The Growing Up Transgender Blog (TGUTB) has investigated the pilot study known as R22. Commission in 2024, following recommendations cited in the Cass Review.

The blog has revealed many concerns about the pilot. From using research that's 40 plus years old to it risking harm to the children participating in the study.

Risk Of Harm

TGUTB highlights the omission of potential harms from the risk identification section of the study.

“The pilot has a risk identification section. It talks about a ‘risk’ of equity complaints from families of under tens who are not able to access the pilot. It does not include a risk of complaints from families and advocates related to the harms of the pilot. It completely fails to recognise the highly well established ‘risk’ of the pilot causing significant harm to trans children whose childhood rejection is encouraged and enforced by this ‘support’.”

The study is criticised for including social transition as a risk:

“Here risk due to social transition is explicitly labelled a risk factor. Of course there is nothing about ‘risk due to family cis-ignorance’, ‘risk due to conversion practices’, ‘risk due to parental transphobia”, ‘Risk due to parental rejection”. Social transition, or even ‘future social transition’ is to be considered a risk.”

The Use Of Outdated Research

TGUTB reveals the extent to which old research into gender identity is being used in the study. The blog reports:

“Four key references are presented as shaping this project:

1968 Kohlberg Gender Constancy Theory

1981 Gender Schema Theory

1950 Identity Development Theory

1966 Marcia Adolescent Identity

These are all incredibly old references. They are extremely dated pieces of work, written at times where trans children’s identities were not understood in academia. They aren’t even focused on trans kids. They provide nothing of use of trans children.”

TGUTB goes on to question why the study is not using more up-to-date research:

“Modern psychology research on trans children is completely missing. There is zero reference to work specifically on the same topics refenced above, that actually focused on trans children, including:

2015 Olson, K.; Key, A.; Eaton, N. Gender Cognition in Transgender Children

2018 Gender Development in Transgender Preschool children Olson & Fast

These studies of trans children’s identity development is omitted for purely political reasons. Because it directly contradicts the base assumptions of this whole pilot.”

The study is scheduled for review today (03.03.2026).