Key points
- A mere change of label: the working group replaces the word “Islamophobia,” now politically worn out, with “anti-Muslim hostility.” The scope is identical, but the new term, less loaded, is more readily adopted by public bodies and companies.
- A lowered threshold: in English, “hostility” has a broader meaning than “hatred.” It encompasses simply disliking, disapproving of or opposing something. A reasoned disagreement may therefore be enough to fall within the scope of the definition.
- Judge and party: the members of the working group who drafted the definition are also the leaders of the body designated by the government to monitor its application (the British Muslim Trust, endowed with 2.6 million pounds of public funds). The same people produce the norm, apply it and benefit from it.
- A disguised reintroduction of a controversial mechanism: Non-Crime Hate Incidents - police records of non-criminal acts motivated by hatred - are being phased out because of the harm they cause to freedom of expression. The new definition effectively reinstates them, but for the benefit of a single religious group.
1. Context
For a non-British readership, several elements of context, all drawn from the report itself, must be recalled in order to grasp what is at stake in the text.
A political sequence spread over nearly ten years
The British debate over the official definition of “Islamophobia” goes back to 2018, when the All-Party Parliamentary Group (APPG) on British Muslims - a cross-party parliamentary body - proposed a definition according to which “Islamophobia is rooted in racism and is a type of racism that targets expressions of Muslimness or perceived Muslimness.” This APPG definition, recalled repeatedly by the authors, is the matrix from which all subsequent developments must be understood. The current Labour government set up a working group, chaired by the Rt Hon Dominic Grieve KC, former Attorney General, tasked with producing a new official definition.
A draft made public through an organized leak
On 15 December 2025, the text of the draft was passed to the BBC. Within the hour following the first tweet by the journalist who received it, Baroness Shaista Gohir, a member of the working group, issued a 500-word statement confirming the authenticity of the text and calling on the government to adopt it “without delay.” The authors note that this release came the day after an Islamist attack that killed fifteen people in Australia, underscoring the clumsy timing of the operation. The report further reveals that the leak was partial: not communicated to the press were (i) a list of examples of statements not classifiable as hostile, and (ii) a clause allowing public bodies and companies to adopt their own definitions, possibly broader ones.
The text of the draft
The draft consists of three paragraphs.
The first characterizes as “anti-Muslim hostility” the committing or encouraging of criminal acts (violence, vandalism, harassment, intimidation “physical, verbal, written or communicated by electronic means”) directed at Muslims or people perceived as such because of their religion, ethnicity or appearance. The second paragraph targets “the harmful stereotyping and racialization of Muslims, as a collective group with defined characteristics, in order to stir up hatred against them.” The third extends the notion to “prohibited discrimination where the conduct in question - including the creation or use of practices and biases within institutions - aims to disadvantage Muslims in public and economic life.”
The British legal substrate invoked
The report refers to several texts that it is important to identify for a continental reader.
The Crime and Disorder Act 1998 defines a racially or religiously aggravated offence as one “motivated wholly or partly by hostility towards members of a racial or religious group.” The Sentencing Act 2020 retains the same notion of hostility as an aggravating factor. The Equality Act 2010 defines race by “colour, nationality or ethnic or national origins.”
These three texts constitute the legal framework in force, which, according to the authors, the project seeks to circumvent.
The Non-Crime Hate Incidents (NCHI) mechanism - the recording by British police of acts that do not amount to an offence but are reported as motivated by hatred - is also central: about 13,000 NCHIs were recorded in 2024. The Court of Appeal's ruling in the Harry Miller case criticized the “exceptionally low” threshold for these records and their “chilling effect” on freedom of expression.
The recurring institutional actors
The report refers to several organizations that the non-British reader needs to be able to place, because their entanglement forms the heart of the mechanism it denounces. The Muslim Council of Britain (MCB) is an Islamic federation long kept at arm's length by successive British governments, across all parties, because of positions deemed incompatible with democratic values; it is now led by Wajid Akhter, whose problematic public statements Policy Exchange documented in January 2025, notably the call for British Muslims to raise their children to identify primarily as Muslims rather than as British. The Muslim Women's Network, led by Shaista Gohir - herself a member of the government working group - made itself notable by describing as “hostility towards Muslims” the media coverage of a mosque race that excluded women and girls, demonstrating the expansive use it intends to make of the vocabulary it is helping to define.
The ousting of Tell Mama is in itself revealing. This organization, founded by Fiyaz Mughal and active for thirteen years in monitoring anti-Muslim acts, had a unique field experience; it has just been pushed aside in favor of a new body with no experience, the British Muslim Trust (BMT), after what Mughal calls a “smear campaign.” Yet the BMT, endowed with up to 2.6 million pounds of public funds to monitor the application of the future definition, is led by Akeela Ahmed - who sits precisely on the working group tasked with drafting that definition. In other words, the same person drafts the norm and becomes its official operator, paid from public funds.
The BMT is moreover co-funded and co-controlled by the Aziz Foundation, created by the property developer Asif Aziz. This foundation simultaneously funds MEND (Muslim Engagement and Development), the Islamophobia Response Unit and Islamophobia Awareness Month, and works closely with the MCB - that is, all the bodies that have campaigned for years for the adoption of a binding definition of Islamophobia. The same funding source thus feeds both the groups that demand the definition and the government body supposed to oversee its application. The East London Mosque - whose October 2025 event, a race excluding older women and girls, fueled the media controversy - completes this map as an actor seeking to have legitimate criticism reclassified as “anti-Muslim hostility.”
What appears here, then, is not a plurality of independent actors, but an integrated apparatus in which the same people and the same funders simultaneously hold the roles of producer of the norm, institutional enforcer and beneficiary.
The British backdrop to the debate
Two contextual dossiers are implicitly invoked. On the one hand, the grooming gangs: the Rotherham scandal, the police failures attributed to the fear of being called “racist,” and the finding of an overrepresentation of British Pakistanis in these group sexual-violence networks - a subject that the draft definition, according to the authors, would make difficult to raise publicly. On the other hand, counter-terrorism policy: the report notes that Islamist terrorism is responsible for 94% of terrorism deaths in Great Britain over the past quarter-century, a proportion higher still over the last ten years, and that the Prevent program is openly contested by the Aziz Foundation as “actively harming Muslims.”
An earlier intervention by Policy Exchange
The authors state that in October 2025 they published a first paper, The Islamophobia Definition Observatory, anticipating the terminological shift from “Islamophobia” to “anti-Muslim hostility.” The present report is its sequel, following the December leak.
2. Central thesis
The terminological substitution is strategic, not substantive. By discarding the word “Islamophobia,” now politically cumbersome, the working group equips itself with a less connoted term, therefore more easily deployed by activist circles and more easily adopted by public and private institutions. The authors show that the semantic field of “hostility” - attested by dictionaries as encompassing merely “disliking,” “disagreeing with” or “opposing” - is structurally broader than that of “hate.” The Law Commission itself, cited in the report, distinguishes “hatred” (the condition for the offence of incitement to hatred) from a “hostility” that includes mere displeasure, mockery or offence: “hatred is more than mere hostility, or ridicule, or offence.”
3. Argumentative structure
The report sets out six demonstrations.
a) Doctrinal continuity
As early as the 1997 Runnymede Trust report - the first significant entry of the term into British public debate - Islamophobia had been defined as “an unfounded hostility towards Islam.” Shaista Gohir herself described the new text as a “definition of Islamophobia that isn't called Islamophobia.” The announced compromise is therefore a repackaging.
b) Extending the domain of speech control
The authors marshal a corpus of documented uses of the term “hostility” by activist actors to neutralize legitimate criticism. A few examples: the media coverage of a race organized by the East London Mosque from which older women and girls were excluded, described by the Muslim Women's Network in October 2025 as “disproportionate media attention... reflecting a more general hostility towards Muslims rather than a genuine concern for women's equality”; an interview described as “striking in its hostility,” Emma Barnett's on BBC Woman's Hour with Zara Mohammed, former secretary general of the MCB, in 2021, an interview which the authors note was in reality “entirely normal”; the MCB's denunciation of an alleged “long history of hostility towards British Muslims” on Policy Exchange's part; the 2015 boycott of Rotherham police on grounds of “hostility” after the grooming gangs scandal, whose leader, Muhbeen Hussain, then played a key role in drafting the APPG 2018 definition.
c) A truncated leak and a blank check handed to institutions
The authors reveal that the text passed to the BBC was deliberately stripped of two decisive elements, a choice that sheds light on the working group's communication strategy.
The first hidden element is the list of statements that the definition considers not hostile - that is, what remains lawful to say publicly. This list, presented as a safeguard for freedom of expression, turns out in reality to be restrictive: it allows, for example, theological criticism of Islam - a purely doctrinal debate, unlikely to be penalized in a secularized society - but it does not allow the statement of an established statistical fact documented by several official British inquiries, namely the overrepresentation of British Pakistanis in grooming gangs cases (organized networks of sexual violence targeting underage girls). In other words, the definition protects abstract religious controversy but leaves open to attack the inconvenient factual finding. What the list spares is secondary; what it does not spare is precisely what had been, in the Rotherham affair, at the heart of the scandal of police failures driven by the fear of being called “racist.”
The second hidden element is graver still: the draft contains a clause allowing public administrations, local authorities, police forces, universities, hospitals and private companies to adopt, if they wish, their own definitions of “anti-Muslim hostility” - potentially broader than the government's. In concrete terms, every town hall, every HR director, every head of an institution will be able to extend the definition at its discretion, without central oversight and without parliamentary debate. The authors describe this provision as an institutional carte blanche: it turns a text that presents itself as measured into a matrix of unlimited variations, leaving the most militant actors - notably in “diversity” departments and mediation bodies - free to impose the most expansive wordings locally. The mechanism thus does not merely lower the threshold of what is deemed hostile: it delegates to thousands of decision-making levels the power to lower it further still.
d) “Hostility”
The draft's third paragraph - targeting “the creation or use of practices and biases within institutions... intended to disadvantage Muslims in public and economic life” - opens the way, according to the authors, to a systemic challenge to counter-terrorism arrangements and migration policies. The report documents several earlier uses of the word “hostility” in this sense: Amnesty International in 2021 denouncing the “hostile and degrading” environment created by counter-terrorism surveillance; the Migrants' Rights Network recasting the Home Office as a “Hostile Office” to be dismantled; Mary-Ann Stephenson, now chair of the Equality and Human Rights Commission, calling in April 2025 for an end to the “hostile policy” towards illegal migrants; the controversial ban on Israeli supporters of Maccabi Tel Aviv attending a match at Aston Villa, justified by “so much hostility and uncertainty.” The report also cites the presentation given to the working group by Amira Elghawaby, the Canadian government's Special Representative on Combating Islamophobia, who defines Islamophobia as including “viewing and treating Muslims as a greater security threat [than others] on an institutional, systemic and societal level.” The MCB, in its workplace guide, extends the notion of hostility to the absence of prayer breaks, to unintentional “microaggressions” and to professional events “deliberately held in bars with alcohol.”
e) Circumventing existing law
The notion of “racialization of Muslims” - retained in the draft and insistently defended by the MCB and the East London Mosque - takes up, in an academically ennobled form, the APPG 2018 thesis. The East London Mosque argues that “any definition seeking to address anti-Muslim racism must reflect the reality that Muslims are regularly targeted as a racialized minority, and not simply as adherents of a faith.” Yet the Equality Act 2010 defines race by objective criteria (colour, nationality, ethnic or national origin), and the Equality and Human Rights Commission has already confirmed that anti-Muslim hatred is not legally a form of racism. The government itself has acknowledged that the racial references in the APPG definition were “not compatible with the Equality Act.” The promoters' aim would therefore be, according to the authors, to shift case law and policy through normative sedimentation, hoping that the official adoption of a definition including “racialization” will in time drag the courts and the legislature along with it.
f) Conflating judge and party
Akeela Ahmed, a member of the working group, was simultaneously appointed chief executive of the British Muslim Trust (this body, new and with no experience of victim support, replaces Tell Mama, ousted after thirteen years of activity). Its chair, Shabir Randeree, justifies its creation by “a growing sense that anti-Muslim hatred in this country was not being properly recorded.” The BMT is co-funded and co-controlled by the Aziz Foundation linked to the MCB, along with Shaista Gohir and Dominic Grieve (who chaired the Citizens' Commission on Islam, Participation and Public Life, a project funded by the Aziz Foundation, which had already recommended “the adoption of a definition of anti-Muslim prejudice”). The BMT will be the day-to-day operator of the definition, a body consulted by institutions and a likely intervener before the courts.
4. Three transferable analytical operations
The report has a methodological interest in itself: it provides three analytical directions.
First, the documentation of chains of funding and interlocking personnel. The authors do not merely denounce an ideological convergence: they methodically establish, with primary sources in support (official documents, activity reports, archived tweets, financial statements), that the same people and the same funders are found simultaneously in the drafting working group, in the official monitoring body (BMT), in the main funding foundation (Aziz Foundation) and in the beneficiary activist bodies (MCB, MEND).
Second, the opposition between a stabilized legal definition and an extensible activist definition. Rather than argue on emotional or communal ground, the authors systematically confront the activist project with existing law, text by text: the Equality Act 2010, which strictly defines race by objective criteria, the Crime and Disorder Act 1998, which frames the notion of hostility, the Miller case law, which protects freedom of expression. This legal method shifts the debate from the moral register to the constitutional register: it shows that the draft definition does not add extra protection to a legal vacuum, but that it attempts to circumvent an already protective body of law by introducing into it notions foreign to it (“racialization”).
Third, the identification of a mechanism of disguised reactivation. Non-Crime Hate Incidents (NCHI) - police records of non-criminal acts reported as motivated by hatred - are being phased out in the United Kingdom because case law and public debate have established their liberticidal character. The authors show that the new definition would make it possible to reinstate them de facto, but this time for the exclusive benefit of a religious group. This operation - abandoning a controversial general norm while reintroducing it in the form of categorical protection - constitutes an identifiable and reproducible pattern. Being able to name it makes it possible to anticipate it: in France, any reintroduction of abandoned mechanisms (recording of opinions, contested administrative-policing measures) under the guise of protecting a minority can be spotted and denounced using the same interpretive grid.
Dr Florence Bergeaud-Blackler
Anthropologist, Research Fellow at the CNRS (HDR)
Founding President of CERIF - European Center for Research and Information on the Muslim Brotherhood
cerif.eu