The Telegraph has revealed Stonewall’s private access to Downing Street during the development of Labour’s Conversion Practices Bill. Parliamentary evidence shows the charity pressing for wider prohibitions and narrower clinical safeguards, while its commissioned research supplies the Government’s principal estimate of the problem. The disclosures raise questions about legislative independence, financial interests and the future of parental and religious freedom.
Stephen Kiely, Stonewall’s Head of Policy and Public Affairs, appears to have enjoyed a particularly productive October. Having attended the Conservative Party conference, he subsequently visited Number Ten, the Department for Education and Parliament to discuss the Government’s proposed Conversion Practices Bill. He was sufficiently pleased with these engagements to publish photographs of himself outside Downing Street and announce them on LinkedIn. There was no apparent need for secrecy. Stonewall has spent eight years campaigning for legislation of this kind, and its representatives were now discussing the proposals with those responsible for developing and examining them.
On 5 November, Daniel Martin, the Daily Telegraph’s Deputy Political Editor, reported that Stonewall had helped Labour develop its proposed legislation, with the Government relying upon research commissioned by the charity to justify creating new criminal offences. The report also disclosed that organisations holding contrary positions had not enjoyed comparable access to Downing Street.¹
The precise nature of Stonewall’s involvement in drafting the Bill remains undisclosed. Its access to government is confirmed by Kiely’s own account, while its influence upon the public argument for legislation is evident in the Government’s published impact assessment. What Parliament has yet to establish is which recommendations Stonewall made privately, how ministers assessed them and whether they were incorporated into the legislation.
That distinction is important. Political access does not establish improper influence, and charitable organisations are entitled to advocate changes in the law. Nevertheless, when legislation carries a potential five-year prison sentence and reaches into family relationships, clinical decisions and the exercise of religious conscience, those who have helped shape it should expect their evidence and recommendations to withstand examination.
Stonewall’s ambitions are hardly concealed. When the draft Bill appeared in June, its chief executive, Simon Blake, celebrated the charity’s having played a central role in the campaign and promised further efforts to prevent loopholes. The charity’s published objectives expressly include shaping legislation through partnerships with policymakers.²
A charity campaigning to change the law is entitled to pursue its objectives. The Government, however, is responsible for evaluating those objectives against the interests and rights of the wider public. The distinction becomes particularly important where the campaign seeks to establish criminal prohibitions upon conduct involving speech, persuasion and moral instruction.
Dennis Kavanagh, a criminal barrister and director of the Gay Men’s Network, told the Telegraph that his organisation had not received the access afforded to Stonewall. He described that access as extraordinary, given what he regarded as Stonewall’s extreme position on gender matters and its poor record of legal interpretation.
Maya Forstater, chief executive of Sex Matters, made a related complaint. Her organisation had secured one short official meeting with Olivia Bailey while Bailey was the minister responsible for the draft, but nothing resembling Stonewall’s reported access.
These complaints should be understood precisely. Both organisations subsequently gave evidence to the Joint Committee examining the legislation. Their representatives have therefore been heard in Parliament. What remains uncertain is whether competing organisations received comparable opportunities to influence the proposals before they reached that stage.
The Government insists that it consulted supporters and opponents, including Sex Matters and LGB Alliance, and denies relying upon any single source of evidence. That response deserves to be recorded. It also makes disclosure of the consultation record a straightforward means of resolving the disagreement.¹
There is an additional reason why Stonewall’s access warrants attention. Its representatives have been unusually specific about the changes they wish Parliament to consider.
Appearing before the Joint Committee on 29 October, Kiely argued that the Bill’s protection for healthcare professionals was too broadly framed. Clause 1 currently provides that conduct undertaken in the course of healthcare services does not constitute a conversion practice unless the practitioner acts far below the standards reasonably expected of someone in that position.
Kiely acknowledged that the provision was designed to protect legitimate clinical practice. His concern was that it could also protect unregulated therapists and counsellors whom Stonewall regarded as engaging in conversion practices.
He proposed restricting the protection to practitioners subject to statutory professional regulation or included on registers accredited by the Professional Standards Authority. The effect would be to make professional registration and compliance with approved standards more important in determining who could rely upon the clinical safeguard.³
There is an understandable argument for ensuring that practitioners providing psychological or medical services are competent and accountable. Yet professional registration cannot resolve every question of clinical judgement. A practitioner may be appropriately qualified and nevertheless mistaken; another may offer responsible assistance without belonging to a particular professional association.
More importantly, the standards of professional bodies do not remove the need for Parliament to define criminal conduct. Professional guidance can change, sometimes substantially. A criminal prohibition should remain sufficiently certain for individuals to understand their responsibilities without having to anticipate every future alteration in regulatory policy.
That concern acquires particular force in the aftermath of the Cass Review, which identified serious deficiencies in the evidence supporting aspects of paediatric gender medicine and called for more comprehensive assessment of young people experiencing gender-related distress. Parliament should be cautious about framing criminal provisions in ways that might discourage the careful examination of psychological, developmental and familial circumstances.
Kiely’s evidence went further.
Under questioning from Sir Jeremy Wright, he supported extending the proposed prohibition to encompass attempts to suppress sexual orientation or transgender identity. He referred specifically to situations in which religious leaders or parents discouraged expressions of homosexuality.
The examples given by the witnesses included preventing individuals from seeing friends, monitoring their movements and withholding food. Such behaviour may plainly amount to abuse, depending upon the circumstances.
The difficulty lies in the breadth of the proposed concept of suppression. Professor Ilias Trispiotis, appearing alongside Kiely for the Ban Conversion Practices Coalition, described it as encompassing efforts to make a person conceal an identity or behave in ways regarded as inconsistent with that identity.
That formulation raises immediate questions about religious moral teaching.
Catholic doctrine distinguishes between sexual inclination and voluntary sexual conduct. The duty of chastity applies to every Christian, although its obligations differ according to state of life. A priest advising someone against sexual activity is exercising a recognised responsibility of spiritual direction. The fact that the recipient experiences a particular inclination does not remove the Church’s authority to teach the moral law concerning conduct.
If attempting to discourage the expression of sexual inclination can itself fall within a criminal prohibition, Parliament must determine where moral instruction ends and unlawful suppression begins.
The distinction is essential. Threatening someone, withholding necessities or subjecting him to humiliation is quite different from explaining that a particular course of conduct is morally impermissible. Catholic teaching condemns unjust discrimination and requires respect for the dignity of persons experiencing same-sex attraction. It also maintains that sexual conduct is subject to moral judgement. Neither principle can simply be discarded to accommodate a contemporary political definition of identity.⁴
The committee’s examination of the word abusive produced an equally revealing exchange.
Sir Jeremy Wright challenged the witnesses concerning the Bill’s distinction between abusive and non-abusive conversion practices. Trispiotis argued that the distinction should not remain, maintaining that conversion practices were inherently abusive.
Baroness Browning subsequently asked whether that position was shared by the other witnesses. Both Kai O’Doherty of Galop and Kiely answered affirmatively.
This is significant because the Government’s present legislation requires more than an intention to influence sexual orientation or transgender identity. It requires conduct amounting to abuse and resulting in serious harm or serious distress.
The witnesses did not all propose removing every criminal threshold, and their evidence should not be represented as an agreed demand to imprison people for harmless conversations. Nevertheless, their objections to the distinction between abusive and non-abusive practices reveal a preference for a broader statutory approach than the Government has presently adopted.³
Baroness Brown of Silvertown then asked about prayer offered to someone struggling with questions of identity. Trispiotis acknowledged that the circumstances would be decisive and that prayer specifically intended to change someone’s sexual orientation might fall within the legislation if the necessary harm threshold were satisfied.
That answer recognises the present Bill’s legal limitations. It also explains why the proposed expansion of its definitions deserves close examination.
A person may seek prayer voluntarily. He may ask a priest to help him resist temptation, live chastely or reconcile his conduct with Catholic teaching. Religious counsel often involves encouraging a change of behaviour and sometimes a change of belief. Whether the state should regard that activity as potentially criminal cannot be determined by applying an elastic definition of suppression without examining consent, intention, conduct and harm.
The Telegraph disclosures also return attention to the evidence used to justify the legislation.
The Government’s impact assessment estimates that between 75,000 and 93,000 people experience conversion practices annually in England and Wales. This is an arresting figure, suggesting a widespread contemporary phenomenon requiring a new criminal offence.
Its derivation is less impressive than its apparent precision.
The Government used research undertaken by Opinium in 2024 and commissioned by Stonewall. The survey reported that approximately 11 per cent of respondents had experienced at least one of several specified practices during the preceding twelve months.
Rather than adopt that entire figure, officials selected two categories: respondents who reported being told to ingest supposedly purifying substances, and those reporting what they described as pseudo-scientific counselling.
Combining these categories produced a central estimate of 4.7 per cent. Officials then applied an adjustment of half a percentage point in either direction, yielding a range of 4.2 to 5.2 per cent, which they multiplied by an estimated LGBT+ adult population of 1,784,842.
Thus emerged the estimate of 75,000–93,000 people annually.⁵
The Government describes the survey as the strongest suitable recent evidence available. It also admits that there are no comprehensive official statistics establishing the prevalence of conversion practices, that the estimates depend upon substantial assumptions, and that some reported experiences may fall outside the proposed criminal offence.
The calculation is therefore a population extrapolation from self-reported experiences. It is not a count of independently verified incidents or of conduct satisfying the statutory threshold.
This distinction formed part of Nuntiatoria’s investigation of 30 October, The Evidence Parliament Must Not Take on Trust, which examined the methodological problems in Galop’s evidence and the Government’s reliance upon campaigning research.
Our earlier examination identified numerical inconsistencies in Galop’s published report, the absence of essential denominational information in several religious cases, and the difficulty of distinguishing ordinary prayer or therapeutic exploration from genuinely abusive interventions on the basis of abbreviated case notes.
Those concerns remain unanswered by the Government’s prevalence estimate.⁶
The Telegraph drew attention to one particularly striking feature of the Stonewall survey: reported experiences of exorcism.
The underlying research has attracted criticism for an apparent lifetime figure suggesting that approximately one in ten respondents had experienced something described as exorcism. The Government’s impact assessment, however, reports a separate figure of 2 per cent for respondents reporting exorcism during the preceding twelve months.
These figures concern different reporting periods and should not be conflated. The Government itself acknowledges that the survey did not define exorcism and that respondents may have understood the term differently.⁵
That omission is particularly serious when legislation may affect religious activity.
The Catholic Church does not regard every prayer for liberation from evil as a solemn exorcism. The latter is an authorised liturgical act subject to ecclesiastical discipline. Under canon 1172 of the 1983 Code of Canon Law, a priest requires special and express permission from the local Ordinary to perform it. The distinction between a formal exorcism, informal prayer, charismatic deliverance practices and coercive behaviour undertaken under religious pretences cannot be ignored when researchers classify incidents.
The survey’s terminology may describe experiences which deserve investigation. Without adequate definitions, it cannot establish how many formal exorcisms took place, which religious organisations were involved or whether the alleged conduct was authorised.
Stonewall has meanwhile released additional research. Its 2026 survey conducted with YouGov among approximately 3,500 LGBT adults found that 1 per cent reported having undergone conversion practices, with a further 4 per cent reporting that they had been offered them.
These findings are not directly comparable with the earlier annual prevalence calculation. They use different questions and reporting frameworks. Nevertheless, Parliament now has distinct Stonewall-commissioned datasets before it and should require a careful explanation of what each establishes.⁷
There is an obvious institutional question here. The organisation campaigning for the legislation commissioned the research from which ministers have derived their most prominent estimate of the problem. Its representatives subsequently appeared before Parliament seeking to expand the legislation’s scope.
That does not invalidate the research. It makes independent examination particularly important.
The Telegraph investigation introduces another matter which deserves scrutiny, although it requires careful separation of established financial facts from allegations about possible future commercial benefit.
Stonewall has operated substantial workplace equality programmes, most notably its Diversity Champions scheme, through which businesses and public bodies obtained guidance, training and access to associated resources.
At its height, according to the newspaper, the scheme involved more than 900 organisations, with annual membership commonly costing approximately £3,000. Public-sector disclosures confirm that departments and other authorities made payments of this order, sometimes purchasing additional training or services.
The Department for Work and Pensions, for example, disclosed payments for Diversity Champions membership and related activities before withdrawing from the scheme in April 2022. Other public authorities have published comparable expenditure.⁸
Stonewall has since experienced significant financial difficulties.
Its accounts for the financial year ending 31 March 2025 record income of £4,741,953 and expenditure of £5,648,315, a deficit exceeding £906,000. Income had fallen from approximately £6.92 million in the preceding year. The charity undertook restructuring and acknowledged pressure upon its reserves.
Stonewall has attributed its difficulties partly to the wider financial circumstances facing charities and changes affecting the LGBT sector. Its January 2026 statement also reported improved trading conditions following restructuring and the introduction of its Proud Employers programme.⁹
These figures provide useful context because compliance training and institutional guidance have historically formed part of Stonewall’s activities.
Clause 5 of the proposed Bill introduces potential criminal liability for relevant officers of companies and other organisations where an offence has been committed by the organisation and an officer authorised, permitted, participated in, or failed to take all reasonable steps to prevent it.
Kavanagh suggested that this could create demand for compliance advice and training of the kind Stonewall has previously supplied. The possibility deserves examination, particularly where employers might reasonably seek guidance to avoid criminal exposure.
There is, however, no evidence in the material presently available that Stonewall has secured contracts arising from this legislation, that it recommended the provision for commercial reasons, or that ministers adopted it to benefit the charity. It would be improper to imply otherwise.
The relevant question is more limited and capable of investigation: whether organisations participating in the development of regulatory legislation should disclose any foreseeable financial interest in providing compliance services under the resulting law.
Such disclosure would protect the integrity of consultation and the reputations of the organisations concerned.¹⁰
The Government’s response to the Telegraph is also relevant. Ministers denied relying upon a single organisation’s research, emphasised consultation with groups holding differing opinions and maintained that the proposed legislation had the support of professional and safeguarding bodies, including the Royal College of Psychiatrists, NHS trusts and the Domestic Abuse Commissioner.
A Government spokesman said that the objective was to prevent coercion and abuse, and that amendments would be considered following the Joint Committee’s recommendations.¹
That account should be examined against the actual legislative record. The Bill’s stated objective of protecting people from abuse does not resolve whether the proposed offences have been sufficiently defined.
Clause 2 requires an abusive conversion practice causing serious physical or mental harm, or serious alarm or distress substantially affecting ordinary daily activities. The maximum five-year sentence applies upon conviction on indictment.
The legislation does not expressly criminalise every religious disagreement or parental conversation. Its provisions contain thresholds which prosecutors would have to establish, and the Government insists that ordinary parenting and legitimate clinical treatment remain lawful.
Nevertheless, clause 1 requires consideration of circumstances including controlling behaviour, psychological pressure and emotional pressure when assessing abuse. Those concepts may have different implications when applied to a violent relationship between adults and when applied to ordinary parental authority over a child.
Parents sometimes must restrict associations, refuse requests, withhold privileges or prevent conduct which their children regard as deeply important. Their responsibilities may require decisions which cause distress without being abusive. The law must provide sufficient certainty to distinguish such decisions from conduct properly attracting criminal sanction.¹¹
Kavanagh explained this difficulty during the parliamentary hearing. Olivia Bailey MP challenged him to show how a mother encouraging her child to accept his or her body could satisfy the proposed criminal offence.
Kavanagh argued that the intention to influence identity could be established without any intention to cause harm, leaving the courts to determine whether the parent’s words or behaviour amounted to abuse.
His concern was that a combination of disputed definitions, family distress and allegations of coercive behaviour could expose parents to criminal investigations even where conviction would ultimately be unlikely.
Bailey’s challenge was legitimate, since the Bill contains further requirements concerning abuse and serious harm. Yet Kavanagh identified a problem which cannot be dismissed merely by referring to the severity of the eventual sentence. A criminal investigation may itself have profound consequences for family relationships, professional reputations and safeguarding decisions.³
The composition of the parliamentary committee introduces another consideration.
Bailey disclosed that she had been responsible for the initial drafting of the Bill while serving as a minister. Lord Isaac declared that he was a former chairman of Stonewall and knew Kiely through his work with the organisation.
These interests were properly declared. Neither establishes misconduct or disqualifies the parliamentarians from examining the proposed law. Familiarity with the subject may indeed assist scrutiny.
It also makes the committee’s independence particularly important. Its task is to test the legislation, including the assumptions and recommendations of those involved in developing it, rather than merely provide a further opportunity for established positions to be restated.³
The report by Baroness Kishwer Falkner and Akua Reindorf KC, Not What It Says on the Tin, has already raised substantial questions concerning the breadth of the proposed offences, the protection afforded to parents and clinicians, and the preventive civil orders.
As Nuntiatoria observed in its editorial of 6 November, Conversion Practices: The Law That Reaches into the Family, the principal concern is legal certainty. Citizens must be able to determine whether their conduct is lawful before undertaking it, particularly where ordinary family decisions or professional responsibilities may be involved.¹²
The latest intervention from Archbishop John Sherrington of Liverpool, chairman of the Department for Social Justice of the Catholic Bishops’ Conference of England and Wales, gives those concerns particular ecclesiastical significance.
In a statement issued on 10 November, Archbishop Sherrington warned that the legislation could interfere with religious freedom, pastoral care and ordinary family relationships. He recognised the duty to protect people from abuse but questioned the proposed extension of criminal law into areas of legitimate personal and religious responsibility.
He expressly called upon politicians to abandon the Bill and concentrate upon enforcing existing protections and providing accessible support to those experiencing abuse or coercion.¹³
His intervention reflects an established principle of Catholic social teaching.
In Divini Illius Magistri, Pius XI defended the prior rights and duties of parents in the education of their children, while recognising the legitimate authority of the state to intervene where children are neglected or abused.
The distinction is essential. Parental authority is neither absolute nor merely delegated by government. It arises from the natural responsibilities of family life and is exercised under moral obligations which include the welfare and dignity of children.
The state possesses a genuine duty to protect the vulnerable. Its authority must nevertheless be exercised with respect for the proper responsibilities of parents and the freedom of religious institutions to teach their doctrines.¹⁴
For the Catholic Church, moral teaching concerning sexuality is integral to the faith. The obligation of chastity, the understanding of marriage and the distinction between sexual inclination and voluntary conduct are not matters which a priest may simply abandon because a political organisation regards their expression as potentially suppressive.
The Church’s teaching also requires that people be treated with charity and respect. Threats, humiliation and coercion cannot be justified as methods of securing conformity to religious doctrine.
The legal question is whether Parliament can preserve these distinctions clearly enough to protect genuine victims without bringing lawful pastoral and parental responsibilities within the reach of uncertain criminal prohibitions.
That question is now being asked beyond religious circles. Criminal lawyers, professional bodies, campaigners concerned with gender medicine and members of Labour’s own parliamentary party have raised objections about the potential consequences for parents, therapists and teachers.
Their arguments differ, and they do not necessarily agree about the appropriate legislative remedy. They nevertheless demonstrate that the disagreement cannot adequately be described as a contest between supporters and opponents of protecting LGBT people from abuse.
The Government is entitled to argue that existing criminal offences leave gaps. Assault, sexual offences, harassment, forced marriage and certain forms of coercive control are already prohibited, but some harmful conduct may fall outside those offences because of the circumstances or relationships involved.
The proper parliamentary task is to identify those gaps and determine whether narrower amendments could address them with greater certainty.
Stonewall and other campaigners maintain that the existing law fails to protect people experiencing repeated manipulation, isolation and psychological abuse. Those concerns deserve consideration. So do the questions raised by clinicians about exploratory treatment, parents about safeguarding their children, and religious ministers about the ordinary exercise of pastoral responsibility.
What should concern Parliament is the possibility that a broad new criminal framework may be constructed before the precise deficiencies in existing law have been satisfactorily demonstrated.
The present revelations add a question about the integrity of the legislative process.
Stonewall’s access to Downing Street is established. Its contribution to the Government’s statistical case is documented. Its representatives’ demands for wider provisions are recorded in parliamentary testimony. Its previous commercial activities and financial difficulties are matters of public record.
These facts do not prove that Stonewall wrote the legislation or sought to profit from it. They do establish several legitimate subjects for further inquiry.
The Government could resolve much of the uncertainty by publishing the relevant consultation record, identifying the recommendations it received from Stonewall and other interested organisations, explaining which were accepted or rejected, and supplying the independent assessment undertaken of the research used in its impact calculations.
The Joint Committee is accepting written evidence until 5 pm on Monday 16 November 2026, with its report due by 22 January 2027. Parliament therefore has an opportunity to examine these matters before the legislation proceeds further.¹⁵
Stonewall is free to campaign for the law it wishes to see enacted. Its opponents are equally entitled to challenge its evidence, definitions and recommendations. Neither can claim the authority of Parliament merely because its representatives have been received by ministers.
The responsibility for the legislation rests with the Government, and ultimately with Parliament. It is their duty to establish which conduct requires criminal prohibition, how the proposed offences will operate and whether the rights of those affected have been properly safeguarded.
There is sufficient evidence of Stonewall’s access and advocacy to justify asking what influence it exercised. The private advice remains undisclosed, and the documents currently available do not establish precisely how the legislation was drafted.
That is the finding which now requires further investigation. Downing Street should be able to explain whose representations shaped the Bill, how competing advice was considered and why its chosen provisions are necessary.
The Government is proposing criminal offences carrying substantial penalties. The public is entitled to something more substantial than an assurance that everyone concerned means well.
¹ Daniel Martin, The Daily Telegraph, Stonewall helped Labour draw up ‘chilling’ trans law, 5 November 2026, 7.49 pm GMT.
² Stonewall, ‘Government Finally Publishes Long Overdue Draft Bill to Ban Conversion Practices’, 25 June 2026.
³ UK Parliament, Joint Committee on the Draft Conversion Practices Bill, ‘Oral Evidence, 29 October 2026’, questions 2, 6–18, 22–24 and 37–57, uncorrected transcript.
⁴ Catechism of the Catholic Church, ‘The Vocation to Chastity’, nn. 2337–2359.
⁵ Office for Equality and Opportunity, ‘Draft Final Stage Impact Assessment’, dated 18 June 2026, Annex A and accompanying methodological notes.
⁶ Nuntiatoria, ‘The Evidence Parliament Must Not Take on Trust’, 30 October 2026.
⁷ Stonewall, ‘LGBTQ+ Life in the UK: 2026’, October 2026.
⁸ Department for Work and Pensions, ‘Stonewall: Written Parliamentary Answer’, 7 March 2024; Greater London Authority, ‘FOI: Payments to Stonewall’, October 2024.
⁹ Charity Commission, ‘Stonewall Equality Limited: Financial Information’, year ending 31 March 2025; Stonewall, ‘Annual Report 2024/25’, 6 January 2026.
¹⁰ Office for Equality and Opportunity, ‘Conversion Practices Draft Bill’, clause 5.
¹¹ Office for Equality and Opportunity, ‘Explanatory Notes to the Draft Conversion Practices Bill’, clauses 1–5 and Schedule.
¹² Policy Exchange, ‘Not What It Says on the Tin’, Baroness Kishwer Falkner and Akua Reindorf KC, 2 November 2026; Nuntiatoria, ‘Conversion Practices: The Law That Reaches into the Family’, 6 November 2026.
¹³ Catholic Bishops’ Conference of England and Wales, ‘Archbishop’s Statement on the Draft Conversion Practices Bill’, 10 November 2026.
¹⁴ Pius XI, Divini Illius Magistri, 31 December 1929.
¹⁵ UK Parliament, ‘Draft Conversion Practices Bill: Joint Committee Inquiry’, evidence deadline and parliamentary timetable.
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