Four models around the world
- Self-determination: a declaration is enough, with no medical certificate or court. Argentina (2012, the first), Denmark (2014), Malta (2015), Ireland (2015), Norway (2016), Belgium (2018), Luxembourg (2018), Portugal (2018), Uruguay, Chile, Iceland, Switzerland (2022), Spain (2023), Finland (2023), New Zealand (2023), Germany (2024).
- A court or administrative procedure without surgery: a judge, registrar or panel checks that the person lives in the claimed gender; no sterilisation or operation. United Kingdom (Gender Recognition Certificate), France (2016), Italy (2015), Netherlands (2014, with an expert's statement), Austria, Canada (by province), Australia (by state), Greece (2017), Poland (by lawsuit, for want of a law), Brazil (2018), Colombia, Mexico City and some twenty Mexican states, South Africa (2003).
- Change subject to heavy medical conditions: surgery, sterilisation or single status required. Japan (2004 law: surgery and unmarried status; the sterilisation requirement was struck down in October 2023), Turkey (article 40 of the Civil Code: 18, unmarried, surgery), South Korea (case law, surgery in practice), Iran (allowed since a 1987 fatwa by Khomeini, with subsidised surgery — and pressure on gay people to "transition"), Ukraine, parts of Eastern Europe.
- Prohibition: no procedure, or recent repeal. Russia (July 2023 law banning any change of legal gender and any medical transition, annulling marriages), Hungary (2020: "sex at birth" is final), Bulgaria (Supreme Court 2023), Georgia (2024), Kazakhstan, most of Africa and the Arab world.
United Kingdom and Ireland
- United Kingdom. The Gender Recognition Act 2004 lets a person over 18 apply to the Gender Recognition Panel for a Gender Recognition Certificate with a diagnosis of gender dysphoria from a specialist, a second medical report, and evidence of two years living in the acquired gender; no surgery is required, the fee is £5, and the certificate gives a new birth certificate. Changing one's name needs no certificate: a deed poll (free if unenrolled) and updated passport, driving licence and bank records — the passport accepts the new gender marker with a doctor's letter. Scotland's 2022 self-identification bill was blocked by the UK government in 2023. In April 2025 the Supreme Court ruled in For Women Scotland that "woman" and "sex" in the Equality Act 2010 mean biological sex, so a trans woman with a GRC may lawfully be excluded from single-sex spaces and services; the EHRC issued guidance accordingly. NHS gender clinics have waits of several years; puberty blockers for under-18s have been banned indefinitely since December 2024 outside clinical trials.
- Ireland. The Gender Recognition Act 2015 allows self-declaration from 18 (16–17 with a court order and medical opinion); Ireland was among the first countries to adopt self-ID; no non-binary option yet.
United States, Canada, Australia, New Zealand
- United States. Everything depends on the state: about twenty accept a simple declaration for birth certificates and licences, others require a doctor's letter, and a few (Tennessee, Montana, Kansas, Oklahoma, Texas for birth certificates) refuse any change. Since January 2025 the federal government recognises only sex at birth on passports (end of the "X" marker and of changes, upheld by the Supreme Court on an emergency basis in November 2025); 27 states ban gender-affirming care for minors, and the Supreme Court upheld Tennessee's ban in Skrmetti (June 2025). Social security records can no longer be changed either.
- Canada. A provincial matter: all provinces allow a change without surgery, most by statutory declaration (Ontario, British Columbia, Alberta, Quebec from 14 alone); the federal passport offers an "X" marker since 2019, and gender-affirming surgery is publicly funded in every province with waits of one to three years.
- Australia. A state matter: Victoria (2020), Tasmania, ACT, Queensland (2024), the Northern Territory and, since 2024, New South Wales no longer require surgery; Western Australia still has a Gender Reassignment Board. Passports accept "X" on a doctor's letter. Medicare covers hormones and part of surgery.
- New Zealand. Since June 2023, a statutory declaration to Births, Deaths and Marriages changes the sex on the birth certificate (M, F or X), from 16 with a guardian's consent, from 18 alone.
India, Pakistan, Africa
- India. The Supreme Court recognised a third gender in NALSA (2014); the Transgender Persons (Protection of Rights) Act 2019 gives a certificate of identity from the District Magistrate, but requires proof of surgery to record "male" or "female", which activists contest.
- Pakistan. The Transgender Persons Act 2018 allowed self-perceived identity on the national identity card; the Federal Shariat Court struck down its core provisions in May 2023, and the matter is before the Supreme Court. The khawaja sira community remains recognised in practice.
- South Africa. The Alteration of Sex Description Act 49 of 2003 allows the change on the basis of medical or surgical treatment (hormones suffice), through Home Affairs — the only clear procedure on the continent, slowed by administrative delays.
- Nigeria, Uganda, Kenya, Ghana, Tanzania, Zambia, Zimbabwe, Cameroon. No procedure. Uganda's Anti-Homosexuality Act 2023 and Nigeria's Same-Sex Marriage (Prohibition) Act 2014 are used against trans people; Kenya's High Court allowed a name change in 2014 but no gender marker; Botswana's High Court ordered a change in 2017. Malaysia and Brunei punish cross-dressing under sharia enactments; Kuwait repealed its "imitation of the opposite sex" article in 2022.
Europe, Latin America, Asia
Germany replaced its 1980 law in November 2024 with a self-determination act (declaration at the registry office after three months' notice, from 14 with parents); Spain (2023) allows declaration from 16, 14–16 with parents, 12–14 with a judge; France (2016) requires a court but no medical condition, with the first name changed at the town hall; Italy a court without surgery since 2015; the Netherlands an expert's statement; Sweden a new act in force since July 2025 (from 16, light medical opinion). Argentina's 2012 Gender Identity Act, the world model, allows change on request with no age limit and free care; Uruguay, Chile, Colombia, Brazil (at the notary since 2018), Mexico City follow. Japan requires a family court ruling, age 18, unmarried status and no minor children; China allows it after full surgery; Iran with subsidised surgery. Russia banned everything in 2023, Hungary in 2020, Georgia in 2024.
Where talking about it is forbidden
Russia has punished "propaganda of non-traditional relationships" to minors since 2013 and to everyone since December 2022, which covers any positive depiction of trans people online, in the media, books and films; Hungary (2021) bans content "promoting" gender change to minors; Georgia (2024) and Kazakhstan (2025) copied the Russian law; Turkey has been preparing since 2025 a text punishing the "encouragement" of behaviour contrary to biological sex; in the Gulf states, Iran, Uganda (2023 Act: up to twenty years for "promotion"), Indonesia and Nigeria, publishing content on trans issues exposes to prosecution. That is why this site does not offer this section in its Turkish version.
The steps, where it is possible
- Change your name first (deed poll, statutory declaration, registry): the simplest step and the most useful day to day.
- Build the file for the gender change: letters from relatives and employer, a doctor's letter if you are in care, photographs, mail in the new name, proof of the time lived in the gender where required.
- File the application (panel, court, registry or notary depending on the country); three months to a year.
- Update every document: passport, driving licence, national insurance or social security, bank, diplomas, employer, lease, medical records.
- Before any trip, check the destination: a passport marker that does not match the appearance means questioning at some airports and danger in others.
See also the Transgender section, medical transition and being in a relationship with a trans person.
