HEC Briefing: Sullivan Review
By Matilda Fitzmaurice and Bijan Parsia
The authors would like to record their thanks to Jay Todd and Felicity Callard for their invaluable work that made this briefing paper possible.
Context
The Sullivan Review Into Sex and Gender in Research Data (hereafter the SR) was announced by Michelle Donelan, then the Secretary of State for Science, Innovation and Technology in October 2023, with the Terms of Reference[1] published in February 2024. The Review is named for its lead author, the UCL sociologist Professor Alice Sullivan, who was commissioned by the government to complete the review. Its commissioning should be seen in the context of the then-government’s anti-woke drive, including the supposed need to safeguard scientific research “from the denial of biology.”[2] The SR’s terms of reference said it would (1) identify barriers to rigorous data collection of sex and gender within public institutions and research systems, and (2) develop best-practice guidelines for data collection in these areas. According to its stated aim, the SR intends its recommendations to be implemented across a wide remit of institutions, including government, universities, research organisations and the health service. The SR is composed of two volumes: SR1 covers data and statistics, while SR2 covers barriers to research.
There is already evidence of this implementation in organisations relevant to our sector. For example, the Higher Education Statistics Agency (HESA) has altered its data collection practices around ‘biological sex.’[3] This appears, mistakenly, to have been a response to the EHRC Code of Practice, which came into statutory force on 5th August 2026. The Code of Practice for Services, Public Functions and Associations does not affect the collection of this kind of data.
The SR should be seen as part of a growing trend. The academic researcher Kevin Guyan[4] has coined the term “trans-exclusionary data activism” to describe this broader move to reshape how public bodies collect, analyse and use data on sex and gender, and how such data can be mobilised in order to erase marginalised communities. Elsewhere, the geographers Jay Todd and Felicity Callard have written the first peer-reviewed, article-length critical response[5] to the SR, from which this briefing paper heavily draws.
The aim of this paper is, first, to brief HEC members on the recommendations made by this review, and, second, to highlight the wide range of areas in which these recommendations, if implemented, could have far-reaching undesirable implications. These are not restricted to the autonomy and rights of trans and gender-diverse people, but also threaten to undermine the legitimacy of critical scholarship, as well as scholarship in biology on the complexities and nuances of ‘sex’. It also puts at risk established principles of ethical research and intersectional feminist praxis that many have long fought to embed within institutions.
SR Recommendations
The bullet points below list a summary of the recommendations made by the SR.
● A ‘biological’ conception of ‘natal sex’ to be used as the default mechanism for recording sex across governmental and quasi-governmentally commissioned research and data collection. It recommends that only two binary options - male and female - be offered. It does not propose an additional category for people who are intersex or who have variations of sex characteristics (I/VSC). Sex is also to be assumed to be in line with “reproductive function"[6]
● That data collection around “transgender identities” should only be supplementary to that around ‘biological sex’, while the term ‘gender’ should be avoided in question wording. Trans identities, though not denied, are made into questions of “individual psychology”[7]
● That universities should consider paring back the scope and power of research ethics committees for “low-risk research” with “children or vulnerable populations” (though no definition of ‘low-risk research’ or ‘vulnerable populations’ are offered)[8]
Implications for Research and Equality Practice in HE
● The SR promotes the erasure of trans people in the name of ensuring ‘clarity’, stating that only categories understood to be ‘mainstream’ and ‘scientific’ should be used. Trans lives are therefore positioned as at odds with truth and scientific legitimacy.
● The SR’s recommendation of an “observed sex” approach to recording sex in “some face-to-face contexts”[9] would remove a research participant’s autonomy in defining their own sex. The implications of this approach being extended to, for example, the recording of data on race/ethnicity or disability are extremely troubling.
● The SR’s call for universities to pare back the power and scope of university ethics committees, including for undergraduate research, is of pedagogical concern for those who teach social research methods. Additionally, its recommendation that ethics committees should not refer researchers to EDI committees for advice appears to undermine EDI professional practice and expertise.
● Relatedly, if an individual is referred to as ‘male’ or ‘female’ against their will or without their knowledge, this risks violating principles of participant dignity and autonomy, which are front and centre in guidelines produced by the Economic and Social Research Council (ESRC) and the UK Research Integrity Office. [10] Similarly, the SR states[11] that “community and campaigning groups should not be assumed to have expertise in question design”, which goes against established norms of marginalised community engagement and ownership over the design of research, as well as of the data it generates.[12]
● More broadly, “gender identity theory” is positioned as being outside of “truth-seeking norms”,[13] with the tacit implication that scholarly inquiry utilising these frameworks is illegitimate. Further, the claim that ‘biological sex’ represents an “ordinary mainstream view” that is not political and therefore should not be questioned, is antithetical to critical scholarship that unsettles categories of, for example, race and gender. As Todd and Callard argue,[14] “calls to depoliticise research and science are themselves ideological.”
● Relatedly, the SR suggests[15] that identity categories and data collection regimes should be subjected to unwarranted, and inappropriate, public approval. Why, for example, should the general public’s understanding of the meaning of ‘transgender’ supersede an individual’s right to autonomy in how they define themselves?
● Potential risk to academic freedom: there are serious implications inherent in a government-commissioned report stating that some forms of critical inquiry are undesirable, ‘unscientific’ and should be avoided.
[1] Department for Science, Innovation & Technology (2024) Review of Data, Statistics and Research on Sex and Gender: Terms of Reference. 29 February. https://www.gov.uk/government/publications/review-of-data-statistics-and-research-on-sex-and-gender-terms-of-reference/review-of-data-statistics-and-research-on-sex-and-gender-terms-of-reference
[2] See Rabesandratana T (2023) UK government vow to end ‘woke’ science draws rebuke from researchers. Science, 17 October. https://www.science.org/content/article/uk-government-vow-end-woke-science-draws-rebuke-researchers
[3] HESA (2026) Sex identifier (SEXID). https://www.hesa.ac.uk/collection/26056/datadictionary.html?element=Student_SEXID
[4] Guyan K (2026) Trans-exclusionary data activism in the UK. Journal of Gender Studies https://doi.org/10.1080/09589236.2025.2611975
[5] Todd J & Callard F (2026) A Critical Response to the UK’s ‘Sullivan Review’ into Sex and Gender in Research Data. Transactions of the Institute of British Geographers 51(2). https://doi.org/10.1111/tran.70057
[6] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 1. UCL Social Research Institute. https://assets.publishing.service.gov.uk/media/67d98b8a4ba412c67701ed92/review-of-data-statistics-research-on-sex-and-gender.pdf, p. 18.
[7] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 1, p. 19
[8] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 2. UCL Social Research Institute. https://sullivanreview.uk/barriers.pdf, pp. 16-17.
[9] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 1, p. 8.
[10] See UKRI: ESRC (2025) Our Principles: Research Ethics Committees. 12 May. https://archive.ph/qAGsB
[11] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 1, p. 12.
[12] See, for example, Howard J (2024) Participatory Action Research. https://www.participatorymethods.org/methodology/participatory-action-research/
[13] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 2, p. 30.
[14] Todd & Callard (2026) ibid, p. 4.
[15] Sullivan A (2025) Review of Data, Statistics and Research on Sex and Gender. Report 1, p. 10.