Project 2025: what it is and how it targets transgender people

In April 2023, the Heritage Foundation published a 920-page document titled Mandate for Leadership: The Conservative Promise [1]. The document is the central product of Project 2025, a presidential transition plan designed to provide the next Republican president with an operational guide ready for use from day one. More than 100 conservative organizations contributed to its drafting, coordinated by Paul Dans and Steven Groves with the support of over 35 lead authors and hundreds of contributors [1][14]. Almost no Italian-language resource analyzes its contents systematically. This article presents the facts.

What is Project 2025

The Heritage Foundation is a conservative think tank founded in 1973 in Washington, D.C., by Edwin Feulner and Paul Weyrich with an initial funding of $250,000 from Joseph Coors. The first Mandate for Leadership was published in January 1981, on the eve of Ronald Reagan’s presidency, and most of its recommendations were adopted by the Reagan administration. Since then, the Heritage Foundation has produced a new Mandate for each Republican presidential transition.

Project 2025 represents the most ambitious iteration of this model. Established in 2022 under the direction of Paul Dans, with Kevin Roberts as president of the Heritage Foundation, the project is structured around four pillars [1][3].

The four pillars

First: the policy document. The Mandate for Leadership 2025 is a 920-page volume divided into 30 chapters covering every aspect of federal administration, from foreign policy to healthcare, from education to energy [1].

Second: the personnel database. The Heritage Foundation built a database of potential government officials, with the declared goal of reaching 20,000 candidates by 2024. Candidates are evaluated on a series of policy positions, including their agreement with statements such as “life has the right to legal protection from conception to natural death” [3].

Third: the training academy. The Presidential Administration Academy is an online educational system designed to prepare future political appointees to be operational from day one of a conservative administration [3].

Fourth: the 180-day operational plan. Developed by Russell Vought (later appointed director of the Office of Management and Budget in the Trump administration), the plan defines the specific actions each federal agency should take in the first six months of government [1][3].

The organizations involved

Project 2025 reached 100 partner organizations in 2023 [14]. Among the most significant: Alliance Defending Freedom, Family Research Council, America First Legal Foundation, American Legislative Exchange Council, Susan B. Anthony Pro-Life America, Liberty University, Hillsdale College, and the Texas Public Policy Foundation [14]. This is not a document produced by a single organization, but a policy platform shared across the entire spectrum of the American conservative right.

The proposals against trans people

The proposals concerning transgender people cut across the chapters of the Mandate for Leadership. They are not confined to a specific section: they appear in the recommendations for the Department of Health, the Department of Defense, the Department of Education, the Department of Justice, and other federal agencies [1][2][3].

Legal redefinition of sex

The document proposes redefining sex at the federal level as a binary and immutable characteristic, determined at conception [1][4]. This redefinition would apply to “every regulation, contract, grant, and piece of federal legislation” [3]. The stated objective is to eliminate the terms “gender identity” and “sexual orientation” from the entire body of federal law [2][3].

The Center for American Progress observed that a definition of gender based not on self-determination but on factors such as reproductive anatomy and birth certificates inevitably entails increased surveillance of every citizen’s gender, not just trans people’s [4].

Elimination of anti-discrimination protections

The Mandate for Leadership explicitly proposes removing the terms “sexual orientation,” “gender identity,” “diversity,” “equity,” and “inclusion” from all federal regulations [1][2][3]. This would reverse the interpretation of the Bostock v. Clayton County (2020) ruling, in which the Supreme Court had established that Title VII of the Civil Rights Act of 1964 protects workers from discrimination based on gender identity.

Ban on gender-affirming care

The document recommends that the Centers for Medicare and Medicaid Services “recognize that there is insufficient scientific evidence to support” coverage of gender-affirming care [2]. It proposes banning such care for minors and cutting all federal funding designated for these treatments. The Heritage Foundation has subsequently advocated for extending the ban to adults as well [2].

Exclusion from the military

The chapter dedicated to the Department of Defense states that “gender dysphoria is incompatible with the requirements of military service” and proposes banning trans people from serving in the armed forces [1][2].

Restrictions in shelters, prisons, and sex-separated spaces

The document recommends that all federally sex-separated spaces — including women’s prisons, shelters for victims of violence, and temporary housing — be assigned based on sex assigned at birth, not gender identity [1][5].

Schools and Title IX

Regarding education, the Mandate proposes redefining Title IX to exclude trans people from protections against school discrimination, banning trans female students from participating in women’s sports, and preventing school staff from using names and pronouns that do not match the student’s birth certificate without written parental consent [1][3].

Equating with pornographic content

In the document’s foreword, Heritage Foundation President Kevin Roberts writes that “pornography, manifested today in the omnipresent propagation of transgender ideology and the sexualization of children,” should be outlawed [1][12]. The text goes on to state that “the people who produce and distribute it should be imprisoned” and that “educators and public librarians who purvey it should be classed as registered sex offenders” [1][12]. Scholar CQ Quinan of the University of Melbourne analyzed this language in a peer-reviewed article published in Crime, Media, Culture, concluding that Project 2025 marks a shift from criminalization to erasure — the systematic cancellation — of trans people from public life [12].

From document to reality: what has already been implemented

Project 2025 was published in April 2023 as a policy proposal. Donald Trump, during the 2024 campaign, distanced himself from the document. But the facts tell a different story.

As of February 2026, according to the PBS and Center for Progressive Reform tracker, the Trump administration had initiated or completed 53 percent of the domestic policies recommended by the Mandate for Leadership in the twelve months following inauguration [8]. Four days after the start of the second term, a Time analysis found that nearly two-thirds of Trump’s executive actions “mirror or partially mirror” Project 2025 proposals [8].

Here are the measures already enacted that directly affect trans people.

Executive Order 14168

On January 20, 2025, inauguration day, Trump signed Executive Order 14168, titled “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” [5][6]. The order establishes that the federal government recognizes exclusively two sexes, defined as immutable and determined at conception — exactly the formulation proposed by the Mandate for Leadership [5][6].

The order’s provisions include: replacing the term “gender” with “sex” in all federal documents; requiring federal identity documents to reflect the sex assigned at birth; eliminating the “X” marker from passports; cutting all federal funding for gender-affirming care; and assigning sex-separated spaces based on biological sex [5][6].

According to the Williams Institute at UCLA, the order has a potential impact on 1.6 million transgender people and 1.2 million nonbinary adults in the United States [7]. In the hours following the signing, the administration removed LGBTQ+ resources from government websites [6].

The military service ban

On January 27, 2025, Trump signed Executive Order 14183, “Prioritizing Military Excellence and Readiness,” which bans trans people from serving in the military [9]. The order states that identifying with a gender different from the sex assigned at birth “conflicts with a soldier’s commitment to an honorable, truthful, and disciplined lifestyle” [9].

On February 10, 2025, Secretary of Defense Pete Hegseth ordered an immediate halt to the enlistment of people with “a history of gender dysphoria” and initiated discharge procedures for trans service members [9]. The discharge code assigned is “JDK,” typically used to indicate a national security threat, with potential consequences for obtaining future employment or security clearances [9].

A federal court initially blocked the order on March 18, 2025, but the Supreme Court reversed the decision in May 2025, allowing enforcement of the ban while judicial proceedings continued [9].

Passports and documents

The “X” gender marker, introduced in 2022 for nonbinary people, was eliminated from U.S. passports. The new policy requires passports to reflect the sex assigned at birth [10]. In November 2025, the Supreme Court allowed the administration to enforce this restriction while legal cases continued, with a majority vote [10].

People who already hold passports with updated markers can continue to use them until expiration, after which they will be subject to the new policy [10].

Healthcare funding

Executive Order 14168 cut federal funding for gender-affirming care [5]. In March 2025, in the case PFLAG v. Trump, a federal court in Maryland issued a preliminary injunction preventing the government from revoking funding to hospitals that provide gender-affirming care to people under 19. The injunction is temporary and subject to appeal.

The organizations behind the project

Project 2025 is not the product of a single think tank. It is the result of a structured coalition of organizations that share a common agenda on abortion, LGBTQ+ rights, and the role of the federal government.

Heritage Foundation

Founded in 1973, the Heritage Foundation is the most influential conservative think tank in the United States. It has played a decisive role in the policies of the Reagan, Bush, and Trump administrations. Its annual budget exceeds $100 million. Under the presidency of Kevin Roberts, assumed in 2021, the foundation shifted its axis toward social conservatism and Christian nationalism [1].

Alliance Defending Freedom (ADF)

ADF is a conservative legal organization with an annual budget exceeding $100 million [11]. The Southern Poverty Law Center (SPLC) has classified it as an anti-LGBTQ+ hate group since 2016 [15]. Among the reasons for the designation: supporting laws that required forced sterilization of trans people in Europe as a condition for legal recognition of their gender identity [15].

ADF has an international structure with five offices in Europe: London, Vienna (at the OSCE), Geneva (at the United Nations), Strasbourg (at the European Court of Human Rights), and Brussels (at EU institutions) [11]. According to an analysis by Corporate Europe Observatory, ADF uses international litigation to influence European jurisprudence and protect its advances in the United States [11].

The Servant Foundation donated over $50 million to ADF between 2018 and 2020 [15]. Other funders include the Green family (owners of Hobby Lobby), the Edgar and Elsa Prince Foundation, the Richard and Helen DeVos Foundation, and the Bradley Foundation.

Family Research Council (FRC)

The Family Research Council is also classified as an anti-LGBTQ+ hate group by the SPLC. Founded in 1981, the FRC has historically promoted positions opposing LGBTQ+ rights and abortion rights. Its participation in Project 2025 confirms the alignment between the anti-abortion and anti-trans agendas within the American conservative movement.

The funding network

The organizations involved in Project 2025 share a network of common funders that includes family foundations and funds linked to the energy and manufacturing sectors. The overlap between the funding networks of the anti-abortion agenda and those of the anti-trans agenda is documented and structural, not coincidental.

The impact beyond the United States

Project 2025 is a U.S. domestic policy document. But its language, rhetorical strategies, and organizational networks have an impact that extends beyond national borders.

Transatlantic networks

ADF International has operated in Europe since 2010 [11]. It has sponsored dozens of cases before the European Court of Human Rights, including cases that would have required trans people to undergo gender reassignment surgery to obtain legal recognition of their identity [15]. Its stated objective is to influence European jurisprudence to consolidate its advances in the United States [11].

A 2021 European Parliament report documented disinformation campaigns targeting LGBTQ+ people in the European Union and the external influences fueling them. The TGEU (Transgender Europe) Trans Rights Index 2025 recorded, for the first time in thirteen years, more regressions than advances in trans rights in Europe.

The Italian case

A comparative study published by Springer Nature in 2024 analyzed anti-gender narratives in Italy, the United Kingdom, and the United States, identifying significant convergences in the language and discursive strategies used by anti-trans movements in the three countries [13]. In Italy, organizations such as Pro Vita e Famiglia have adopted a vocabulary that mirrors that of the Mandate for Leadership, speaking of “gender ideology,” “protection of minors,” and “biological truth” [13].

The DDL Disforia (DDL 2575), approved by the Italian Council of Ministers in August 2025, introduces restrictions on access to gender-affirming care for minors through a series of additional bureaucratic steps. Although the Italian legislative context is profoundly different from the American one, the direction of travel presents analogies: greater state control over transition pathways, emphasis on “protection of minors” as justification for restricting rights, and the use of language that presents trans identity as a phenomenon to defend against rather than a reality to protect.

The British model

In the United Kingdom, the Cass Review of 2024 led to the closure of the Tavistock Gender Identity Development Service and a revision of guidelines for minors. The SPLC documented that ADF activated its British networks to support restrictive policies on access to care for trans minors. The result is an international convergence in which documents and strategies originating in the United States are adapted to local contexts while maintaining the same argumentative framework.

The picture that emerges

The data allow us to trace a precise chronology. In April 2023, the Mandate for Leadership was published with a detailed program of over 920 pages [1]. In November 2024, Donald Trump won the presidential election. On January 20, 2025, inauguration day, Executive Order 14168 was signed, implementing the central proposal of the document: the federal redefinition of sex as binary and immutable [5]. In the following months, the military service ban for trans people was enacted [9], the X marker was eliminated from passports [10], and healthcare funding was cut [5]. As of February 2026, 53 percent of Project 2025’s domestic policies had been initiated or completed [8].

The document is no longer a proposal. It is a governing program in the process of being implemented, supported by a coalition of over 100 organizations with operational networks in Europe and with a documented impact on the legislation of other countries. The sources are public. The data are verifiable. The reader can draw their own conclusions.