This is an (incomplete) list of problems I have found in dogma. It does not contain any medical issues (particularly the ones that are not addressed there but should be), does not address partial or complete self-contradictions of dogma, neither does it address missing parts in dogma (while plenty of room is spent on restricting our civil rights), in particular the acknowledgement that transsexuality is not a mental illness and that the motivation of transition can be partly or exclusively emotional or spiritual instead of physical. It also does not address a number of issues dogma outlines which clearly do not belong into a treatment protocol (most notably several sections on ethical positions of the surgeon).

I believe that each and every single position in this list would justify an immediate suspension of the application of this dogma. It is entirely incomprehensible to me why any medical practitioner would be willing to enforce something like this and I am at a complete loss why any person  licensed to practice medicine would support such "standards of care", never mind write or publish these.

Systemic Issues:

1 Transgender treatment as well as today's dogma work on the premise that gender (and gender-identity) only comes in two expressions, completely male and completely female, and that each and every human being must have exactly one of these and maintain the same throughout a lifetime.
I believe that this is not true (I actually believe that it is complete and utter nonsense to make such a claim!), instead I believe that an individual can in fact have more than one gender-identity and that gender itself is a multidimensional concept that is individual to each and every human being (never mind that the same expression of gender would likely be interpreted differently by every observer and in every social setting as well as by every culture, it would also be interpreted differently over time)
2 Dogma bases it's assumption on the premise that gender is derived from how genitals look and that if genitals are ambiguous then doctors do have the right (or even the duty) to assign an unambiguous gender either surgically or by means of brainwashing (which they call 'therapy') - all to the doctor's preference and specification.
I believe that the assumption that a doctor has the right to assign a gender to a human-being either surgically or by means of other therapy, including mental treatment, without or against the consent of this very human-being comes from a long tradition of medical arrogance. Doing this to anybody is wrong, in fact it is my opinion that this should be treated as a first degree assault, perpetrators should be criminally persecuted and punished accordingly. I further believe that gender-experience is made-up in the brain, not in the genitals and while genitals are one part of the gender-experience they are not the most important and most definitely not the only one.
3 Transsexual patients are deemed mentally ill because the physical aspect of gender is given priority over the emotional one. This, in my opinion, happens solely because the group who makes this assertion - medical doctors - are used to treat human-beings from a physical point of view. In fact they appear so used to this view that they have grown by and large incapable to see beyond their interpretation of what being human means.
If gender would be determined from a spiritual point of view then transsexuals would not be mentally ill at all but at best physically handicapped, but even this would depend upon the self-experience and -interpretation of each individual.

The fact that doctors see and interpret their world from a physical perspective may not be a systemic problem of medicine (or it may well be the most important systemic problem western medicine suffers from), but it is most definitely an expression of narrow-mindedness and displays a fundamental lack of acceptance of other views of humanity.

 

Legal issues:

1 Forcing a group of people into mental-treatment because their self-identification fails to meet certain expectations is a violation of the UN charter of human rights, in most countries this is also illegal
2 Forcing only selected people with the same self-identification into such treatment (i.e. transsexual women vs. biological women or transsexual males vs. biological males) is discrimination
3 There in fact exist people who do just fine without the assistance of a psychiatrist (who would have thought?)
4 Forcing an individual into mental treatment without any evidence of any behavioural problem whatsoever is illegal, it is also an abuse of medical power
5 Restricting our rights to make decisions, in particular restricting the rights to freely decide over our own bodies, is a human-rights violation
6 Linking social behavioural expectations such as being unmarried, being employed or identifying heterosexual (after surgery) to providing medical treatment is in sharp contradiction to the medical oath, it is unethical and discriminatory, in many courtiers it is also illegal
7 The absolute minimum required treatment time at a facility requiring proof of “gender-dysphoria” by presence (the standard for a majority of large institutions) is (assuming) a 3 months wait for an initial visit, then typically at least 24 months for the diagnosis, then 12 months on hormonal treatment and then a minimal 9 months wait to obtain surgery, a total of 48 months or 4 years, not including recovery from surgery. This is assuming that everything happens as quickly as possible and the psychiatrists sign their prescriptions and letters on the first possible day - which in itself is just about unheard of. (Realistically the expectation should be about 6 years). This in itself is abusive. It is also painful and harmful, this wait indeed turns deadly for many patients
8 To live "the opposite gender-role" "full time" as required by dogma may in certain circumstances be illegal. This is in particular true when it comes to such things as using washrooms or other legally gender-separated facilities. To force transsexual patients to do something illegal as a condition to obtain medical treatment is unethical, it contradicts the medical oath and it is illegal in itself as forcing a person by means of blackmail to disobey the law is in most jurisdiction a crime in itself.
 

Procedural issues:

1 Dogma distinguishes between 'eligible' and 'ready', both of these criteria need to be met to being allowed on the next step in treatment. being 'eligible' means that one has done the time, has complied endlessly and now expects to be allowed the next form of treatment while 'ready' means that the psychiatrist deems the person 'ready' for this step. This is comparable to the process of parole for prisoners where a committee decides if an inmate is to be released early, i.e. having been sentenced to 4 years but being released after only 3. Only with transsexuals this is turned upside-down: A single person decides not if the patient in question is to be granted treatment a little sooner but if punishment should be extended potentially indefinitely! No reasoning needs to be given as to why 'readiness' is denied, so on top of that already completely arbitrary and highly abusive schedule (which is called "a minimum requirement") any additional criteria a psychiatrist may dream-up can be enforced.
2 Most of the requirements of dogma are largely open to interpretation or are subjective or even entirely arbitrary
3 None of the restrictions of dogma and none of the conditions it sets out have necessarily anything to do with our self-identification or are related to diagnostic results of verifiable medical tests
4 The way this dogma is set-up, in particular that it implicitly states that there is no urgency and that there is never any need for immediate treatment, makes our requests for gender-alignment look as if it were not necessary medical treatment. After all, if there are no cases in which treatment is ever urgently needed and several years of delay are always acceptable then all cases can be postponed time and again and eventually indefinitely without causing significant harm
5 Dogma specifically limits our access only to hormonal treatment and a very small number of surgeries (such as breast augmentation and genital surgery). Other surgeries which are far more invasive or socially visible, such as facial and voice modification, leg- and neck-extensions and many others are freely available to everybody at any time. People who do not require or wish these specific restricted treatments but live the other than assigned gender-role anyway aren’t even considered. This double-standard can only be explained by this being a targeted measure to single-out people who need these select treatments (in particular presumably genital alignment). Such narrow targeting shows that this is indeed not a measure to “help and support”, because if it were then everybody with similar concerns would merit help also!
6 The requirement of "living a gender-role" is entirely arbitrary. It is furthermore in no way related to our medical need
7 The employment criteria of dogma (being 100% employed, full-time volunteer or a full-time student) are discriminatory against people who are under- or unemployed, retired, choose to live on a part-time income, are self-employed or make other socially meaningful but unpaid contributions such as co-workers in a family business, homemakers or people who full or part time care for another person, in particular in home-care
8 The mandatory character of this dogma amounts to socially endorsed punishment based on the grounds of who we are or what we need. This punishment is handed out by a private interest-group bypassing the legal system, its safeguards as well as any and all avenues of recourse
9 Because the psychiatric, medical and mental-health community profits handsomely from how they treat us they are in a conflict of interest situation when it comes to writing dogma, declaring us mental and mandating treatment (their own treatment) onto us.
I am not saying that they have set this up solely for profiteering on a vulnerable population but it is my opinion that over time they have proven that they are incapable to render unbiased judgement.