The “period of reflection” a person wishing to change gender must observe before obtaining a gender recognition certificate is unnecessary, according to the equality watchdog.

The Equality and Human Rights Commission spells out its opposition in its submission to the government’s controversial consultation on the Gender Recognition Act, which was due to close on Friday, but has been extended until noon on Monday due to the high number of submissions.

While its thinking is in line with that of leading human rights groups, including Amnesty International, women’s organisations believe dispensing with a period of reflection would be a retrograde measure.

WomansPlaceUK believes a gap of one to two years before applying for, and obtaining, a certificate is essential, as it would “protect and support the applicant in making the right decision for themselves and for society in general, demonstrate sincerity and commitment to the change [and] enable the applicant to be confident in their final decision”.

Moves to reform the act to make it easier for a person to self-identify have sparked a fierce debate between transgender campaigners and feminist groups who fear its impact on women-only services and spaces.

David Isaac, who chairs the commission, last night appealed for “all voices to be heard”, an acknowledgment of concerns that the debate was being stifled amid claims of intimidation and harassment.