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Given that being trans (i.e. having the protected characteristic of gender reassignment) is v. wide criteria, this in practice means the service is mixed sex. So then it should be labelled mixed sex (which with floor-to-ceiling cubicles, as you say, is fine)
The point is there should be clear expectations for all - women should be able to be told clearly if a changing room, toilet, dorm, showers whatever is single sex or mixed.
Do you understand this? Visually, auditorily there is no way to distinguish between a male person with the protected characteristic of gender reassignment and one without (and it would be rude to try).
So either you let males in and make something mixed sex (and signpost it that way), or you keep it single/ separate sex. The guidance will need to provide clarity.
You seem to be arguing from a user right to expect segregation, but UK law does not have such a right. The closest I can think of is a Canadian case, which establishes a right to privacy from "other sex" when nude only.
However, when there is actual shared nudity (not the case in toilets), the "indistinguishable for all practical purposes" guidance can be applied, which in that specific case means genital configuration as visible. It was probably written *for* that specific case.
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