Nobody in their right mind would formulate an equality law justification for forcing gay men to use a third set of toilets to protect the inherent dignity of a (not statistically insignificant) group of men who are uncomfortable with doing so.

The nebulous idea that a ban is not necessary for safety, but for the 'dignity and respect' of cisgender women makes me deeply uncomfortable. I know plenty of men from my time growing up who would happily admit they would not be comfortable using a urinal next to an openly gay person

I do not see how banning trans women from women's toilets is a proportionate way of achieving a legitimate aim. The argument that trans women pose a risk to cisgender women's safety is entirely speculative, based on its own prejudices around tran people and is not supported by real world evidence.

On the other hand, an explicit call-out that in some circumstances trans women may be banned from using either the men's or women's facilities. Presumably, this will leave trans people having to ask for the radar key for the disabled toilets. It's nice to know where the EHRC's priorities lie.