Evaluation of the “National Plan for Equality, Against Hatred and Anti-LGBT+ Discrimination (2023-2026)

Source: 📒 Evaluation of the “National Plan for Equality, Against Hatred and Anti-LGBT+ Discrimination (2023-2026)✍️

 📜🔗LINK

1. Analytical summary

Context and issues: an ambitious plan on paper, but little effective

The opinion analyses the fourth national plan for equality of rights and against anti-LGBT+ discrimination (2023-2026), published on 10 July 2023, in a context of documented increases in violence and discrimination, despite significant legislative advances over the past 40 years. The CNCDH reminds us that this plan was adopted before the evaluation of the previous plan and without real structured consultation with associations, several ministries, or independent institutions such as the Defender of Rights or the CGLPL. The content appears disconnected from the expectations of the people concerned, particularly trans, intersex, lesbian, bisexual, and pansexual individuals, with major blind spots on asylum, immigration, and education on emotional, relational, and sexual life (ÉVAR/ÉVARS). The opinion also highlights the paradox between a proactive political discourse and a reality of persistent hostility, transphobic backlash, and the rise in anti-LGBT+ crimes and offences recorded by the police since 2016. It finally points out the intersection of discriminations (sexism, racism, precarity, ableism...) that worsen the situation for many LGBTI+ groups.

Operational contributions: 127 recommendations for a 2026-2029 plan that is led, funded, and co-constructed.

The CNCDH shows that only about 20–21% of the measures in the 2023‑2026 plan have been fully implemented, with two-thirds not having been carried out or having been done insufficiently, due to vague, unquantified objectives, without a precise budget or operational timeline. It proposes 127 recommendations, including 20 priorities, to structure the next 2026‑2029 plan: real co-construction with associations, systematic consultation of ministries, outcome indicators, detailed budgeting, LGBTI referents by ministry, and strengthening of the CORAHD. The text provides very concrete prescriptions on training (police, justice, health, education, asylum), LGBTI+ asylum, ÉVAR/ÉVARS, trans health, protection of intersex individuals, labelling, and sustainable funding for LGBT+ centres. It emphasises the need to transfer part of the burden on associations to the State, by securing funding, avoiding 'grant blackmail', and recognising community health as a structuring partner. This opinion thus positions itself as a directly actionable roadmap for future texts, plans, and territorial programming.

2. Key points of the document 

1. The 2023‑2026 plan is deemed overall disappointing: only about 20–21% of the measures have been fully implemented, with more than two-thirds not realised or implemented inadequately, due to a lack of measurable objectives, precise budget, and structured management (absence of clear numbering, indicators, and monitoring) (p. 2, 30–31, annex 5).

2. The drafting process was rushed and incomplete: chaotic and partial consultation of associations (implicit selection, lack of feedback, low consideration of more than 300 proposals), ineffective consultation of several ministries and independent institutions, and almost total disregard for previous recommendations from the CNCDH (pp. 11–13, 75–76).

3. Large sections of the public and policies are rendered invisible or marginalised: no specific measures for asylum and migration, lack of integration of education on emotional, relational, and sexual life, low ambition for trans people, minimisation of intersex realities, invisibility of lesbian, bisexual, and pansexual people (pp. 17–22, 33–41).

4. LGBT+ associations and centres carry out a massive share of public service missions (access to rights, health, housing, legal support, prevention, support for migrants) with unstable funding, despite a fund of 10 million euros for LGBT+ centres; the CNCDH emphasises the need to define, label, and territorialise these centres to limit abuses and territorial inequalities (pp. 28–29, 33, 66–71, 73–76).

5. The opinion details a range of operational measures, from strengthening training (police, gendarmerie, justice, health, asylum, education) to revising lists of safe countries of origin, including the effective implementation of the three sessions of ÉVAR/ÉVARS, the de-judicialisation of changing gender markers on civil status documents, and the labelling of LGBT+ centres, to structure a forthcoming plan for 2026–2029 based on effective rights and verifiable indicators (pp. 14, 30–32, 37–45, 66–71, 75–76).

3. Action points for local actors 

• Integrate the CNCDH recommendations into territorial diagnostics (CLS, CPTS, associative projects, social schemes) by identifying absent or locally marginalised groups (trans people, intersex individuals, LGBTI+ asylum seekers, young people without effective ÉVAR/ÉVARS) and explicitly naming them in action plans (p. 17–22, 33–41, 75–76).

• Use the training recommendations to negotiate with ARS, rectorates, prefectures, and bar associations for mandatory modules on LGBTI+ discrimination for healthcare providers, social workers, criminal justice agents, school staff, and asylum actors, relying on the requirement for initial and ongoing training set out by the CNCDH (p. 22–25, 35–36, 80–81, 75–76).

• Mobilise the proposed framework for LGBT+ centres (labelling criteria, missions, territorial network) to consolidate or create local LGBTI+ resource hubs (health, social, legal, prevention) and advocate for secure multi-year funding, particularly in rural and overseas territories (p. 66–71, 69–70, 75–76).

• Draw on the recommendations regarding asylum and migration to train accommodation providers, social support workers, and healthcare access personnel on the specific needs of LGBTI+ migrant and asylum-seeking pathways, and to engage with prefectures and OFPRA regarding the consideration of vulnerabilities and effective access to rights (p. 33–36, 75–76).

Link education on emotional, relational, and sexual life with prevention actions carried out by associations and youth structures (MDPH, local missions, PAEJ, animation structures) by using the recommendations on the effectiveness of the three annual sessions, the creation of ÉVAR/ÉVARS referents, and the remuneration of associative interventions (p. 37–41, 75–76).

4. Additional References

1. Ministry of Higher Education and Research, "Fighting Hate and Anti-LGBT+ Discrimination in Higher Education and Research" (updated guide 2021): methodological guide with practical sheets on prevention, reporting, and addressing LGBTphobias in institutions.https://www.enseignementsup-recherche.gouv.fr/sites/default/files/2021-10/guide-2021-lutter-contre-la-haine-et-les-discriminations-anti-lgbt-dans-l-esr--14053.pdf

2. European Commission, "LGBTIQ+ Equality Strategy 2026-2030": European strategic framework specifying the expected contents of national LGBTIQ equality plans and the levers (governance, data, participation, combating violence).https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/combatting-discrimination/lesbian-gay-bi-trans-and-intersex-equality/lgbtiq-equality-strategy-2026-2030_en

5. Cross-Analysis — Values of Pratiques en Santé

• Literacy: the document remains legal and institutional, without simplified educational tools for different levels of understanding; it rather targets expert readers (p. 5–10, 75–76).

• Empowerment: LGBTI+ beneficiaries are not directly involved as co-authors, but the associative voice is widely mobilised through hearings, written contributions, and consultation, which provides a perspective close to lived experience (p. 14, 15, annexes 3–4).

• Participation: the opinion critically addresses the lack of real co-construction of the plan with associations and proposes to fully involve them in the development of the next plan (p. 11–17, recommendation no. 1).

• Community Health: it explicitly recognises the structuring role of LGBT+ centres and community health associations (screening, support, prevention) and recommends securing their resources (p. 28–29, 66–69).

• Ethics: the text identifies several biases (Western centrism in asylum, abusive medicalisation of trans journeys, invisibility of certain groups) and makes recommendations to correct them (pp. 33–36, 41–45).

• Human rights: the approach is explicitly based on human rights, equality, and the effectiveness of rights, with references to international and European law and the principles of inclusion and non-discrimination (pp. 4–9, 12–13, 43).

• Intersectorality: the opinion covers a large number of ministries (Interior, Justice, Health, Labour, Education, Sports, Culture, Housing, Armed Forces…) and emphasises the need for strengthened inter-ministerial coordination (pp. 39–60, recommendations 5–7).

• Partnership: it proposes to formalise roles (ministerial referents, CORAHD, monitoring committees) and to better articulate administrations, independent institutions, and associations in the steering of policies (pp. 27–29, 71, 75–76).

• Combating discrimination: the entire opinion is focused on anti-LGBT+ discrimination, with particular attention to intersectional forms and violence directed against trans, intersex, and migrant LGBTI+ individuals; it values non-judgment and diversity as principles of action (pp. 5–9, 33–41, 40–45).

Points of caution in facilitation (sensitive theme)

The document directly addresses sensitive themes: LGBTphobias, violence and discrimination against LGBTI+ individuals, situations of trans and intersex individuals, asylum requests, online violence, mental health and suicide risk, sexist and sexual violence, issues of sexual education.

Risks of emotional triggering:

• Accounts or data on discrimination, aggression, online hate, and physical violence against LGBTI+ individuals, particularly trans people.

• References to international contexts where homosexual relationships are penalised, even punishable by death.

• Mention of mutilations or treatments imposed on intersex individuals and abusive practices known as 'conversion therapies'.

• Highlighting the precariousness, risk of suicide, and suicide attempts among trans individuals, particularly young people.

• Description of asylum situations where the intimacy and credibility of sexual orientation or gender identity are called into question, sometimes in a perceived hostile institutional setting.

In facilitation, it is necessary to:

• Inform participants of the sensitivity of the content and offer a right to withdraw without justification.

• Provide breaks, secure speaking spaces, and, if possible, a listening resource (psychologist, peer supporter, helpline).

• Avoid scenarios that may revive personal experiences of violence or discrimination, favouring the analysis of anonymous and distanced cases.

6. Evaluation of the reliability of the resource.

• Scientific relevance: the opinion is based on recent national surveys (CSF 2023, Ifop barometers, INSERM/ANRS studies, SOS Homophobie work, Acceptess-T), court decisions, legislative and regulatory texts, and reports from national and international institutions, with a detailed notes apparatus (pp. 5–9, multiple footnotes). The evaluation methodology is explicit: written questionnaires, over 40 hours of hearings, analysis by measure with a tracking table in the annex (p. 14, annex 5).

• Operational relevance: the resource is directly actionable, as it outlines 127 recommendations, often formulated in precise terms (who should do what, with what levers: mandatory training, budget, indicators, timeline, modification of safe country lists, labelling of centres, creation of referents). However, some points remain at the macro-political level and require local translation by field actors (ARS, local authorities, associations, establishments), making it a framework document rather than a 'turnkey' operational implementation guide.

7. MCQ — 5 questions

Part 1 — MCQ without answers

Question 1 (pp. 2, 30–31, web):

According to the CNCDH, what proportion of the measures in the LGBT+ Plan 2023-2026 has been fully implemented?

a) About 10%

b) About 20–21%

c) About 50%

d) More than 75%

Question 2 (pp. 33–36):

Which group is completely absent from the specific measures of the 2023-2026 Plan, according to the CNCDH?

a) Older LGBTI+ people

b) LGBTI+ people with disabilities

c) Migrant and asylum-seeking LGBTI+ people

d) LGBTI+ employees in the private sector

Question 3 (p. 37–41):

What does the CNCDH remind us about education for emotional, relational, and sexual life (ÉVAR/ÉVARS)?

a) It has never been included in French law

b) The law provides for three annual sessions, which are largely not implemented

c) It only concerns vocational high schools

d) It is reserved for private institutions not under contract

Question 4 (p. 66–71):

For LGBT+ centres, what is one of the main concerns of the CNCDH?

a) The systematic refusal of grants by local authorities

b) The lack of a clear definition of what a "LGBT+ centre" is

c) The prohibition of employing staff

d) The obligation to be located only in rural areas

Question 5 (p. 11–13, 75–76):

What major criticism does the CNCDH make regarding the procedure for developing the 2023-2026 Plan?

a) A consultation that is too long and costly

b) A lack of participation from private companies

c) Insufficient consultation with the relevant associations and ministries

d) An excess of quantitative indicators making the plan unreadable

Part 2 — Commented correction

Question 1:

✅ Correct answer: b) Approximately 20–21%

📝 Explanation: The opinion indicates that only about 20–21% of the measures in the plan have been fully implemented, while two-thirds have not been implemented or have been insufficiently implemented, due to a lack of operability, governance, and monitoring. Source: p. 2, 30–31, annex 5.

Question 2:

✅ Correct answer: c) LGBTI+ migrants and asylum seekers

📝 Explanation: The CNCDH highlights the complete absence of specific measures for LGBTI+ individuals in migration or asylum situations in the 2023–2026 plan, even though the previous plan had included this very vulnerable group (intersection of discriminations). Source: p. 17–19, 33–36.

Question 3:

✅ Correct answer: b) The law provides for three annual sessions, which have largely not been implemented

📝 Explanation: The opinion recalls that since 2001, the law has mandated three sessions per year on emotional, relational, and sexual education, but this obligation has not been systematically applied, resulting in a condemnation of the state and the late implementation of an ÉVAR/ÉVARS programme in 2025. Source: p. 37–41.

Question 4:

✅ Correct answer: b) The absence of a clear definition of what a "LGBT+ centre" is

📝 Explanation: The CNCDH is concerned about the lack of a definition for LGBT+ centres, which would secure funding, prevent abuses and competition between structures, and proposes to develop a labelling system based on criteria shared with the LGBTI+ Federation. Source: p. 66–69, recommendation no. 32.

Question 5:

✅ Correct answer: c) Insufficient consultation with the relevant associations and ministries

📝 Explanation: The opinion describes a chaotic consultation of associations (opaque selection, proposals poorly taken into account) and the lack of real involvement from several ministries and independent institutions in drafting the plan, which leads to unrealistic, redundant, or incomplete measures. Source: pp. 11–13, recommendations no. 1 to 3, 75–76.

8. Frequently Asked Questions (FAQ)

1. What are the main objectives of the LGBT+ Plan 2023‑2026 evaluated by the CNCDH?

   The plan aims to affirm the reality of LGBTphobias, measure discrimination, guarantee access and effectiveness of rights, sanction perpetrators of anti-LGBT+ acts, and defend LGBT+ rights at the European and international levels. Reference: introduction, pp. 5–6, table of contents.

2. Why does the CNCDH consider the implementation of the plan to be disappointing?

   Because only 20–21% of the measures have been fully implemented, due to vague, unquantified objectives, without a dedicated budget or clear management, which prevents tracking and evaluating the effectiveness of actions. Reference: summary p. 2, pp. 30–31, annex 5.

3. Which groups are the most forgotten or marginalised in the plan according to the CNCDH?

   Migrants and asylum seekers who are LGBTI+, trans, intersex, lesbian, bisexual, and pansexual individuals, as well as those concerned with education on emotional, relational, and sexual life, are deemed particularly invisible or insufficiently taken into account. Reference: pp. 17–22, 33–41.

4. What role do LGBT+ associations and centres play in the implementation of LGBTI+ policies?

   They play an important role in public service missions (access to rights, community health, support for migrants, prevention, accommodation) with fragile resources; the CNCDH recommends securing their funding, labelling the centres, and correcting territorial disparities. Reference: pp. 28–29, 66–71.

5. What does the CNCDH recommend regarding asylum for LGBTI+ individuals?

   It advocates for mandatory training for OFPRA agents and CNDA judges, a strengthened use of the normal procedure rather than the accelerated one for these applications, a review of the list of so-called safe countries of origin, and the explicit consideration of trans identity and intersex status, as well as the recognition of summons as a travel document. Reference: pp. 33–36, recommendations no. 12–16, pp. 75–76.

6. How does the document address education on emotional, relational, and sexual life (ÉVAR/ÉVARS)?

   The CNCDH regrets the lack of specific measures on ÉVAR/ÉVARS in the plan, whereas the law mandates three annual sessions that have not been implemented for over twenty years, and recommends a dedicated budget, academic referents, remuneration for associations, and the publication of follow-up data. Reference: pp. 37–41, recommendations no. 17–22.

7. How can this opinion help health, social, and medico-social professionals?

   It provides a reasoned framework to advocate for mandatory training on LGBTI+ issues, structured partnerships with LGBT+ centres, and better consideration of multiple discrimination in establishment projects and reception protocols, particularly for trans, intersex, migrant, and young individuals. Reference: pp. 22–25, 39–50, 66–71, annex 2.

9. Rewriting in Easy-to-Read Language 

9.1. Analytical summary in Easy-to-Read Language

Title: What is this document about

The document discusses a government plan to protect LGBT+ people in France.

This plan aims to combat hate and injustices against lesbian, gay, bi, trans, and intersex people.

The CNCDH is an official group that checks if this plan is really working.

It has looked at how the plan was created and used in practice.

It shows that many promises have not been kept.

It also explains which groups of people are overlooked by this plan.

Title: What the CNCDH proposes

The CNCDH says that only a small part of the actions in the plan has been carried out.

It makes 127 proposals to better protect LGBT+ people.

It asks that associations be listened to and involved from the start.

It wants each action of the new plan to have a clear objective, a budget, and a date.

It emphasises the training of many professionals: police, justice, health, school, asylum.

It also asks for more resources for LGBT+ centres and prevention in schools.

9.2. Key points in Easy-to-Read Language

Title: Idea 1 — The plan is poorly implemented

Many actions of the plan have not been done or have been done very poorly.

The objectives are often vague and hard to measure.

There are almost no figures or money allocated for each action.

It is not clear who is responsible for what.

Therefore, it is difficult to verify if the plan really helps LGBT+ people.

Title: Idea 2 — The voices of those concerned are not heard enough

LGBT+ associations have not been sufficiently consulted in writing the plan.

Their proposals have been very minimally included in the final text.

Several ministries and institutions have not been truly involved.

This creates a plan that does not adequately meet the needs on the ground.

The CNCDH calls for genuine co-construction of the next plan.

Title: Idea 3 — Some audiences are forgotten

LGBT+ migrants or asylum seekers are not taken into account.

Trans and intersex people are not very visible in the planned actions.

Education on emotional, relational, and sexual life in schools is not addressed.

Lesbian, bisexual, and pansexual people are also mentioned too little.

This exacerbates the risks of violence and injustices for these groups.

Title: Idea 4 — Associations bear too much of the burden alone

LGBT+ centres and associations do a lot of public service work.

They assist with health, housing, rights, support, and prevention.

They have received significant funding, but often without a clear framework or stability.

Resources remain fragile and vary across regions.

The CNCDH wants a clear definition, a label, and sustainable funding.

Title: Idea 5 — Concrete solutions for the future

The CNCDH proposes making training on anti-LGBT+ discrimination mandatory.

It wants quantified indicators, deadlines, and regular monitoring.

She calls for better protection for LGBT+ asylum seekers.

She advocates for education on emotional, relational, and sexual life for all students.

She also recommends facilitating the change of civil status for transgender people.