Overview
On January 27, 2026, the U.S. Department of State published three final rules that impose significant new conditions on receiving U.S. foreign assistance. These rules, collectively known as the Promoting Human Flourishing in Foreign Assistance (PHFFA) policy, take effect February 26, 2026. The PHFFA policy includes: 1) Protecting Life in Foreign Assistance (abortion rule), which expands the Mexico City Policy prohibiting U.S. funds to organizations that perform or advocate for abortion services;1 2) Combating Gender Ideology in Foreign Assistance (gender ideology rule), which prohibits speech and activities the administration characterizes as promoting “gender ideology”;2 and 3) Combating Discriminatory Equity Ideology in Foreign Assistance (DEI rule), which restricts diversity, equity, and inclusion speech and programming.3
This brief examines all three rules and their implications for lesbian, gay, bisexual, transgender, intersex, and other gender-diverse (LGBTQI+) persons abroad. The rules most directly target transgender, nonbinary, and intersex people. The gender ideology rule explicitly defines transgender identities as an ideology to be combated and prohibits a wide range of activities related to gender identity. The DEI rule’s operative provisions do not explicitly prohibit programming for cisgender lesbian, gay, and bisexual people; nonetheless, the uncertainty created by these rules may lead organizations to curtail LGBTQI+ programming more broadly. The abortion rule, while not directly targeting LGBTQI+ people, has implications for LGBTQI+ individuals who need reproductive health services and for the continuing existence of family planning clinics, which are often the providers of choice for LGBTQI+ people seeking health care.
The reach of these rules extends beyond organizations that have been directly funded by the United States to implement LGBTQI+ programming. Foreign organizations that receive any U.S. funding must comply with the rules across all of their activities, regardless of funding source. An organization that receives U.S. State Department funds for a safe water project, for example, would be prohibited from providing gender-affirming care or using a curriculum that includes the existence of transgender, intersex, and nonbinary people anywhere in the world, even if those programs are funded entirely by other donors. This extraterritorial reach magnifies the rules’ potential impact across the global development and humanitarian landscape.