Five numbers, five ways of counting: what the trans suicide figures circulating in the UK actually measure

Evidence Note

Content note. This note discusses suicide, including the deaths of children. Suicide is preventable. If anything here affects you personally, Samaritans are there day or night, 365 days a year: you can call them free on 116 123 or visit samaritans.org.

Evidence summary

Question: What does each figure count? Can the figures be added up or compared, and can any of them show a suicide rate, a trend, or a difference from the general population?
Overall certainty: Not graded. This note establishes what each figure counts; it assigns no certainty grades.
Reading time: 17 minutes
Companion review: None (standalone Evidence Note)
DOI (all versions): 10.5281/zenodo.23327488
DOI (this version): 10.5281/zenodo.23327489 (Evidence Note EN-025, version 1.0, 13 October 2026) · PDF →
Data and verification: Data processing record → · Source register, claims and verification script on GitHub →

At least five figures presented as counts of suicides among trans people are circulating in the UK. They come from five different sources, using five different ways of counting. Each uses different rules for who is included and how deaths are found, over a different period, and not all of them define a suicide in the same way. Some of the same deaths may appear in more than one figure.

They measure different things, so a difference between them is not a contradiction. But they cannot be added up. And none of these trans-specific figures comes with a suitable denominator for the trans group it covers: the number of people at risk under the same inclusion rules, and the time over which they were observed. So none of them can, on its own, estimate a suicide rate among trans people, show whether that rate is rising, or show how it compares with the rate in another population.

That gap is the finding. It reflects how deaths, and the people at risk, are recorded. In England and Wales, the death certificate has no separate question on gender identity (ONS FOI-2025-2822). ONS says census gender identity estimates “should not be used as precise estimates to support service delivery, but can be used to provide insights” (ONS, Census 2021 gender identity estimates: additional guidance, 26 March 2025). Some gender clinics count the deaths of their patients and others do not, and those that count do not do so in a uniform way (QueerAF, 10 October 2026).

A count of deaths cannot say why any one person died. Suicide “is usually the result of multiple risks acting in combination” (DHSC review, “Suicide risk in gender dysphoria”).

Scope

This note examines five figures and the documents they come from. It asks what each counts. It does not estimate any suicide rate, grade the evidence on suicide risk, or examine why any person died, and it makes no recommendation for or against any treatment or service. It is not a policy position, and no clinical or policy decision should rest on it alone.

The aim is to treat “the evidence is too weak to show benefit” and “the evidence is too weak to show harm” as the same kind of claim, judged by the same rules. Here that means a figure is not dismissed because it supports a conclusion the author would welcome, and is not inflated because it supports one she would not.

The five figures

Figure	Source	Who is counted	Death counted as	Period	Area	How deaths were found
46	National Child Mortality Database: a one-off analysis released under FOI	Children whose death was reviewed by a Child Death Overview Panel, where the records met NCMD’s umbrella definition of trans for this request	Primary category “Suicide or deliberate self-inflicted harm”, as recorded by the panel	Apr 2019 – Mar 2025	England	Child death review records: dropdown fields and free-text searches
104	National Confidential Inquiry into Suicide and Safety in Mental Health, annual report 2026	People aged 10 and over who had been in contact with mental health services in the previous 12 months, reported through the clinician questionnaire as “within a trans … group”	Suicide or undetermined conclusion (in Scotland, an intentional self-harm code)	2016 – 2023	UK and Jersey	Death notifications from national mortality data, then a questionnaire to the responsible clinician
12	Independent review for the Department of Health and Social Care, July 2024	Current and former patients of one service, the youth gender service (GIDS)	Suicide, as recorded in the clinic’s audit; deaths “not confirmed as suicide” set aside	NHS years 2018-19 to 2023-24	One service	The clinic’s own internal audit, summarised by NHS England
50	Good Law Project and QueerAF investigation, April 2026: a journalistic case series	Trans and non-binary people whose death was verified through multiple sources	“Suicide or self-inflicted death” (not defined)	Last ten years	Not stated (framed as UK)	Coroners’ reports, official documents, bereaved families, FOI, media and other sources
21	QueerAF, October 2026: an aggregate of FOI responses	People who died while under the care of an NHS gender clinic, at the three clinics that gave separate figures	Suicide or suspected suicide	Varies by clinic: since 2017, 2012 and 2018	3 of the 13 clinics asked	Freedom of Information requests to gender clinics

Only the 104 comes from a recurring national report, published annually. The 46 is a one-off analysis, the 12 summarises one clinic’s audit, and the 50 and 21 come from journalistic investigation.

Sources: NCMD FOI response (undated); University of Bristol FOI reference FOI2526-321, 5 February 2026; NCISH annual reports 2023–2026 (2024, p. 9; 2026, pp. 6, 10 and 13); DHSC, Review of suicides and gender dysphoria at the Tavistock and Portman NHS Foundation Trust, 19 July 2024; Good Law Project, 25 April 2026; QueerAF, 10 October 2026.

What each one can and cannot tell you

46 (NCMD). This figure comes from England’s national database of child death reviews. Of 647 deaths of children for which a Child Death Overview Panel recorded “Suicide or deliberate self-inflicted harm” as the primary category, which occurred between April 2019 and March 2025 and were reviewed before 25 November 2025, 46 met NCMD’s definition of trans.

That definition is broader than transgender identity. NCMD used “trans” as an umbrella term covering transgender, non-binary, gender questioning, gender transitioning and gender dysphoria. The 46 were drawn from 107 deaths that NCMD identified as LGBTQ+. Those were found through a recorded difference between sex at birth and gender at death, a sexual-orientation field, or checked keyword matches in free-text review fields. The 46 are therefore deaths that met this definition, found in this way, not a count based on a single standard question on gender identity.

This was a one-off analysis for an FOI request, not a routinely published NCMD series. NCMD says its cohort and method “may differ to other NCMD publications”. It says the cohort underestimates all such deaths in the period, because some are not yet reviewed, and that exact-match text searches can miss cases. (NCMD FOI response, methodology notes and Parts 1–3.) The response gives no information on whether a child was known to a gender clinic or on a waiting list.

By year the 46 runs 5, 4, 22, 10, 3, 2. The highest count is 22, in 2021-22. In a follow-up FOI response on the NCMD data, the University of Bristol says the numbers for more recent years will likely be underestimated, because a child death review can take several years to complete. (University of Bristol FOI2526-321.) So the fall after 2021-22 cannot be read at face value. The series cannot by itself say why 2021-22 is high.

The DHSC review notes that NCMD also reported a higher figure for suspected suicides among under-18s as a whole in 2021-22. It says this “may be the result of random fluctuation in small numbers but it does coincide with a crucial year in the COVID-19 pandemic”. (DHSC review, “NCMD figures”.) Good Law Project, writing about the trans figure of 22, says that while the period coincides with the pandemic, “according to official data there was no notable increase in suicides generally”, citing an ONS statistician. It does not address the all-under-18s figure the DHSC review refers to. (Good Law Project, 25 April 2026.)

104 (NCISH). This counts only people who were in contact with mental health services in the year before death, so it misses everyone who was not. Over 2013–2023, mental health patients accounted for 26% of all suicides among people aged 10 and over in the UK and Jersey. (NCISH annual report 2026, pp. 6–7.) That figure covers all patients, not trans patients, so it is not an estimate of what share of trans suicides the 104 captures. NCISH is notified of deaths given a suicide or undetermined conclusion (in Scotland, deaths given an intentional self-harm code), then asks the clinician responsible for each patient’s care to complete a questionnaire. Trans status comes from that questionnaire: the report says 104 patients, about 1% of patient suicides in 2016–2023, were “within a trans” group. (NCISH annual reports 2023, p. 17; 2024, p. 9; 2026, pp. 10 and 13.) The Inquiry’s 2023 report said its 2016–2020 figures for lesbian, gay, bisexual and trans patients, being based on clinical reports, are likely to be underestimates. (NCISH annual report 2023, p. 37.)

The Good Law Project and QueerAF article of April 2026 describes the 104 as covering seven years. The report’s period is 2016 to 2023, which is eight. The same article gives annual figures of 16 in 2021, 34 in 2022 and 20 in 2023. None of the NCISH annual reports for 2023 to 2026 gives a single-year count for trans patients. Each gives a running total: 37 for 2016–2020 (an average of 7 a year), 53 to 2021, 84 to 2022 and 104 to 2023. The figures 16 and 20 equal the differences between successive totals (53 − 37 and 104 − 84). For 2022 the same subtraction gives 31, not 34. But NCISH says figures from previous reports change “as further information is received”, so subtracting one report’s total from the next cannot reliably give a yearly count, even where the arithmetic matches. (NCISH annual reports 2023, p. 37; 2024, pp. 9 and 17; 2025, p. 12; 2026, p. 13.)

12 (DHSC review). This counts current and former patients of the youth gender service at the Tavistock. The review says the deaths occurred at different points in the care system, including while waiting, but it gives no breakdown. It found 5 suicides in the three years leading up to 2020-21 and 7 in the three years after. The review cautioned that the figures are for NHS years, April to March, so the High Court judgment of December 2020 does not fall neatly between the two periods. It concluded the data did not support the claim of a large rise. It also judged it “likely that there has been a rise over a longer period as young people at risk have increasingly presented with gender dysphoria and referrals to GIDS have risen”.

Its caveats include the small numbers, the lack of data on where each person was in the care pathway, and deaths not confirmed as suicide, which it set aside. (DHSC review, “NHS England appraisal of Tavistock audit” and Conclusions.) Good Law Project and QueerAF report that at least two young people who were referred when under 18 were not included: one referred to the youth service at 17 and a half, and one placed straight on the adult waiting list at 17. (Good Law Project, 25 April 2026.)

50 (Good Law Project / QueerAF). This is a verified case series, not a count of a defined population. Its strength is that each death was confirmed through multiple sources. Its limit is that it can only include deaths that left a trace those sources could reach. The article does not define “self-inflicted death”. (Good Law Project, 25 April 2026.)

21 (QueerAF). This comes from Freedom of Information requests to gender clinics. Of the 13 clinics QueerAF asked, three gave separate figures for suicide or suspected suicide: at least 10 at the Tavistock and Portman since 2017, 6 at the Northern Region service since 2012, and 5 at Sheffield since 2018. QueerAF also reports between one and five suicides of people on the Belfast waiting list in 2021, and between one and five at the Welsh service between 2019 and 2025, which are not in the 21.

QueerAF reports that the other clinics could not give suicide figures: some do not hold the data or do not record cause of death, and others withheld small figures because of the risk of identifying people. QueerAF also found at least 618 deaths from all causes, including the 21, in data going back to 2009. That is a floor: figures such as “less than five” deaths a year were left out, two clinics gave no death data, and one did not respond. Clinics gave figures for different date ranges. (QueerAF, 10 October 2026.) Without a defined population at risk and the time each person was under observation, these deaths cannot be turned into a death rate. Comparing them with another population would also need matching periods and adjustment for age.

The QueerAF figure of at least 10 at the Tavistock and Portman since 2017 and the DHSC review’s 12 cannot be directly compared. QueerAF does not say which Tavistock and Portman service its figure covers, while the DHSC review covers the youth service only. The periods also differ, and the DHSC review set aside deaths not confirmed as suicide.

Why they cannot be added up or compared directly

The groups counted overlap but are not nested. A 16-year-old GIDS patient who died could appear in the NCMD figure, the DHSC review, the NCISH figure if they were also a mental health patient, the verified series, and the clinic figure. A 30-year-old adult clinic patient could not appear in the NCMD figure. They could appear in the NCISH figure (if a mental health patient), the verified series and the clinic figure.
“Trans” is identified differently in each. A child death review record, a clinician’s questionnaire, a verified case file and a clinic’s patient list use different criteria, so they can capture different groups of people.
The death being counted is defined differently. The sources variously count a child death review category of “Suicide or deliberate self-inflicted harm”, deaths given a suicide or undetermined conclusion, clinic-recorded suicides with unconfirmed cases set aside, “suicide or self-inflicted death”, and suicide or suspected suicide.
The periods and areas differ. Start and end years differ, from 2012 onward, and some end dates are not stated. They cover one service, three clinics, England, the UK and Jersey, or no stated area.
No source records waiting-list status consistently. Waiting-list status is central to public claims, such as the claim the DHSC review examined.
Recording may change over time. A change in the number of recorded trans deaths can reflect a change in how often trans status is disclosed, recognised or written down, as well as a change in the number of deaths. The DHSC review said a rise in references to gender distress in NCMD cases was more likely to reflect young people “increasingly expressing their distress through conflicts about gender and more frequent recognition by professionals”. (DHSC review, “NCMD figures”.)
None has a suitable denominator. Without the number of trans people at risk and the time they were observed, a change in a count cannot be separated from a change in the number of people at risk. NCISH’s own figures show why this matters: the number of patient suicides rose in 2018, after a change in the standard of proof at inquests, while the suicide rate among patients, taking account of the number of people in contact with services, has fallen in England. (NCISH annual report 2026, p. 7.)

What they cannot tell us about suicide rates

The Good Law Project and QueerAF article is headlined “Trans people are dying of suicide more than the general UK population, data shows”. It says: “Trans people make up less than 1% of the population – but from 2019 to 2025, trans under 18s made up 7% of all child suicides.” (Good Law Project, 25 April 2026.)

The 7% is a share of deaths, not a suicide rate. Of the 647 NCMD deaths, 46 met NCMD’s umbrella definition of trans: about 7%. To compare rates, you would need the number of children in England who met the same definition over the same period. The “less than 1%” does not supply that. The article attributes it to official statistics in development, which is how ONS designates its Census 2021 gender identity estimates. Those estimates cover people aged 16 and over, count people who report a gender identity different from their sex registered at birth, and carry extra uncertainty, although ONS says the headline estimate gives an indication of the size of that population. (ONS, additional guidance, 26 March 2025; ONS, Sexual orientation and gender identity quality information for Census 2021.) NCMD covers children under 18 and uses a broader definition, including gender questioning and gender dysphoria. The areas do not match either: the NCMD deaths are from England, the census estimates cover England and Wales, and the article’s headline refers to the UK. The same denominator problem applies to the NCISH and clinic counts.

The article itself quotes a professor of public health and psychiatry who reviewed its findings, describing the picture as “concerning” but “fundamentally incomplete, making meaningful comparison or quantification of risk impossible”. (Good Law Project, 25 April 2026.)

This does not show that the risk is not higher. The same reviewer says existing evidence, and what is known about the factors that lead to suicide, suggest “transgender people may face higher suicide risk” (Good Law Project, 25 April 2026). The DHSC review describes the evidence on suicide risk in children and young people with gender dysphoria as “generally poor”, but says “there are good reasons to believe that their risk is high compared to other young people”, because of known risk factors they often face (DHSC review, “Suicide risk in gender dysphoria”). What these five figures cannot do is show whether, or by how much, it is higher.

Figures in circulation that do not match their sources

As circulated	What the source says
47 trans child suicides, “England and Wales” (Good Law Project / QueerAF, 25 April 2026)	46 deaths meeting NCMD’s umbrella definition of trans, England only. The same article elsewhere gives 46 for England.
104 “over a seven-year time period” (same article)	2016–2023: eight years
16 in 2021, 34 in 2022 and 20 in 2023 (NCISH) (same article)	None of the NCISH reports for 2023 to 2026 gives a single-year count for trans patients. Subtracting successive totals gives 16, 31 and 20, but NCISH revises earlier figures, so none is a reliable yearly count.
“21 suicides and over 600 other deaths” (QueerAF headline, 10 October 2026)	At least 618 deaths in total, including at least 21 suicides or suspected suicides. Within that disclosed total, 597 deaths were not among the 21 counted as suicide or suspected suicide.
Trans people “less than 1% of the population” but “7% of all child suicides” (Good Law Project / QueerAF, 25 April 2026)	A share of child deaths classed as suicide or deliberate self-inflicted harm, set beside a population estimate with a different age range, definition and area. It is not a comparison of suicide rates.

One both overstates the count and widens its area: 47 instead of 46, and England and Wales instead of England. One understates the period: 2016–2023 is eight calendar years, not seven. One sets a share of deaths beside a population estimate for a different age range, definition and area, which cannot show a difference in rates. The single-year figures for 2021–2023 are not given in any NCISH report we hold. The headline “over 600 other deaths” is not supported by the total the article discloses. Because that total is incomplete, this does not show that the true number of other deaths is only 597; and because some clinics do not record cause of death, some of the 597 may themselves have been suicides.

What would answer the question

There are two different questions here, and they need different data.

Deaths among people referred to gender services. Annual death counts from clinics would not be enough. A rate needs consistent definitions and follow-up of each person. For people referred to gender services, that means recording the period each person is under observation (waiting, in treatment, transferring between services and, where appropriate, after discharge) and finding deaths the same way across services. People who move between services would need to be counted once. That would allow death rates per person-year to be calculated. Comparing them with other populations would also need the same definition of the death counted, matching periods, and standardisation for important differences in population make-up, particularly age. Some clinics do not record deaths or their cause (QueerAF, 10 October 2026), so deaths would need to be found from a source outside the clinic, such as national death records. This would describe people referred to NHS gender services, not all trans people.

Deaths among trans people in the population. This needs death records linked to a population-wide measure of gender identity. ONS has said it could look at further groups in future, for example by linking death records with census records. (ONS FOI-2025-2822.) Census 2021 gender identity estimates cover people aged 16 and over, from a voluntary question. ONS says some respondents may not have interpreted the question as intended, which adds uncertainty, and that estimates for smaller groups should not be treated as precise. (ONS, additional guidance, 26 March 2025; ONS, Sexual orientation and gender identity quality information for Census 2021, updated 8 April 2025.) A census-linked study would classify people by their 2021 census answer, so it would measure deaths by gender identity as reported in 2021, not as it changes over time. It would cover England and Wales only, could not classify anyone who was under 16 at the census or did not answer the question, and would need to allow for that uncertainty.

The statements on death registration in this note have been checked for England and Wales only.

In short. These figures cannot, on their own, estimate a suicide rate among trans people, show whether it is rising, or show how it compares with the rate in another population. This does not show that the risk is not higher: the sources discussed give reasons to think it may be, while describing the direct evidence as poor or incomplete. The note holds the evidence question, what each figure counts, apart from any clinical or policy question, and sets out the data that would answer it, for people referred to gender services and for the wider trans population.

Sources

National Child Mortality Database, response to a Freedom of Information request on child deaths classed as suicide or deliberate self-inflicted harm, with methodology notes (Parts 1–3).
University of Bristol, Freedom of Information response FOI2526-321, 5 February 2026.
National Confidential Inquiry into Suicide and Safety in Mental Health, Annual Report 2023, Annual Report 2024, Annual Report 2025, and Annual Report 2026: UK patient and general population data 2013-2023 (March 2026, version 2).
Department of Health and Social Care, Review of suicides and gender dysphoria at the Tavistock and Portman NHS Foundation Trust: independent report, 19 July 2024.
Good Law Project, Trans people are dying of suicide more than the general UK population, data shows, 25 April 2026 (produced with QueerAF).
QueerAF, The deadly toll of the trans healthcare crisis: 21 suicides and over 600 other deaths, 10 October 2026.
Office for National Statistics, Suicides of, and crime rates against, transgender people in the UK, FOI-2025-2822, 29 May 2025.
Office for National Statistics, Census 2021 gender identity estimates for England and Wales, additional guidance on uncertainty and appropriate use, 26 March 2025.
Office for National Statistics, Sexual orientation and gender identity quality information for Census 2021, updated 8 April 2025.
Samaritans, Media Guidelines for Reporting Suicide, 2026.

Why two sources are not linked. We have not linked to the Good Law Project and QueerAF articles. This is not a judgement on their work. Samaritans’ media guidelines advise against linking to previous stories about suicide (Samaritans, Media Guidelines for Reporting Suicide, 2026), and we apply that to every story about suicide, including our own. Their full titles are given above so that readers can find them. Several of the figures discussed here were made public through their investigations, including the NCMD figures, which their Freedom of Information requests revealed (Good Law Project, 25 April 2026).

Competing interests

Position. The author is a transgender woman receiving gender-affirming hormone therapy and a dermatologist, with a personal stake in transgender health and the commitments set out below, and treats these as potential sources of motivated reasoning. A plausible risk is preferential detection or weighting of congenial findings, but the direction and magnitude of any actual bias cannot be known in advance, and over-correction is as possible as confirmation. The safeguards are the paper’s published methods, not the disclosure. Nothing in this paper rests on the author’s clinical standing; every judgement is published with its reasoning, for anyone to check.

Declared prior (an intellectual interest, declared as a competing interest). “Eden is a transgender woman receiving gender-affirming hormone therapy, and a dermatologist. She holds a declared prior in favour of access to gender-affirming hormones for adults, and of adolescent access to puberty blockers and gender-affirming hormones; the method is designed to make any resulting bias more visible and auditable, and findings that cut against that position are reported at full weight.”

Competing interests (as at 13 October 2026; any change is declared as an Update in this paper’s revision history. The definitive, dated list is kept at edenopenly.com/about/declared-interests).

(a) The author is the founder and sole funder of a non-profit transgender healthcare and education organisation. The author is developing its clinical services, including its clinical protocols, and its education programmes, and is recruiting its clinical staff. Its education programmes include patient and family resources, school resources, and training for healthcare professionals in the organisation’s own standards of care, which address questions in the same field as the guidelines and standards of care this series appraises. The organisation is not a party to this paper and has no role in it. The findings of this paper may inform its clinical protocols and educational material; that is a further interest in the findings, declared here.

(b) The author is the founder and sole funder of Eden Institute (edeninstitute.kr), a transgender health research institute in South Korea, which is intended to include a biobank and associated data infrastructure. It provides no funding for this paper and has no role in it.

(c) The author, through Eden Openly, is engaged in public correspondence and requests concerning the NHS Wales Joint Commissioning Committee’s Welsh Gender Service surgical referral pause, including written approaches to the Committee, requests under the Freedom of Information Act 2000, correspondence with Llais, and submissions to Senedd committees. Eden Openly publishes critical analysis of the decision at edenopenly.com/welsh-gender-service and describes itself as a party to the matter; the correspondence is published at edenopenly.com/wgs-correspondence. This is a public position on the evidence base for gender services. The author is not a party to any litigation and has no present intention to become one; any change is declared as an Update.

(d) The author, through Eden Openly, is engaged in parliamentary advocacy on the Health Bill’s single patient record provisions: written evidence to the House of Commons Public Bill Committee (published on the parliamentary record as HB130), a submission to the House of Lords Delegated Powers and Regulatory Reform Committee, and briefings to members of the House of Lords proposing an amendment. The advocacy concerns the confidentiality of, and access to, patient records, including a competent young person’s confidential control of their own record. It argues against provisions drafted by the Department of Health and Social Care and engages NHS England’s conduct. Everything filed is published at edenopenly.com/single-patient-record. This is a public position taken before Parliament; it is continuing, and any change is declared as an Update.

(e) The author, through Eden Openly, is conducting a structured appraisal of the Cass Review and the associated University of York systematic reviews. Its methods, stage and record are published at edenopenly.com/cass-review. The appraisal is a public undertaking to reach judgements on evidence and recommendations in the same field, and where this paper’s evidence overlaps its objects, the two may reach judgements on the same studies. This paper does not discuss the Cass Review or the University of York systematic reviews, and none of its sources is among the objects of that appraisal.

(f) The author’s published evidence reviews at Eden Openly assign quality and certainty grades to evidence that may overlap the subject of this paper. Where they do, they are a prior commitment on the same evidence, stated study by study, and are declared here as an interest. None of the author’s published reviews overlaps the evidence in this paper.

(g) The author, through Eden Openly, reports errors in published literature to the journals and bodies responsible for them, and records each report and its outcome in the Evidence Transmission Register, published at edenopenly.com/editorial/transmission-register. Reports concerning sources examined in this paper: QueerAF, concerning the Good Law Project and QueerAF article of 25 April 2026 and the QueerAF article of 10 October 2026, 12 October 2026; reported; acknowledged on 13 October 2026, with a fuller reply awaited.

(h) The author is a co-owner of, and the lead researcher at, a commercial business that develops skincare products and sells them to the general public through ordinary retail channels. The author is also planning, as a joint venture with a surgeon, a general aesthetic dermatology and surgery hospital; it is not open, may not open, and would not target transgender patients. The author may receive a financial return from both. Neither is a party to this paper, provides funding for it or has a role in it. These are the only commercial interests declared here.

The declared prior and interests (a) and (b) create a plausible incentive toward findings favourable to access to gender-affirming care, and each is disclosed for that reason. (e) creates a plausible incentive toward findings on shared evidence that are consistent with the author’s appraisal of the Cass Review. (c) and (d) are public positions on gender-service policy and patient-record policy respectively; they bear on this paper only so far as its findings touch those policies. (f) and (g) are disclosed as prior commitments on the same evidence, not as incentives of stated direction; their direction depends on the grades and reports concerned. (h) bears only where a paper concerns skin, hair or aesthetic treatment; this paper does not.

Memberships. The author holds no membership of WPATH, EPATH, ASIAPATH or any professional body whose guidance Eden Openly appraises. Our full position is set out in our statement of independence.

Symmetric standard. The interests are declared before the findings rather than after them. This note reaches conclusions the author did not want: that the figures cited as evidence of a rise in trans suicides, or of a higher rate than in the general population, cannot show either, and that several were misstated in the articles that reported them. It was revised following adversarial review conducted with AI assistance; that process was not peer review, and this note is not peer reviewed.

Ethics

This note analyses published documents and responses to Freedom of Information requests. It involves no new data and no participants, and ethical approval was not required. It identifies no person who died.

Funding

This paper is unfunded. The author accepts no third-party funding for research, publication or appraisal activity, as a standing policy, and neither does (a) nor (b). All costs, including any external review, are paid personally by the author. The author’s funding of (a) and (b) is a financial interest in organisations working in transgender health, whose operating environment the subject of this paper may affect. (h) is a commercial interest, present and planned, from which the author may receive a financial return.

Data availability

Each source is identified in the Sources list by issuer, title and date. Copies of all 13 source documents are held in Eden Openly’s source archive. This note, including its correction record, is deposited as a PDF under the version DOI given above. The source register, the claims checked and the verification script are published in the companion repository linked above.

Author contributions

Eden: conceptualisation, methodology, investigation, writing (with AI assistance, as described under Preparation), review and editing, and project administration.

Acknowledgements

No external human reviewer read this note before deposit. The reviews described under Verification were conducted with AI assistance.

Preparation

This note was prepared with the assistance of a large language model (Claude, Anthropic), used for source retrieval, arithmetic verification, structural editing and adversarial review. AI assistance is not authorship, peer review or author approval. The author is responsible for every claim, every number and every citation. The claim-to-source checks described below were carried out with the language model’s assistance and have not been independently repeated by a human. Errors identified during production are recorded in the correction record below; that record shows why this statement is needed.

Verification

Of 13 source documents, 13 were obtained and read in full; none was read in published abstract only, in an official extract, translation or summary, and none was cited unobtained. The Sources list has ten entries; the NCISH entry covers four annual reports. Every figure, quotation and page reference in the note was checked against its source in a series of AI-assisted passes, each by a pass that had not drafted the text it checked, ending with a full read of the final text against all 13 source documents (about 108 statements). A numeric check alone would not have found most of the errors recorded below, which were wrong descriptions of what a source says rather than wrong numbers. Those checks are not independent human verification.

Correspondence

The discrepancies in the Good Law Project and QueerAF article of 25 April 2026 (the 47 and “England and Wales”; “seven years”; the yearly NCISH figures; and the comparison of 7% of child deaths with under 1% of the population) and in the headline of the QueerAF article of 10 October 2026 were reported to QueerAF on 12 October 2026, with an offer to share the relevant passages before publication. The QueerAF journalist who co-wrote both articles was copied; Good Law Project was not separately contacted. As of 13 October 2026 the published articles are unchanged. On 13 October 2026 the journalist acknowledged the report and said a fuller reply would follow. Publication did not wait for it; any reply will be reflected in a later version of this note.

Method and limitations

This is a narrative evidence note. It is not a systematic review, it is not peer reviewed (it was revised following adversarial review conducted with AI assistance), it does not follow PRISMA, and no formal risk-of-bias instrument was applied. It assigns no certainty grades. It is not a policy position, and it must not be used to start, stop or withhold any treatment or service. Because the method is not a systematic search, the note reports what the documents it read contain and does not assert that no other source exists. It is a descriptive note, not an outcome-grading review. Statements of general epidemiological method, for example that a rate needs a denominator, are given without citation. Statements about death registration have been checked for England and Wales only.

Evidence identification — method and its limits

The sources were identified by tracing each figure in circulation to the document it comes from, and adding the reports, reviews and official guidance needed to interpret those documents. No search was run for other figures for suicides among trans people in the UK, and any that exist are not discussed. Each absence statement in the note is limited to the documents named: for example, that none of the NCISH annual reports for 2023 to 2026 gives a single-year count for trans patients.

Correction record — eleven entries

This record lists substantive errors found and corrected during production, before deposit. It is the note’s only credential for method: a reader who can see what went wrong, and how it was caught, can judge whether the remaining text is likely to be right.

On the direction of corrections. Corrections are recorded whichever way they move the text. No ratio between directions is given, and none should be inferred from this list.

What was wrong	Where it came from	What changed
QueerAF’s 597 deaths not counted as suicide were described as “at least 597 other deaths”.	Drafting: some clinics do not record cause of death, so some of the 597 may have been suicides.	Now “597 deaths were not among the 21 counted as suicide or suspected suicide”, with the reason stated.
A census-linked study was said to be unable to “cover children”.	Drafting: the census question was asked of everyone aged 16 and over.	Now “could not classify anyone who was under 16 at the census or did not answer the question”.
The note said the figures “cannot measure how much higher” the risk is.	Drafting: the wording presupposed that the risk is higher.	Now “cannot show whether, or by how much, it is higher”.
The DHSC review’s “good reasons to believe” that risk is high was quoted without its preceding “generally poor”; the Good Law Project article’s reviewer was quoted as calling the evidence “fundamentally incomplete” without “concerning”.	Drafting: one-sided quotation.	Both quotations restored with their qualifications.
Several figures were said to be public “only because” of the Good Law Project and QueerAF investigations; a recent-years undercount was attributed to the NCMD response; NCISH’s 2023 underestimate warning was applied to the 104.	Drafting: attributions stronger or wider than the sources.	Now “made public through their investigations”; the undercount is attributed to the University of Bristol’s follow-up response; the warning is limited to NCISH’s 2016–2020 figures.
The DHSC review’s judgement that a longer-term rise was “likely” was reported as a rise that “may have occurred”.	Drafting: understated the source.	Now quoted in full.
QueerAF’s Tavistock and Portman figure and the DHSC review’s 12 were said not to disagree.	Drafting: a comparison the data do not allow.	Now “cannot be directly compared”, with the reasons.
Three NCISH page references were wrong.	Drafting.	Corrected against the reports’ own page numbering.
The five figures were dated from 2009.	Drafting: 2009 is the start of QueerAF’s all-cause death data, not of any of the five figures.	Now “from 2012 onward; some end dates are not stated”.
The sources were described as five “populations” and “systems”, each counting “different people”.	Drafting: two do not define a population, and the same death may appear in several figures.	Title and text changed; overlap stated.
QueerAF’s data were said to cover “around a quarter” of clinics.	Reading a newsletter introduction rather than the article.	Now three of the 13 clinics asked, from the article.

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Revision history

First published — 13 October 2026.