The updated policy came into force on April 1 and continues the practice of allowing transgender women to play in amateur women’s competitions if they have had reduced testosterone levels for at least a year.
Campaigners had wanted football to follow sports such as rugby union and hockey by restricting women’s matches to those who were born female, with an open category for all other players.
Instead, about 20 transgender women registered to play amateur football in England can continue to do so if their testosterone levels
The new FA rules state: “Where there is an issue about a player’s eligibility, efforts will always be made to resolve it through dialogue between the player, the county FA and the FA.
“In any case where (1) the FA does not approve a player’s application to participate in matches in the women’s game following a match observation, or (2) the FA reasonably considers on the ground of (A) safety to competitors and/or (B) fairness of competition that it might be necessary to withdraw a player’s eligibility to participate in matches in the women’s game having previously granted such eligibility under this policy, the player or the FA may refer the matter to the FA’s Transgender and Non-Binary Eligibility Committee for determination.”
Players’ medical records of hormone therapy have to be verified at least annually, before the start of each season, “and more often at the FA’s discretion”, according to the rules.
Clark was the first openly trans referee before becoming Sutton manager. There are about 20 transgender women registered to play amateur football in England
There are no transgender women playing in or even close to the elite level in England. It is understood that if this changes, the FA would seek advice from Fifa — however the policy of world football’s governing body is also around reduced testosterone levels, rather than a full ban.
In September Sutton United women’s team postponed their fixture against Ebbsfleet United after the club were criticised for signing a transgender goalkeeper, Blair Hamilton. Sutton’s manager, Lucy Clark, was the first openly trans referee before her appointment by the club in January 2024.
There have been no cases to date of transgender women wishing to play in professional or international women’s football.
The new FA policy follows a lengthy review and has been drawn up with input from two KCs. The FA is understood to wish to promote inclusion as a priority but to be able to intervene when there are concerns.
In November there was a protest against the FA’s transgender policy outside Wembley before the England men’s match against Ireland in response to a 17-year-old girl being banned for two matches over remarks she made to a transgender opponent in a grassroots match. She was sanctioned after she was found to have repeatedly asked a transgender opponent during a match: “Are you a man?”
Last month the FA’s chief executive, Mark Bullingham, said the governing body was “in the right place” with its transgender eligibility policy. “We do continue to look at areas that we might refine,” he added.