LGB Samtökin writes to the Director of Health

Iceland's Directorate of Health has been asked to show its working.

The LGB Association has written to the Director of Health asking what scientific evidence Iceland's medicalisation of gender-distressed children and adolescents actually rests on. Which systematic reviews. Whether the Directorate has ever assessed the quality of that evidence itself, using GRADE or anything comparable. Whether WPATH's Standards of Care (SOC-8) are being used as the basis, formally or otherwise.

Subject: Inquiry concerning the scientific and epistemological basis of gender-affirming treatment of children and adolescents in Iceland, with reference to WPATH SOC-8 and the visit of Irish health authorities

Honourable Director of Health,

I, the undersigned, hereby request, with reference to the role of the Directorate under Act No. 41/2007 on the Director of Health and Public Health, in particular supervision of the quality and safety of health services and guidance to the public, clear answers to the following.

1. Epistemological and scientific basis

According to public information, the transgender team of the Child and Adolescent Psychiatry Department of Landspítali (BUGL) provides children and adolescents with diagnosis and treatment for incongruence between gender identity and the sex observed and recorded at birth. This may include puberty-suppressing medication (puberty blockers) and later sex hormones, as well as social and psychosocial approaches. Public descriptions state that the service is based on “international procedures and clinical practice consistent with contemporary service and the foremost knowledge in the field.”

I request that the Directorate specify:

a) which systematic reviews of research, quality assessments of guidelines, and other primary sources the Directorate considers to constitute the scientific and epistemological basis on which Icelandic treatment policy towards children and adolescents rests;
b) whether and when the Directorate has independently assessed the quality of these data, e.g. using GRADE or comparable methods;
c) whether the WPATH Standards of Care, version 8 (SOC-8, 2022), Endocrine Society guidelines, or other foreign guidelines are formally or informally used as a basis in this country;
d) how the Directorate assesses the findings of independent systematic reviews showing that the evidence for benefit of puberty blockers and sex hormones for children and adolescents with gender dysphoria is generally of low or very low quality, including the reviews on which the Cass review in England (2024) was based, as well as comparable reviews in Sweden, Finland and Norway.

2. Status of WPATH and SOC-8 before U.S. courts

In U.S. litigation, including cases concerning the FTC and SOC-8 in 2026, WPATH has argued that statements and recommendations in SOC-8 are not bare assertions of fact but opinions about what particular studies support; that the field is one of “intense medical debate” and “medical and scientific uncertainty”; and that such opinions enjoy freedom-of-speech protection.

This raises a fundamental epistemological question: if the authors of the guidelines widely cited as a “standard” themselves describe them as opinions in a field of scientific uncertainty, what standing can such guidelines then have as a scientific basis for interventions that can have lasting effects on fertility, puberty, bone health, cognitive development and sexual function of children and adolescents?

I request the Directorate’s position on:

a) whether SOC-8 is regarded in this country as scientifically standardised clinical guidance or as professional opinion/consensus;
b) whether the Directorate considers it justifiable to base treatment of children on guidelines whose authors have themselves classified them as opinions in a field of scientific uncertainty;
c) whether the Directorate has reviewed internal documents that have emerged in U.S. court proceedings concerning the drafting of SOC-8, including the handling of systematic reviews, conflicts of interest, and the influence of political pressure on age limits.

3. Visit of Irish health authorities

In the latter part of 2025, Mary Butler, Irish Minister of State with responsibility for mental health, and Dr Colm Henry, Chief Clinical Officer of the HSE, visited Iceland on a so-called knowledge-exchange visit organised by the Icelandic Ministry of Health. The purpose, according to public statements, was to familiarise themselves with the “Icelandic model” (which the Directorate has in fact never mentioned in our previous correspondence nor at our meeting in October 2024) as a possible model for a new Irish service model in this field.

I request information on:

a) whether the Directorate of Health was involved in the preparation, reception or professional content of this visit;
b) what scientific data, reviews or quality assessments were presented as the basis for presenting the Icelandic approach as a model;
c) whether the Irish guests were informed of the uncertainty of the evidence, the findings of the Cass review and comparable European reviews, as well as the position WPATH has taken before the courts regarding the nature of SOC-8;
d) whether the Directorate considers the export of the Icelandic approach to other countries to be consistent with the requirements of evidence-based medicine and the precautionary principle towards children.

4. Responsibility, informed consent and supervision

Finally I request answers to:

a) whether the Directorate has issued or endorsed clinical guidelines, quality standards or minimum requirements for diagnosis, diagnostic time, exclusion of other mental disorders, informed consent and follow-up in this field;
b) how it is ensured that parents and young people receive objective information about the quality of the evidence, uncertainty about long-term benefit and known risks, and not only a description based on “foremost knowledge” without explanation of what that knowledge actually supports;
c) whether the Directorate considers the current arrangement, under which refusal of treatment involving alteration of sex characteristics is appealable to the Director of Health under the Gender Autonomy Act, to require the Directorate to have an independent and up-to-date evidence assessment of the field.

I request a written reply and, as applicable, copies of the documents, opinions or internal analyses on which the Directorate relies. The inquiry is made in the interest of transparency, child protection and that health policy towards children rest on science that withstands scrutiny, and not on guidelines whose authors have themselves classified as opinions.

Yours faithfully,

Eldur Smári Kristinsson
LGB Samtökin

Copies: Alma Möller, Minister of Health (former Director of Health)
Hallgeir Jónsson, Chair of the LGB Samtökin