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The Gender Recognition Act 2004 (the Act) sets out a number of requirements for applicants when applying for a Gender Recognition Certificate (GRC). These include that applicants must provide two medical reports, at least one of which must be from a registered medical professional working in the field of gender dysphoria. At least one of the reports must also set out details of a diagnosis of gender dysphoria, and any surgery and treatment that has been undertaken, or is planned, for the purpose of modifying sexual characteristics.
Many people who are transitioning will undergo some form of this kind of surgery and medical treatment. Some applicants are unable to undergo surgery for other medical reasons. However, there is no requirement under the Act for an applicant to have undergone gender reassignment surgery in order to obtain a GRC. Each application under the Act is dealt with on a case by case basis, and no data is held on the genitalia of the applicants.