Less than two months after LGL formally urged Minister of the Interior Vladislav Kondratovič to end the automatic disqualification of trans persons from police service, the Ministry has circulated a draft order amending the Health Status Requirements Code (Sveikatos būklės reikalavimų sąvadas), the legal act governing fitness assessments for statutory service.

The draft, dated 29 April 2026 and prepared by the Ministry’s Public Security Policy Group, was sent to ministries, statutory services, and trade unions for inter-institutional coordination, with copies to LGL and the Office of the Equal Opportunities Ombudsperson. Stakeholders have ten working days to submit opinions.

What the draft proposes on F64.0

Under the current Code, paragraph 5 lists ICD-10 diagnosis F64.0 (transsexualism) as grounds for declaring a candidate unfit for service. Yet the Annex (point 5.2) says unfitness applies only where the Central Medical Expert Commission (CMEK), after psychological assessment, identifies pronounced personality trait accentuation causing behavioural and functional problems. The Ministry now openly acknowledges that this contradiction creates regulatory ambiguity and effectively blocks any individual assessment of a candidate’s suitability.

The amendment resolves the contradiction in favour of individual assessment: a person with diagnosis F64.0 would be deemed unfit only where strongly expressed personality trait accentuation disrupting psychosocial adaptation is established, not on the basis of the diagnosis alone. This is the structural shift LGL had requested in its 6 March letter: a move away from automatic diagnosis-based disqualification toward functional assessment, in line with ICD-11 standards and the practice of EU member states.

The Ministry’s explanatory note frames the change as implementation of Recommendation 3 from the 2025 Annual Report of the Equal Opportunities Ombudsperson, in the section “Ensuring equality of LGBTI+ persons.” The recommendation pointed out that persons with a trans-related diagnosis can already serve as prosecutors, judges, advocates, notaries, and bailiffs, and called for the legal acts setting health requirements for statutory officers to be amended so that those rules no longer restrict trans persons from holding such posts.

The Ministry also references alignment with criteria already applied to soldiers and conscripts under the Minister of National Defence’s 3 June 2020 Order No. V-449, addressing precisely the institutional inconsistency between military and police medical assessment that LGL had highlighted.

The draft is not limited to gender identity. Candidates whose thyroid was removed due to a malignant tumour would be able to apply for service five years post-treatment if no recurrence is detected, and officers with well-controlled diabetes would be allowed to remain in service. For the first time, persons whose hearing can be compensated by assistive devices would also be able to apply, with graded assessment based on the nine-point Stanine scale and individual evaluation depending on the duties of the post.

The order is at the inter-institutional coordination stage. Addressees include the Ministries of Finance, Health and Justice, the Special Investigation Service, the Ministry’s Medical Centre, all major statutory services, and the main police trade unions. Their feedback will shape the final text before the Minister signs the amendment into force. The explanatory note records that no additional public funds will be required.

For LGL, the draft is an important and unusually rapid institutional response. LGL has been advocating for individual functional assessment rather than diagnostic exclusion. The reform is not yet adopted, however, and the precise wording of the new paragraph 5, in particular how “strongly expressed personality trait accentuation disrupting psychosocial adaptation” will be assessed in practice by CMEK, will determine whether the change delivers genuine access to service or simply relocates the disqualification one step further into the assessment procedure. LGL will be submitting its opinion within the consultation window and will continue to press for the methodological guidelines, appeals mechanism, and harmonisation with military assessment standards set out in its March proposals.