The Welsh government is asking for feedback on its proposed ‘Relationships and Sexuality Education Statutory Guidance and Code‘ in advance of the introduction of the new ‘Curriculum for Wales‘ in 2022. The new code will apply to all maintained schools, nurseries, PRUs and local authorities in Wales.

Parents, carers, teachers: you have until the 16th of July to comment.

For help with filling in the consultation please click here.

We have reviewed this guidance and found some worrying features… and some glaring omissions.


First, it is worth noting that ‘RSE’ in Wales will now refer to ‘Relationships and Sexuality Education’.

Sexuality is defined in the Guidance as “a central aspect of being human and encompasses sexual orientation, gender identities and roles, sex, reproduction and intimacy. Sexuality is experienced and expressed through thoughts, beliefs, behaviours and relationships.”

The RSE curriculum based upon this definition of sexuality will be mandatory for all Welsh children from the age of three years old.

The reason for the rebrand from sex to sexuality education is given in the supporting paper as permitting more “inclusive and holistic” aims. As can be seen above, this is a wide-ranging definition which introduces some concepts that were not previously covered by ‘sex education’. One of these is ‘gender identity’.

‘Gender identity’ is a concept that is grounded in queer theory, the study of gender and sexual practices that are outside the ‘norm’ with an interest in breaking down of categories and boundaries. In some cases this includes the boundaries around children’s sexuality. Its proponents seek to challenge the view of the Primary School as a place of safety and innocence.

The ‘Sex and Relationships Education Expert Panel’ which advised on this change to the curriculum was chaired by Prof Emma Renold, a Cardiff University professor who focuses on the application of queer theory in childhood studies. The panel was established by former Cabinet Secretary for Education, Kirsty Williams, and other members included Stonewall Cymru and Stonewall Diversity Champions such as Barnardo’s and Public Health Wales. The Welsh Government, Senedd (formerly National Assembly of Wales) and Cardiff University are in the Stonewall Diversity Champions Top Ten.

This means that academic theory concerned with breaking down ‘barriers’ to acknowledging children’s sexuality is combined with the activities of a lobby group – with an active presence in schools – that has been criticised for undermining safeguarding. Stonewall advocates for the removal of single-sex spaces, the keeping of secrets from parents, and the overriding of what a child sees (sex) with what another person tells the child they should see (gender).

Parents should be actively questioning what their children are being taught as a result of this collaboration.

Sex and gender

So what does this Guidance say, and more importantly, what does it not say?
First let’s turn to the glossary. The document acknowledges that sex (not gender) is a protected characteristic in UK law.

Sex is defined as follows:

(Rhyw) Assigned to a person on the basis of primary sex characteristics (genitalia) and reproductive functions. 
Some people’s gender identity does not match up with the sex they were assigned at birth. Sometimes the terms ‘sex’ and ‘gender’ are used interchangeably to refer to whether someone is female, male or non-binary.

This is an unclear and misleading description which introduces contradictory concepts: ‘primary sex characteristics’ are binary (for 99.999% of the population), but apparently the word ‘sex’ can also be used to describe someone as ‘non-binary’.
The description of sex as ‘assigned’ rather than ‘observed’ also represents sex as something that is temporary, which may be changed, and which doctors may be wrong about. This unscientific way of representing sex allows it to be confused with the more open-ended term ‘gender’.

Gender is ‘defined’ here as follows:

(Rhywedd) Often used to refer to whether someone identifies 
as female, male or non-binary. Gender often refers to the 
socially and culturally perceived norms and differences 
between men, women and non-binary people. People often 
find an important sense of identity in these but they can also 
perpetuate and enforce inequalities and harms through 

We now have several contradictory definitions of the word ‘gender’: a biological term, a term about identity, a term referring to social norms, and a harmful stereotype.
Which definition the Welsh government using in this document is not specified. When they talk about “gender-based violence”, “gender equality” or challenging limitations placed on children based on their “gender”, what problem they are trying to solve is therefore also left undefined.


The Guidance states that:
“all schools and settings must teach RSE in a neutral, factual way. Where questions of values arise, they must present learners with different perspectives on a range of views on issues commonly held within society. For example, schools may teach about different perspectives within faiths on matters of relationships and sexuality… However, this must not be done in a way that seeks to indoctrinate learners in a particular view.”

The authors of this guide cannot fail to be aware that the concept of ‘gender identity’ is not one that has a ‘neutral, factual’ definition. They must also be aware of parental concerns over the explosion in the number of girls identifying as transgender at a time when sexual harassment of girls is alarmingly common in schools.
This is not acknowledged. ‘Gender’ is mandated as something of which learners must develop an understanding:
“Across these themes, curriculum content in RSE is to be inclusive and reflect diversity. It must include learning to develop learners’ awareness and understanding of different identities, views and values and a diversity of relationships, gender and sexuality, including LGBTQ+ lives.”

How schools should develop learners’ understanding of gender is not clear, particularly as the concept has not been adequately defined in this Guidance.

The Guidance says that “Provision should draw on specialist services and expertise”. However, there is no information given for schools on how to select 3rd party providers to ensure that they teach in a neutral, factual way and do not seek to indoctrinate learners. The 3rd party provision that schools may be expected to turn to is the material already associated with the new Welsh RSE Curriculum, which was produced by Prof. Renold, the Chair of the RSE Expert Panel which proposed the curriculum changes. They include Agenda, a resource for educators which defines ‘gender identity’ as:
“a person’s inner sense of self. Gender Identity does not necessarily relate to the sex a person is assigned at birth. Feelings about gender identity start early, around the age of 2-3.”

We do not consider this to be a ‘neutral, factual’ statement.
Can schools tackle gender stereotyping if they must also tell learners that sometimes peoples’ gender identity does not match their sex? How should a 5-year-old girl who likes football and trucks, or a 7-year-old boy who wants to dance, make sense of this?

Where is the safeguarding?

It is widely recognised that a lesson on RSE may lead to disclosures from a young person. But there is no information in this document about how schools should approach this. There is no section on safeguarding, dealing with sensitive issues, confidentiality or disclosures. We find this lack of a safeguarding framework very concerning, particularly given the observations above.

There is no specific requirement within this Guidance to teach about the age of consent, sexting or sexual harassment. ‘The law’ is mentioned, as is harassment “relating to gender”. This is not good enough. The vast majority of sexual harassment in schools is by boys against girls, and this must be acknowledged and tackled directly through RSE.

The Guidance mentions menstrual health as it applies to ‘learners’. There is no recognition that having periods or dealing with period-shaming is something that is relevant to girls. This also side-steps any debate around girls needing a single-sex space to change period products, or for any other reason.

What is especially notable is that the previous, February 2019 ‘Relationships and Sexuality Education in schools’ guidance for Wales does cover the age of consent, safeguarding and disclosure in some detail. This is missing from the newer version. Why?
The Introduction to the new Curriculum for Wales states that “A defining feature of the Framework is that it requires schools to design their own curriculum and assessment arrangements.” and that rather than telling schools what to teach, the curriculum sets out the “essence of learning” that should underpin topics.

Parents in Wales should be aware that this will mean that there is only a very loose framework regarding the content of the learning that their children will be doing about ‘sexuality’.
Ask to see what your child will be taught.

Click here to fill in the consultation.

There is more information and advice on the Merchedd Cymru website.

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