AHPRA is a member of ACON’s Pride in Diversity program.

Framing those organisations as “community” representatives rather than lobbies, the FOI documents suggest an unguarded adoption of an external agenda.

“Initial feedback on this [strategy] draft has been sourced from three community peak/support organisations—ACON’s Pride in Diversity, Transgender Victoria, and Thorne Harbour Health … Their feedback indicates the draft is strongly aligned with community expectations,” says an April 2025 executive summary on the strategy.

That same month, the working draft was said to provide “a framework to achieve our commitments to community (e.g. pre-existing commitment to Rainbow Tick and AWEI in People Plan)”. [Emphasis added]

AWEI is ACON’s Australian Workplace Equality Index, in which employers compete to implement the lobby group’s agenda. Rainbow Tick is an “LGBTIQ inclusion” scheme that emerged from a La Trobe University research centre which urges an expansion of “affordable, accessible gender-affirming medical care”.

Also last year, an executive summary for AHPRA’s strategy said its purpose was “to elevate and reinforce existing programs of work to achieve accreditation against recognised standards and benchmarking tools—namely Rainbow Tick and the AWEI—to influence positive systemic, attitudinal and cultural change across the National Scheme for LGBTQIA+ peoples”.

In September 2020, a Family Court judge noted evidence that ACON was among the promoters of the fast-track “informed consent model” for minors aged 16-17 without the necessity of a mental health assessment.

A psychiatrist told the court that ACON “has essentially condoned this model and sets 16 years of age as being the threshold for autonomous consent to hormone treatment, overriding any parental objections or misgivings”.

Thorne Harbour Health was also offering the informed consent fast-track to 16-17 year olds. Following the court’s ruling, both Thorne Harbour and ACON had to scramble to change their webpage advice to reflect the law.

In his decision, Justice Garry Watts said “the existing law is that any treating medical practitioner seeing an adolescent under the age of 18 is not at liberty to initiate [puberty blockers, cross-sex hormones or trans surgery] without first ascertaining whether or not a child’s parents’ or legal guardians’ consent to the proposed treatment”.

Language games

The AHPRA documents released under FOI law include an activist-sourced list of terms and definitions.

This ignores the poor benefit to risk ratio of the gender-affirming approach, which it says “may include medical treatment (surgery, hormone therapy and other treatments) …”

The practice of prescribing opposite-sex levels of hormone drugs is dignified as “hormone replacement therapy” as if normal male and female hormone levels put patients in need of therapy.

In the AHPRA FOI documents, there are notes on how to deal with “resistance” from “minority fringe groups”, “potential backlash”, “the risks of the vocal minority” and “potential misinformation”.

“Globally, but with particular reference to the USA, there has been an escalation of anti-LGBT sentiment that has contributed to increased discrimination against LGBTQIA+ peoples, heightened risks to their personal safety, and removed access to critical health services,” according to a 2025 summary of the AHPRA strategy.

This implies that AHPRA regards the affirmative approach as the only possible health service for the gender-distressed, and that evidence-based criticisms of the gender-affirming model, or decisions to restrict it for safety, amount to discrimination that makes trans individuals feel “unsafe”.

The 2025 summary continues: “The politicisation of identity has contributed to increased public and social discourse and the dissemination of misinformation about marginalised communities, under the guise of ‘anti-woke-ism’.”

“While Australia’s legal and cultural landscape differs significantly to that of the USA and other countries that have wound back legal rights for LGBTQIA+ peoples, the global debate suggests that the benefits of equity and inclusion are misunderstood, driving increased activity by fringe minority groups that seek to advocate views and actions that are not grounded in peer-based research, to the detriment of the LGBTQIA+ community.”

AHPRA says its response to potential misinformation will include “Data-driven and research-informed approaches to public health”.

But there is no reference in the FOI documents to the highest quality data, namely the multiple systematic reviews commissioned independently in several countries. These gold-standard reviews confirm that the evidence for hormonal treatment of gender-distressed minors is of low quality, meaning there is no firm basis for gender clinicians in public or private health to claim beneficial outcomes for young people.

Nor is there any acknowledgement in the documents of the good-faith concerns of clinicians and researchers internationally who are not “anti-LGBTQIA+” but regard the gender-affirming treatment model as unsafe, including for gays and lesbians whose same-sex attraction is undermined by the concept of gender identity.

Minutes from an April 2025 AHPRA meeting note concerns “about the current social climate, including rising anti-LGBTQIA+ sentiment and its impact on healthcare access and mental health”. [Emphasis added]

Health authorities in jurisdictions including the UK, Queensland, Finland, New Zealand, Sweden and US Republican states have adopted policies restricting paediatric medical transition because of the inadequate evidence of safety. This trend goes unmentioned in AHPRA’s FOI documents, apart from the implication that the regulator views such restrictions as discriminatory.

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And then they changed: UK lobby Stonewall was the inspiration for ACON’s Australian Workplace Equality Index. AHPRA regards that index as a benchmark. Both ACON and Stonewall are former gay rights/AIDS organisations that pivoted to radical trans lobbying. Starting in the UK, LGB Alliance groups have emerged to reassert same-sex attraction against the conflicting concept of “gender identity”.

Free speech, with undefined limits

During a Senate estimates hearing in June, One Nation Senator Malcolm Roberts raised the case of psychiatrist Dr Andrew Amos, noting that one of the complaints leading to Dr Amos being silenced by AHPRA was his “misgendering” of a UK trans activist.

Senator Roberts asked AHPRA’s chief executive Justin Untersteiner whether “a health practitioner [has] the right to refer to a trans person’s biological sex?”

Mr Untersteiner: “I’m struggling a little bit with that question in regard to our role as the regulator. I don’t know.”

Senator Roberts: “Is it discrimination for a health practitioner to refer to a person’s biological sex?”

AHPRA general counsel Dr Jamie Orchard: “In respect of public comments by practitioners, you’ve heard earlier the discussion around the right of free speech and the fact that AHPRA and the boards are committed to those ideals, but there are limits to free speech and how people express themselves.”

Senator Roberts: “How can a doctor fulfil their ethical obligation to inform the public of potential harms of gender interventions and gender ideology without being accused of discrimination against LGBTQIA+ people?”

Mr Untersteiner: “Health practitioners have a right to have public debate about a range of different issues, which includes, again, gender-affirming treatment, gender blockers [sic] and other like treatments. And we would not be taking regulatory action on that basis.”

“We will intervene where this goes beyond a debate about clinical pathways and treatments and moves into a place of hate or discrimination against individuals or groups.”

Senator Roberts: “Given AHPRA’s affiliation with the Rainbow Tick scheme and ACON, a high-profile gender identity organisation, how can a doctor be sure that AHPRA is neutral and not biased against them?”

Mr Untersteiner cited the “need to be engaging with all sorts of communities to understand their experiences in the health system”. He was silent on the lobbying function of a trans rights organisation such as ACON.

Senator Roberts: “Have you conducted any formal assessment of whether these relationships create actual or perceived conflicts?”

Mr Untersteiner: “No formal assessment.”

Senator Roberts: “How does AHPRA reconcile its statutory obligation to act as an independent regulator with participation in programs designed to influence institutional behaviour toward progressive inclusion strategies?”

Mr Untersteiner: “… there is a very robust regulatory and legislative framework that ensures that there isn’t a conflict of interest that occurs as a result of us listening to different members of the community to understand their experiences.”

Senator Roberts: “Has AHPRA received advice, internal or external, on whether alignment with advocacy organisations risks regulatory capture or bias?”

Mr Untersteiner: “I’ll take that on notice.”

AHPRA’s answer to questions on notice says, in part, that it was “aware of some media reports that we have signed an agreement with ACON and that an agreement has resulted in regulatory capture or bias”.

“All regulatory decisions are made impartially, based on evidence, public safety, risk and in accordance with the Health Practitioner Regulation National Law, as in force in each state and territory.”

“AHPRA does not have a partnership agreement or advisory relationship with ACON … AHPRA has an arm’s-length organisational membership (essential membership tier) with Pride in Diversity, as do nine out of 10 of Australia’s largest employers,” Mr Untersteiner said.

Last week, Queensland’s Education Department said it was leaving Pride in Diversity because it did not “align with its current requirements”, The Courier Mail newspaper reported. The Department won platinum status this year in Pride in Diversity’s Australian Workplace Equality Index.

On August 20, a mother from Queensland’s Sunshine Coast, Nerissa Pace, launched a petition calling on the Department to remove itself from ACON and Pride in Diversity. Ms Pace told The Courier Mail that “transgender ideology is contentious and not settled”, and the vast majority of parents agreed that “gender and LGBTQ+ education did not belong in schools”.

Michelle Rider, a petition supporter, was quoted as saying: “Parents are angry. We are watching our children being sexualised through school and arts programs that expose them to adult sexual and gender themes.”

“Many parents see this pattern as grooming: the gradual normalisation of adult sexual content and contested ideologies to children who are not developmentally ready.”

In April this year, the ABC announced an end to its ties with ACON and its lobbying schemes following external concerns about the effect on the public broadcaster’s impartiality. Former ABC managing director David Anderson had won Pride in Diversity’s “CEO of the Year” award.

ACON’s projects are modelled on the UK charity Stonewall—a gay liberation campaigner turned trans rights lobby—and its Diversity Champions program and Workplace Equality Index. But the credibility of Stonewall, which promotes gender identity over biological sex, has been seriously damaged.

Many of Stonewall’s members have withdrawn from its lobbying vehicles in recent years, among them the BBC, the UK Cabinet Office, the Ministry of Justice, the Department of Health, the Equality and Human Rights Commission, the school standards regulator Ofsted, NHS England, the Royal College of Paediatrics and Child Health, Police Scotland, and the media and communications regulator Ofcom.

Stonewall has been criticised for its unbalanced trans rights demands at the expense of women and (same-sex attracted) gays and lesbians, and its promotion of the gender medicalisation of minors based on alarming but unreliable data on attempted suicide. For these reasons, together with the conflicts of interest occasioned by competing to implement Stonewall’s ideological agenda, many employers have decided the reputational and legal risks of membership are too high.

Writing for Legal Feminist in 2021, lawyer Naomi Cunningham noted that more than 850 companies, charities, government departments and public authorities had signed up with Stonewall in its heyday.

“It’s easy to see what’s in it for Stonewall. They’re a lobby group. Persuading people to their way of thinking is what they’re for; and if people are willing to pay them substantial sums of money for the privilege of being intensively and elaborately lobbied and then catechised on the degree to which they have absorbed and implemented the lobbying, what’s not to like?” she said.

“What’s more mysterious is why serious organisations full of serious grown-up professionals are willing to submit to these time-consuming indignities. How does it come about that magic circle law firms, government departments, universities and the rest are prepared to be so publicly suckered?

“You might think employers would discern a significant reputational risk—not only from being associated with an organisation that has suffered Stonewall’s recent run of startling lapses of corporate judgment (their extraordinary attempt to silence a black lesbian barrister by complaining to her chambers and their irresponsible promulgation of scaremongering claims about effects of the recent High Court decision in Keira Bell’s case on the mental health of young people are just two examples)—but also simply in being publicly taken for this ride.”