In the wake of the U.K. Supreme Court ruling from two weeks ago that trans women aren’t considered women under the law, the country’s leaders are still dealing with the fallout. Over the last two weekends, there were mass protests against the ruling in major cities across the country, but nevertheless, government officials seemed unfazed in pushing forward with further anti-trans actions.

Bridget Phillipson, U.K. minister for Women and Equalities, said in a radio interview last week that the Supreme Court ruling would effectively bar trans women from women’s sex-segregated spaces in the country, including bathrooms. Following Phillipson’s comments, the country’s Equality and Human Rights Commission issued a guidance for public and private entities who provide single-sex facilities to ban trans people from using the room of the gender they identify with. The move represents another giant step back for trans rights in the country, and it is especially concerning coming from the country’s allegedly centre-left political party, Labour.

Since taking power last July, Labour’s secretary of state for Health and Social Care Wes Streeting made a temporary ban on puberty blockers for trans kids instituted under the previous Tory party into a permanent one. Along the way, an internal civil war has seemingly opened up, with many pro-trans members of Parliament sparring with anti-trans voices within the party.

Despite the internal disagreement, however, there is little doubt that of all of the centre-left parties in the English-speaking world, U.K.’s Labour is by far the most transphobic. U.S. Democrats, while often not willing to verbally fight back against near-constant conservative rhetoric against trans people, do tend to show up to vote against key anti-trans measures most of the time, inducing a recent highly contentious U.S. Senate vote on a bill that sought to ban trans athletes from women’s sports.

In Canada and Australia, the Liberal party and Labour party respectively seem to have a very solid record on trans rights.

In fact, U.K. Labour is such an outlier that a debate has recently sprung up on social media as to whether they are worse on trans rights than the U.S. Republican party. One side, the one I tend to agree with, says that U.K. Labour’s actually implemented policies—i.e., the bathroom ban and puberty ban—go much further than anything U.S. Republicans have managed to put into place nationally in the States, while the other side contends that individual red states are unmatched in the level of legal restrictions introduced on trans life. I’d say in rhetoric, almost certainly not. There is a deep-seated obsession with harming trans people within the U.S. political right that just isn’t there for U.K. Labour outside of, let’s say, MP Rosie Duffield.

The media culture around the trans rights debate is simply different in the U.K. Trans people and pro-trans voices have largely been excised from mainstream media coverage in the country, while anti-trans articles are running multiple times a day. In fact, U.S. conservative media is often producing complementary coverage using narratives that first started in the British press, creating a sort of human centipede of transphobic disinformation.

I don’t think those in power with Labour realize the kind of anti-trans media environment they’ve been slowly boiling in for years and how much it resembles the conservative media messaging in the States.

In action, there’s very little difference between U.K. Labour and U.S. Republicans. There is no national ban on puberty blockers in the U.S. right now, though Republicans at the federal level have tried. There is one in the U.K. There is no real threat of a U.S. bathroom ban as long as the Senate filibuster stays in place. A bathroom ban feels much closer to reality in the U.K. right now. In the U.S., trans people can no longer get a passport with a corrected gender marker, while U.K. anti-trans activists have started targeting their own passport system after the court ruling last week.

The anti-trans movement is international, and its actors are co-operative with one another across borders. U.S. anti-trans activists have partnered with U.K. activists and vice versa on plenty of occasions. During a U.S. Supreme Court hearing last year, conservative justices asked many questions about the Cass Report, a document produced by a U.K. examination into youth gender care that disallowed experts in trans care from participating.

There has been much talk over the years about the so-called “special relationship” between the U.S. and U.K. We share a language, we share the same basis in common law and we share the same anti-trans movement, as do Canada and Australia. But it’s only in the U.K. that left-leaning officials have no backbone to stand up for their trans constituents. Just this week, U.K. prime minister Keir Starmer said, through a spokesperson, that he no longer believes trans women are women.

He has his finger in the air, trying to do whatever he thinks polls the best. But in reality, I think Starmer and his Labour peers are cowards and outliers on the international stage when it comes to trans rights.