After the utter debacle surrounding the UK EHRC's initial guidance, it seems that their revised guidance has leaked. The Times has seen it – here's a non-paywalled secondary source:

Trans people may be banned from single-sex spaces based on looks, say leaked docs

TRANSGENDER people could be banned from single-sex spaces based on what they look like, according to a leaked copy of a document

Laura Pollock

This is a spectactularly bad idea. It gives free rein to anyone who wants to police other people's looks the go ahead to abuse people. And I do mean all people here, cis and trans, because they really can't 'always tell'.

I'm a trans woman who tends toward the high-ish femme end of the spectrum by my own preference. I pass as cis face-to-face, and after a lot of voice training also do so on the phone. I don't tend to make photos of myself very public because I value my own safety, so you're going to have to just accept this as written.

Trans people are a tiny percentage of the population. Some of us 'look' trans. Many don't. But the bigger problem here is that this also applies to cis people. A substantial proportion of cis women aren't anything like as femme-presenting as me, and as-such are way more likely to be excluded. Since cis women are roughly half the population, way more cis women than trans women will be affected by this idiotic legislation, just by sheer weight of numbers.

The nonsensical nature of this argument can easily be laid bare: if trans women are such a danger to cis women (which is blatantly untrue anyway, but even letting that slide for a second), why are cis-passing trans women somehow given a pass, whilst a whole spectrum of cis women are excluded on the basis that they (checks notes) might be trans?

What a load of absolute fucking bollocks.

Let's just see this for what it is: an attempt to force women – all women, cis and trans – into rigid, narrow gender roles, on pain of exclusion from society. And let's also not miss the fact that this has considerable racist overtones, because the standards of femininity we're talking about here are those of idealised cis white high femme presenting women. Black and brown women have historically been seen as less femme, more masculine, so this will inevitably be seen here.

Can we just cut to the chase and bury this total fucking stupidity, before another genration (and most likely the EHRC's anagramatic nemesis, the ECHR) has to fight to slap it down?

For the record: this legislation would basically give me a free pass. I'm really very far from wanting to accept that privilege at the cost of the freedom of other women, both cis and trans.