Beats me honey,
as the rest of the continent (I guess) and Switzerland for sure, asks 3 years RLE with a therapist to prove it. Then you MAY get "THE LETTER(S)", then have GRS, and only then can change your status (M/F).
The UK has it's own law system (still) never been influenced by the Napoleonic code, which BTW also does not allow a female name (and visa versa) if it does not fit your physical sex.
So you need GRS (MtF) at present, *for any ID document change*.
FtMs need breast reduction (if not flat by nature, and be hysterectomised so as not to be able to conceive in guy-mode). A judge is appointed in Berlin High-Court, he will look at you and then decided if it's a go - no go! So t-guy with boobs be a no go for sure, or MtF that does not pass also a no-go. Doctores letter for GRS, etc. must be presented to the judge.
The state considers GRS (penoplasty) for FtM as too invasive to explicitly ask for as in the case of MtF.
So, in answer your question: Yes, those laws are obviously different as are still plenty other laws. It's due the different systems going way back in time: Interpretive Law (UK) vs. Interrogative Law (Germany, France, etc. as in: vee will ask se queschons!) and Coded Law (Germany, etc.) vs. Case Law (UK)
I hope I got it all right, only my ex-gf is a legal-beagle.
Axelle