Even before the Trump administration rolled out a new rule that undercuts global efforts to protect women in conflict and promote their participation in peace processes, UN work in this space was under assault. U.S. aid cuts have exacerbated a budget crunch at the UN, and programs promoting the wellbeing of women and girls are among the hardest hit. Members of the Trump administration, moreover, have throughout their first thirteen months in office expressed scepticism about aspects of the UN’s Women, Peace and Security (WPS) agenda, which links efforts to pursue gender equality with international peace and security.

The pressure on UN programming is about to intensify. On 23 January, the U.S. introduced a foreign assistance policy that threatens the UN’s work on gender issues, with potential ramifications not just for its peace and security efforts, but humanitarian and development work more broadly. At the March for Life (an annual anti-abortion gathering in Washington), Vice President JD Vance announced the “Promoting Human Flourishing in Foreign Assistance Policy”, comprising three separate rules on “protecting life”, “combating gender ideology” and “combating discriminatory equity ideology”. This policy aims to ensure that foreign aid aligns with administration policy “opposing gender ideology, discriminatory equity ideology, unlawful diversity, equity and inclusion (DEI) programs, and abortion as a method of family planning overseas”. The administration made clear that the policy “restricts activities funded by other sources” in order to achieve this goal. 

As a result, many recipients of U.S. non-military assistance will be unable to use U.S. funds, or any funds received from other donors, for work that contradicts the Trump administration’s positions on gender. Non-compliance with the rule – which went into effect on 26 February – can lead to withdrawal of funding and a requirement to pay already spent funds back to the U.S.

The new rule is a major expansion of the so-called U.S. Mexico City policy, which President Ronald Reagan’s administration introduced in 1984. The Mexico City policy (which was first announced in Mexico’s capital, hence the name) prohibited foreign NGOs from using U.S. family planning funding to support abortion-related activity. Every subsequent Republican administration has instituted the rule, while Democratic presidents have lifted it. In practice, as Crisis Group highlighted in March 2025, Mexico City functioned as a “gag” rule and prevented grantees from speaking about sexual and reproductive health issues. Under Trump’s first presidency, the rule was expanded from family planning assistance to most health assistance provided to foreign NGOs. As further broadened by the current Trump administration, the rule would potentially apply to nearly $40 billion of U.S. aid. Another consequential change is that in its new form the rule will, for the first time, apply to voluntary contributions to multilateral organisations, foreign governments and U.S. NGOs – as well as to foreign NGOs.

The human flourishing policy is aimed at shaping a large proportion of non-military foreign assistance to conform to Trump administration positions on gender and family planning. The policy’s vagueness makes it difficult to know exactly which UN entities and programs will be affected. But stances the Trump administration has adopted within the U.S. and at the UN provide clues. For example, programs that support transition procedures that reflect a person’s transgender identity appear to be in the administration’s sights. The policy’s definition of “gender ideology” takes issue with work that separates gender and sex as distinct categories or informs or advocates for the accessibility of what it calls “sex-rejecting procedures” (referred to by non-sceptics as “gender-affirming care”). Advocacy for special protections or status for people based on their gender identity is also prohibited, though no examples are given of what constitutes advocacy or what kinds of special protections would violate the rule. Statements made by the U.S. at the UN in 2025 suggest that the restrictions will be applied broadly, as U.S. officials have already used the term “gender ideology” as a derogatory label for gender-related concepts they do not agree with in UN texts.

The human flourishing policy also reflects the administration’s animosity toward DEI initiatives. The policy’s repudiation of “discriminatory equity ideology” takes issue with the idea that people can be “members of preferred or disfavoured groups” and that “an individual’s moral character or status as privileged, oppressing, or oppressed is primarily determined by the individual’s race, color, religion, sex or national origin”. The rule also requires that recipients understand U.S. law sufficiently to avoid “unlawful DEI-related discrimination”. These formulations are consistent with Trump administration positions already taken by the U.S. at the UN, where U.S. diplomats have specified that the U.S. cannot agree to “quotas, targets or goals for participation based on sex”, while categorising gender equality and DEI as “radical causes” that do not help women and girls.

With regard to abortion, the new rule takes a similar stance to the Mexico City policy in that it prohibits “abortion as a method of family planning” (considered to be an abortion for any reason other than rape, incest or to save the life of the woman). The new policy, however, also bans medical providers receiving U.S. assistance from giving patients who had decided to have an abortion contact information for safe and legal abortion services, unless local law mandates such information be provided. Previous iterations of the Mexico City policy permitted these so-called “passive referrals”.

Unlike regular earmarking, which allows countries to commit their voluntary funds to specific UN entities or programs, the human flourishing policy requires that any UN entity (or other multilateral institution) that receives U.S. voluntary contributions commit not to use any funds – whether contributed by the U.S. or any other donor – for activity that violates the rule.

The rule has strict and time-consuming compliance requirements. As in past iterations of the Mexico City policy, officials from recipient organisations must conduct verification in person, which generally requires travel to the site of activities, an often expensive and risky endeavour in conflict settings. In many cases, rather than carry out these burdensome processes, aid recipients under the former Mexico City framework pre-emptively ended collaborations with smaller organisations operating on the ground to ensure they would not be deemed non-compliant. The human flourishing policy’s vague definitions will most likely exacerbate such compliance concerns. UN officials and NGO practitioners worry there will be variation among U.S. embassies and even individual officials in terms of what is considered a violation of the new rule. Some believe the variation will cause confusion and inconsistency, allowing U.S. officials to use the threat of investigation as a bargaining chip to push other priorities with recipients.

Exemptions to the human flourishing policy will likely be difficult to obtain. Guidance issued on 26 February specifies that the U.S. Department of State is open to giving waivers to organisations that provide “critical emergency relief or operate in time sensitive and disaster and crisis zones” as long as these groups are “making a good faith effort to comply with the policy as a whole”. At the same time, the guidance warns the standard for waiver approval will be “high” and only possible in “narrow circumstances”. Successful applications, moreover, will have to show that a waiver is necessary to serve the foreign policy of the U.S. This gives the administration vast discretion. The implementation of the Mexico City policy under the first Trump administration suggests the waiver procedure will be used quite sparingly if at all: only two applications were submitted to the State Department and neither was approved, for reasons the department did not disclose. 

The way the Trump administration is applying this policy to the UN indicates a desire to steer the organisation’s approach to gender. As mentioned above, under previous Republican administrations, the U.S. did not extend the Mexico City policy to funds it gave to multilateral institutions, although some administrations looked to the 1985 Kemp-Kasten amendment (legislation which prohibited funding for what it termed “coercive abortion”) as reason to block funding to the UN Population Fund (UNFPA). Even before it announced the human flourishing rule, the Trump administration had zeroed out contributions to entities such as UNFPA and UN Women. But by making voluntary U.S. funding to the UN subject to the human flourishing policy, it has gone a step further, because of the way in which the new rule restricts what UN agencies can do with other countries’ funding if they are also taking money from the U.S. 

The administration issued different compliance requirements for the UN than for countries and U.S. NGOs receiving aid. Bilateral aid recipients can comply with the rule by keeping U.S. funds separate from other countries’ donations. That way U.S. monies are not used for programs with which the administration disagrees. U.S. NGOs not only have to keep U.S. donations financially separate but also must ensure physical separation between services deemed acceptable under the rule and those that contradict it. (For example, a clinic that provides abortions would be expected to offer different “entrances, waiting rooms, [and] exam rooms” for services funded with U.S. monies.) Multilateral institutions are placed in a different category: they do not have the option of complying with the rule by keeping U.S. funding in a separate financial accounts or offering services in physically separate spaces. The different rules for compliance would seem to indicate the administration hoped to shape a broad swathe of multilateral institutions’ programs. 

The human flourishing rule could affect the UN’s efforts in conflict and crisis settings. For example, work mandated by the Security Council to support the survivors of sexual violence may run into challenges. Consider the UN peacekeeping mission in the Central African Republic, which coordinates with other UN entities to air-lift post-rape kits to local clinics working with survivors in remote areas. These kits – which are essential to preventing illness, treating rape-related injuries, and providing emergency contraception – must be administered in the first 72 hours after the rape occurs. To be clear, by itself distributing rape kits would be permissible under the rule. But in the words of a UN official, it would be “extremely difficult – basically impossible” to be absolutely sure that partner UN entities and local clinics did not provide services outside of rape kit distribution that could run afoul of the rule, particularly in a time-sensitive conflict setting. As a result, UN officials could decide against coordinating with these entities out of an abundance of caution and essential care could be withheld from those who need it.

UN programs to bolster women’s participation in peacebuilding and politics – also mandated by the Security Council under resolution 1325, subsequent WPS resolutions and political mission mandates – could also be affected by the human flourishing policy. The UN Department of Political and Peacekeeping Affairs (DPPA) promotes women’s participation through gender advisors to political missions, experts embedded in UN country teams, and advocacy and training on inclusive mediation. UN officials pointed out to Crisis Group that the U.S. policy – with its goal of “combating discriminatory equity ideology” – could be seen as incompatible with programs that single out women for tailored support. In 2024, the U.S. was among the lowest contributors of voluntary funds to DPPA, at around $100,000 – compared to the Republic of Korea at $3.5 million and Denmark at $2.4 million. But even if the U.S. were to continue its fractional voluntary assistance in the coming year, the Trump administration would presumably expect the organisation to comply with the priorities it lays out under the human flourishing policy.

Other parts of the UN’s gender equality work in crisis contexts could also be affected. The UN Refugee Agency (UNHCR), to which the U.S. has historically been the largest donor, has dedicated capacity to serving LGBTQI+ individuals who have become refugees in the context of conflict and other crises; its support includes providing safe housing and helping vulnerable individuals avail themselves of legal protections. But the U.S. could understand such UNHCR programs to be “encouraging a foreign government to provide special legal status or protections based on gender identity” in a way that violates the new U.S. policy. LGBTQI+ activists and UN officials told Crisis Group they fear this will mean that support for LGBTQI+ refugees will be terminated if UNHCR receives U.S. voluntary funds as it has in the past.

Then there is the $2 billion pledge that the U.S. committed to the Office for the Coordination of Humanitarian Affairs (OCHA) at the end of December – the Trump administration’s largest contribution of voluntary funding to the UN since its return to office in 2025. Absent a waiver (something that OCHA’s leadership has pushed for) the agency would face challenges, in part because the majority of this money is to be allocated to other UN entities, all of which would have to comply with the rule. Some of these monies would go to pooled funds, for example the Regional Humanitarian Pooled Fund for Latin America and the Caribbean – which the U.S. will fund for its work on Haiti, Colombia, El Salvador, Honduras and Guatemala. As discussed above, it can be difficult for UN entities to monitor operations and the actions of other recipient organisations working on the ground. As a result, staffers at agencies that receive U.S. funds may err on the side of caution and refrain from such partnerships to avoid running afoul of the rule. 

Apart from the substance of the UN’s work, the organisation will have to consider the practicalities of compliance with the human flourishing policy internally. For example, the U.S. could use the rule’s prohibition of DEI efforts as a pretext for discouraging hiring by UN entities under the Secretary-General’s organisation-wide gender parity guidance. The Trump administration could also challenge guidance that aims to bolster recruiting from under-represented countries to the UN entities affected by the rule. Measures that aim to enable a supportive work environment for staff of diverse identities, such as the UN guidelines on gender-inclusive language (which explicitly state that gender and sex are distinct categories) could also come under U.S. scrutiny.

The rule will inevitably sit poorly with donors that have made voluntary contributions to support women in peacekeeping and peacebuilding, protection of LGBTQI+ populations, and women and girls’ access to health care. On 2 March, ten countries – including France, the UK, Germany, South Africa and Sweden – released a letter pointing out the rule could end up “constraining the delivery of essential health and social services” as well as “undermin[e] gender equality and the full enjoyment of human rights of all women, girls and adolescents, as well as LGBTQI+ persons worldwide”. But whether countries will work collectively at the UN to take action against a rule promulgated by a U.S. administration that can be vengeful in response to critics is an open question.

The U.S.’ use of funding restrictions to attempt to govern how other states spend their money sets a troubling precedent – one that Washington could use to engineer UN programming in other areas, and other states could attempt to adopt for their own purposes. Given the UN leadership is dealing with a financial crisis and organisation-wide restructuring, they may find it tempting to wait to react to the human flourishing policy at a later date. But a more proactive approach may be required to keep UN agencies from accepting funds that could wind up doing more harm than good, and to keep the precedent from crystallising.

To this end, UN entities should conduct a systematic assessment of how the human flourishing rule could affect three areas. The first is the UN’s work on gender issues, including both the effects of the rule on vulnerable populations such as women and girls in conflict, and the incompatibility between the human flourishing policy and norms and principles that have been agreed to in the Security Council and General Assembly. The other two issues relate to internal UN procedure: hiring and employment practices with which the policy could interfere, and compliance costs – ie, the time that personnel would spend dealing with red tape imposed by the U.S. rule. Such an assessment could be coordinated by the Secretary-General’s Executive Committee, and the results shared with the entire UN membership, given that roll-out of the human flourishing policy at the UN would affect the use of all member states’ funds. Such an assessment would at the least serve an important purpose in raising awareness with respect to the U.S. policy, and could also provide a basis for rallying support for steps to lessen the impact – including, potentially, decisions by UN agencies to foreswear U.S. support in cases where the damage of taking it would outweigh the benefits.

Meanwhile, member states supportive of the WPS agenda and concerned about interference with the use of UN contributions should press the UN to conduct such an assessment, and continue to look for ways in which they can push back against the U.S. on this issue. In 2025, the U.S. did not always hold fast on its anti-gender equality positions at the UN. For example, when negotiating the mandate renewal for the South Sudan peacekeeping mission (UNMISS), the U.S. – which held the pen – yielded to other Security Council members’ demands that existing programs serving women and girls be protected. Carefully chosen battles in which member states work together to challenge U.S. positions may help reveal where U.S. diplomats have discretion concerning the policy’s application, including with respect to its waiver policy.

These steps are well worth taking: finding ways to limit the Trump administration’s efforts to shape the UN’s programs on gender could have major consequences for the organisation’s ability to protect and promote the equality of women and girls around the world.