02/10/2026

Dear England Touch Association Board,

I am writing as Chairperson, and on behalf of the London Stags RFC, to express our deep concern and disappointment at the Participation Eligibility Policy update, published on 30 September 2026. The policy takes immediate effect, ending self-identification for competitive Touch and determining eligibility for Touch competitions (such as the National Touch Series) by sex recorded at birth.

The England Touch Association’s (ETA) statement reinforces the commitment to fair competition, as well as to the core values, including, “Inclusive”, “Transparent” and “Respectful”, and yet none of these appear to have been considered upon enacting this policy update. We recognise that the Equality Act 2010 permits lawful sex-based distinctions in certain gender-affected sports where necessary to secure fair competition or safety. However, neither the Act, nor the 2025 Supreme Court ruling requires a particular model to be adopted. The updated policy does not currently provide any Touch-specific evidence explaining why this change is necessary in Touch, nor any published evidence of unfairness or harm under the previous policy.

We therefore ask you to consider our four points of concern: to explain the underlying sporting and legal basis and publish the supporting evidence, including the Equality Impact Assessment; to allow for consultation from trans and non-binary members within ETA-affiliated clubs and leagues; to publish the related guidance and explain how this remains inclusive of trans players and to withdraw this updated policy whilst the review is ongoing.

The ETA has stated that this policy is a “live document” and so we expect an immediate review in order to understand the impact this update has had across the entire Touch Rugby community, as well as to ensure trans and non-binary voices are heard.

1) The policy was introduced without consulting the players it affects

The London Stags RFC is an LGBTQ+ inclusive rugby club, founded in 2019. Our Touch squad competes in the IGR Touch Series, and we are proud to be a home for trans and non-binary players.

Trans and non-binary players can find a safe haven in Touch, a sport that has been a frontrunner in developing mixed-gender on-field playing formats. Touch has offered our trans players the chance to express themselves, take leadership, engage in sport and build friendships through this community. This policy affects them directly and risks their future playing the sport they love.

Despite being an ETA-affiliated club, the London Stags RFC were not consulted, nor did we have any opportunity to voice our concerns, or vote, on this policy update. We therefore endorse the joint statement from Pride In Touch and IGR Touch, which sets out how this process compares with the consultation behind the 2021 policy. With our trans and non-binary players directly affected, and the policy taking effect immediately, our club's future relationship with the ETA is now in question. We will always stand behind our trans and non-binary players and refuse to let their voices be silenced.

2) No case has been made for why this is needed in Touch

We understand that fairness, rather than safety, is the central concern. Yet, such fairness in Touch deserves Touch-specific evidence, and the ETA has not published evidence explaining why this change is necessary to “secure fair competition”. Other sporting bodies have reached different conclusions about closely related formats. The Rugby Football League, for example, continues to treat Touch and Tag as mixed-gender formats without applying sex-based eligibility criteria.

The updated policy does not explain what specific problem it is intended to resolve, nor does it provide Touch-specific evidence demonstrating why Touch Rugby is now considered a gender-affected sport by the ETA.

3) The policy puts trans players' privacy and dignity at risk

The policy relies on a "trust-based" approach to registration, with captains and coaches responsible for ensuring their teams meet the eligibility rules and thus, theoretically, having to ask members to disclose their sex at birth in order to align with this new update. In practice, this could force a captain/coach who knows a teammate is trans to choose between pressuring that player to disclose their gender history, risk their team being deemed ineligible or for all involved to be scrutinised under an ETA-led review.

Trans and non-binary players are now expected to play in a team that does not match their gender identity, where one could expect isolation from their teammates and exposure to unwanted attention on the pitch. The policy states that transphobic behaviour, including deliberate misuse of pronouns, will not be tolerated, but it does not explain how this will be upheld when trans players are being placed in teams based on their sex at birth, rather than the teams they have always played in.

Those who choose not to disclose risk being barred from competitive Touch and having their identity questioned at any moment, often in a high-pressure match environment, in order to match the eligibility criteria set out in the policy. This would naturally be deeply distressing, and seems to be at odds with the policy stating that all players must be treated with dignity and respect.

Furthermore, referees and officials are now expected to “manage any concerns raised”, yet the policy has taken immediate effect. Several of our members are currently training as referees with the ETA; without clear guidance, these situations risk damaging relationships across the sport and within our own club.

Whilst the ETA has stated that further guidance for players, coaches and referees will be released in the coming weeks, the policy has been implemented immediately. By introducing a culture of policing identity, the ETA risks undermining the foundation of inclusivity that the Touch community is built on, impacting both inter- and intra-club relationships.

4) Inclusive clubs are blocked from progressing in the sport

Inclusive clubs are a key pathway into Touch, and into sport more generally, for LGBTQ+ people, and many of our players hope to compete at a higher level. Under this policy, IGR teams with trans and non-binary players cannot progress into competitive pathways without risking our players experiencing discrimination, a loss of dignity and the fear of being ‘outed’. This restricts our ambition as a club, and particularly affects our trans and non-binary players who wish to develop and compete at the highest level available to them, within their chosen gender identity.

We therefore ask the England Touch Association to:

Yours faithfully,

Daniel Webb
Chairperson of the London Stags RFC, on behalf of the London Stags RFC Executive Committee