Please sign on here if you agree with our joint statement below. Your organization name will be added to a list at the end of the paper.
This statement is being organised collectively by IPPF and Women Deliver on behalf of civil society organisations.
We, the undersigned feminist, human rights and social justice organizations committed to gender equality and social justice, express deep concern regarding the framing of the call for a thematic report by the Special Rapporteur on Violence Against Women and Girls (SRVAW), which adopts a "sex-based" rather than a "gender-based" approach. This framing undermines decades of progress in advancing human rights and gender equality and risks confining cisgender women to patriarchal, protectionist policies by interpreting violence as rooted in biology. It further marginalizes vulnerable groups, including trans and gender diverse persons, increasing the risk of violence and hatred.
The Strategic Shift of the Focus from Real Perpetrators to an Oppressed Group
The current mandate holder has unfortunately dedicated her tenure to attacking trans and gender diverse people. Many of her calls and statements have indirectly framed trans people as an obstacle for cis women in achieving safety and equality. This dangerous narrative shifts focus away from patriarchal systems and cis-normative gender roles as the primary sources of violence, discrimination and inequality. Instead, it positions trans people as scapegoats, enabling the very systems responsible for violence and oppression to avoid accountability.
This approach undermines the broader fight for gender equality and harms cis women by reinforcing paternalistic and protectionist policies that uphold patriarchal power structures. Such policies, presented as "women’s protection," constrain women within patriarchal systems rather than breaking away from patriarchal power dynamics altogether and empowering them, inter alia, through autonomy and equitable redistribution of power and resources. It is telling that anti-gender actors have often welcomed the current mandate holder’s reports and positions and have used her framing and recommendations to push for retrogressive language and to argue against the inclusion of gender-related language in resolutions. This alignment reveals how such framing serves regressive agendas, patriarchal systems and anti-rights actors rather than advancing human rights for all.
The current mandate holder has a history of efforts that have caused tangible harm, including:
- Undermining National and Regional Reforms: unsolicited interventions on rights-affirming reforms, such as the Scottish Gender Recognition Reform Bill and the Council of Europe resolution on sex workers’ rights.
- Opposing UN Evidence-Based Policies: Ignoring and attacking established UN positions supporting trans and gender diverse persons and sex workers, attempting to insert her mandate into resolutions at the Human Rights Council in violation of the mandate’s independent nature.
- Manipulating data: Erasing and ignoring contributions from rights holders and affected communities including sex workers, trans persons, and allied organizations in her thematic reports.
Why Framing Violence as “Sex-Based" is a Problematic Lens
The Special Rapporteur’s call framing violence as "sex-based" imposes a limited lens for understanding systemic violence, overlooks the structural root causes of such violence, thereby undermining access to an effective remedy and seeks to erase the well-established understanding of gender-based violence (GBV) within the UN system and international law.
As defined by the World Health Organization:
“Gender refers to the characteristics of women, men, girls and boys that are socially constructed. This includes norms, behaviours and roles associated with being a woman, man, girl or boy, as well as relationships with each other. As a social construct, gender varies from society to society and can change over time.”
Gender has been the subject of decades of feminist scholarship and organizing, as well as the work of human rights mechanisms. It captures both biological elements and the social interpretations of those elements, as well as the systems of regulation surrounding them. Feminists have long argued that sex is always gender because power imbalances stem not from sexual (biological) elements themselves but from societal interpretations and regulations of those elements. Consequently, discussions about sex are inherently discussions about gender.
The “sex-based” approach reduces the complex social and structural dynamics of violence to a rigid, biological understanding of sex, ignoring lived realities. By promoting a Western colonial patriarchal worldview that insists on the binary nature of sex, it disregards the lived experiences of millions of people. The notion of binary sex stems from Western colonial patriarchy, which historically used strict sex distinctions to assert white supremacy. Under this framework, Black and other racialized women were labeled as inherently gender non-conforming with catastrophic consequences on their health and rights. The category of "woman" has always been racialized, with white women expected to enforce binary gender norms violently upon anyone deemed non-conforming. This legacy underpins the harmful positions now advanced by the current mandate holder.
In the real world, neither sex nor gender is binary. Sex comprises many elements, manifesting differently in individuals. The Special Rapporteur’s positions oversimplify these realities and perpetuate an alternative worldview rooted in exclusion and erasure. Even though Special Procedures have a crucial role in upholding the universality and indivisibility of human rights, the current mandate holder’s stance undermines progress on gender equality and reinforces harmful narratives that perpetuate violence and discrimination.
Established Norms
In the call for input, the mandate holder directly contradicts her position by justifying her use of “sex-based” violence with the following statement:
“While the term ‘sex’ has not been defined in international law, Article 31 of the Vienna Declaration on the Law of Treaties (1969) mandates that treaties be interpreted ‘in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose.’ The same article also specifies that States shall take into account—together with the context in which a treaty was concluded—‘any relevant rules of international law applicable in the relations between parties’ and any subsequent practice. Based on the aforementioned, sex is to be understood as a ‘biological category’ and a distinction between women and men as well as boys and girls. This is the understanding that the Special Rapporteur has for the purposes of the report.”
Human rights mechanisms have clarified as early as 1989 that the prohibition of sex-based discrimination, as enshrined in core international human rights treaties, includes gender-based discrimination. In its General Recommendation 35, CEDAW reaffirmed this interpretation as including gender-based violence, which it defines as “violence which is directed against a woman because she is a woman or that affects women disproportionately”. This definition has been accepted and recognised by over 30 years of State practice and now forms a principle of customary international law. Furthermore, the term “gender-based violence” is recognised by CEDAW as a more precise and preferred term to “violence against women” as it makes explicit “the gendered causes and impacts of the violence”, and emphasizes the social structures and causes of the violence. This is a position that previous mandate holders have always endorsed.
These standards cover all women, including trans and intersex women and gender-diverse people, who are disproportionately targeted for social control based on their perceived transgressions of established gender roles and sexuality. UN agencies, Treaty Bodies, and past Special Procedures mandate holders have long promoted a gender-based lens to address violence, rooted in the principles of non-discrimination, universality, and interdependence of rights. Gender as a concept was not developed at the time when human rights law was created. Feminist scholarship and human rights mechanisms have redefined the concept of "sex." Unfortunately, the current mandate holder misinterprets “sex” in bad faith by ignoring decades of feminist scholarship and the work of human rights mechanisms in defining the concept of sex and gender, undermining decades of coherent UN agency, Treaty Body and Special Procedures’ analysis of gender.
Call to Action
We urge all human rights mechanisms and bodies, including UN Treaty Bodies, Special Procedures Mandate Holders, and UN Agencies to:
- Adopt an inclusive, evidence-based gender lens, recognizing that violence is rooted in structural inequalities and social norms, expectations and stereotypes, not biology alone.
- Refrain from divisive and biologically deterministic narratives that undermine the rights of cis women and trans and gender-diverse persons.
- Center the autonomy, agency, and voices of all rights-holders, especially those directly impacted by patriarchal violence.
Our Position on Participation
We respectfully call on civil society organizations, academics, and other stakeholders not to validate the problematic "sex-based" framing, but instead to engage through advocacy and submissions to this call for inputs which challenge the flawed premise and reaffirms the indivisibility and universality of human rights.
Violence against women and girls cannot be addressed without an intersectional and inclusive gender-based framework. Rights belong to all humans; there are no separate or special categories of rights beyond those grounded in universal principles. Let us collectively uphold this vision.
Signed by:
- Action contre la Faim – France
- AFDA Familias Diversas
- AFEMTRAS
- Aidos
- Akina Mama wa Afrika
- Alianza Si Podemos
- APROSEX
- Arachnapoid
- Asamblea Feminista de Madrid
- Asamblea Nacional Trans No binarie
- ASEAN SOGIE Caucus
- Asia Pacific Alliance for Sexual and Reproductive Health and Rights (APA)
- Asia Pacific Transgender Network
- Asociación de Servicios Integrales por la Equidad en la Sociedad A.C.
- Asociación por las Infancias Transgénero
- Association of LGBTI People in Zimbabwe- GALZ
- ASTRA Network
- Athens Pride
- Australian Women’s Health Alliance
- Austrian Family Planning Association
- AWID
- Balance A.C.
- BearHands Amsterdam
- Bonhishikha
- Bundesverband Trans* / Federal Association Trans (Germany)
- CAN-Myanmar
- Canadian Alliance for Sex Work Law Reform
- CARAM Asia
- Casa CoMadreja y Circulo de Parteras en apoyo a migrantes
- Casa de las Muñecas Tiresias AC
- Center for Reproductive Rights
- Centre for Sexualities, AIDS and Gender, University of Pretoria
- CEPESJU
- Charity Foundation Woman health &Family Planning , IPPF MA Ukraine
- Chirapaq/ECMIA
- CHOICE for Youth and Sexuality
- COC Nederland
- Colectiva Tzitzimiyotl
- Colectiva unidas somos más
- Colectivo de Prostitutas de Sevilla
- Colectivo TLGB Tarija
- Colors Rainbow
- COMCAVIS TRANS
- Comitato per i Diritti Civili delle Prostitute APS
- Common Action for Gender Development COMAGEND
- Community Care Collective
- Comunidad Cultural de Tijuana LGBTI A.C.
- Controla tu Gobierno A.C.
- Cooperativa Sociale Parsec a r.l.
- Copenhagen Pride
- Correlation-European Harm Reduction Network
- Council for Global Equality
- Count Me In! consortium, consisting of AWID, CREA, JASS, Mama Cash, UAF Africa, UAF for Feminist Activism
- Courageous Sisters Ghana
- Creación Positiva
- CSD Olpe e. V.
- DASTAK Foundation
- Democracia sin barreras
- DIOTIMA – Centre for Gender Rights and Equality
- Diverlex
- DRACHMA MALTA
- DSIL Designing for Systems Innovation and Leadership
- EcST-Espert* contro la Tratta
- Edge Effect
- EL*C – EuroCentralAsian Lesbian* Community
- ELLA Mexico
- End FGM EU
- Equal Asia Foundation
- EquiLabs
- Equipop
- Esquerra Republicana de Catalunya
- ESQUERRA REPUBLICANA DE CATALUNYA
- Esquerra Republicana de Catalunya
- European Network for the Rights and Health among Migrant Sex Workers-TAMPEP
- European Sex Workers Rights Alliance
- Family Planning Association of Nepal
- Fédération Laïque de Centres de Planning Familial (FLCPF – BE)
- Feminist Gender Equality Network
- Feminist Task Force, FTF
- Feministas en Holanda
- FILIA Center
- FLIRT
- Fórum 50 %
- Fòs Feminista
- Foundation for Women and Family Planning FEDERA
- Foundation for Women’s Solidarity
- FPES
- French Family Planning
- FRI – The Norwegian Organisation for Sexual and Gender Diversity
- Fundacion Arcoiris por el respeto a la diversidad sexual
- Fundación MUJER & MUJER
- Fundheg
- GALA Queer Archive
- Gender Concerns International
- Gender Dynamix
- Gestos – Soropositividade, Comunicação e Gênero
- GIRLxGIRL
- Global Alliance against Traffic in Women
- Global Justice Center
- Groupe pour l’Abolition des Mutilations Sexuelles féminines (GAMS Belgique)
- HILFE-FÜR-JUNGS e.V.
- Hivos
- Hola Amigue
- Hope beyond foundation
- Human Right, Women and Migration
- ILGALAC
- Impulso Trans
- Independent Filmworks Inc.
- Iniciativa Alianza EnBy Mx
- Instituto de Investigación y Estudios para la Atención de la Violencia hacia NNA REHILETE A.C
- Instituto Prios
- International Federation of Medical Students’ Associations (IFMSA)
- International Lesbian, Gay, Bisexual, Trans, and Intersex Association (ILGA WORLD)
- IPPF
- International Women’s Development Agency (IWDA)
- Intersex Asia
- Intersex Philippines
- IYAFP
- Jóvenes por una salud integral
- Kaos GL
- KFUK-KFUM Global
- Kolektyw Kamelia
- Konsent
- Kwathu Ndi Kwanu
- La Revuelta
- LAIN Laboral Interseccional
- Lake Region Womxn Health and Equal Rights
- Lazos por la Diversidad, México
- LEDESER, A.C. (Litigio Estratégico en Derechos Sexuales y Reproductivos, Asociación Civil.) México
- LEFÖ – Information, Education und Support of Migrant Women
- Life Quality Improvement Organisation FLIGHT
- LIRAD NIGERIA
- Lobby Europeo de Mujeres en España- LEM España
- Malta LGBTIQ Rights Movement (MGRM)
- Mama Cash
- MANODIVERSA
- MAP Foundation
- MOVIMIENTO DE MUJERES DOMINICO HAITIANAS MUDHA.
- Movimiento Trans Feminista Bolivia
- Naked Eye Productions Ltd
- NAmibia Diverse Women’s Assocation (NDWA)
- National Trans Coalition human rights NGO
- NESEHNUTÍ
- NGO KYIVPRIDE
- NGO WA Sphere (Ukraine)
- Ni Una Menos
- NIJUDI A.C
- Northumbria University
- ODRI – Office against Discrimination, Racism and Intolerance
- OII Chinese (Organizational Intersex International – Chinese)
- OII Europe
- Orgullo Ecatepec A.C
- OTRANS-RN, REDLACTRANS .
- Our Voices, Our Futures (OVOF) Programme
- Outright International
- PION – Sex Workers’ interest organization in Norway
- Planet Ally
- Planned Parenthood Global
- Platform Self-Determiniation and Residence Rights
- Población Diversa e Incluyente
- Population Services and Training Center (PSTC)
- Pride in UA
- Profamilia Colombia
- Promoting Empowerment Through Awareness for Lesbian ad Bisexual Women
- Promsex – Centro de Promoción y Defensa de los Derechos Sexuales y Reproductivos
- Prostitution Information Center (PIC)
- Q-Initiative C.B.O. Kenya
- Queer.red
- RAÍCES Análisis de Género para el Desarrollo A.C.
- Red de familias trans
- Red de Juventudes Trans México
- RED GUATEMALTECA MUJERES EN ACCION
- Red Nacional de abogadas feministas Mexico
- Red Umbrella Sweden
- Reimagining Sex Work (NL)
- RFSL – The Swedish Federation for LGBTQI Rights
- RFSL Ungdom – Queer Youth Sweden
- Roter Stöckelschuh
- Rutgers
- SAIH – The Norwegian Students’ and Academics’ International Assistance Fund
- SAVE sex workers rights (NL)
- savie asbl NGO LGBTQI DRC
- Sdružení pro integraci a migraci, o.p.s.
- SEED Malaysia
- SekswerkExpertise
- Sensoa
- SERAC-Bangladesh
- Sex og Politikk (IPPF Norway)
- Sex Workers Alliance Ireland
- Sexual Reprodutctive Justice Coalition – Southern Africa
- SHOP (Stichting Hulp en Opvang Prostitutie en Mensenhandel)
- SHOP the Hague
- Sindicato OTRAS
- SistersLab – Association of Women in Science and Technology
- Skeiv Ungdom / Queer Youth Norway
- Society of Gender Professionals
- Solidarity Yaad International
- Somos Manada México
- STAR-STAR Skopje
- Success Capital Organisation
- Surkuna Ecuador
- Survivor Exit Foundation
- Tamtang Group
- The Canadian Association of Elizabeth Fry Societies
- The Federation of the Women Associations in Turkiye
- The Global Interfaith Network For People of All Sexes, Sexual Orientations, Gender Identities and Expressions (GIN SSOGIE)
- The May 17 Association
- The Regional Collective of Women who Use Drugs
- The Society for Education on Contraception and Sexuality
- Trans Hälsoplattformen (Trans Health Platform)
- Trans-Dífusion Asociación Civil
- Transammans
- Transcontingenta
- Uluntu Africa
- United Belize Advocacy Movement
- Urgent Action Fund for Feminist Activism
- Vaqueros CDMX
- Vecinas Feministas por la Justicia Sexual y Reproductiva en América Latina
- VIHve Libre
- WO=MEN Dutch Gender Platform
- Women & Girls Capabilities & Empowerment Organization Nigeria
- Women Enabled International
- Women Deliver
- Women for Green Economy Movement Uganda
- Women for Women’s Human Rights – WWHR
- Women Make Movies
- Women’s Rehabilitation Centre
- Womens leadership center
- Young Feminist Europe
- Youth Association for Development (YAD) Pakistan
- YUWA
- Zamara Foundation
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