Project 2025 Tracker / What’s done, what’s next

9. Agency for International Development · Notable

Remove PLGHA exemptions for U.S. NGOs and international organizations

Partially done

261 9. Agency for International Development

“The new pro-life executive order should apply to foreign NGOs, including subgrantees and subcontractors, and remove exemptions for U.S.-based NGOs, public international organizations, and bilateral government-to-government agreements.”

What has happened

  1. Partially done

    Two of the three exemptions the Quote names are gone and the flow-down is universal, but the third is discretionary and subcontractors are not yet reached. State's Protecting Life in Foreign Assistance rule "expands the scope of entities that are required to agree to relevant terms and conditions, beyond foreign NGOs, to include U.S. NGOs, international organizations, and foreign governments and parastatals": United States NGOs must agree not to provide abortion as a method of family planning overseas and to keep physical and financial separation, and international organizations are covered on the same terms as foreign NGOs. Government-to-government agreements are treated differently - a foreign government "may be required" to agree, "[p]ursuant to a Department assessment" - so the bilateral exemption is narrowed rather than removed. Flow-down now "applies to all recipients of foreign assistance who issue sub-awards", unlike earlier iterations, but the corresponding contract clause has not been written and so subcontractors are outside the term.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Every source relied on for this item is on our evidence allowlist and was read; nothing found was off the allowlist or unreadable.

  • EO 14332 grant-process sweep (2026-09-29). Executive Order 14332 (2025-08-07) puts every agency’s funding announcements and discretionary awards under senior-appointee review and a test of the President’s priorities. Under the rule we settled on 2026-09-29, it counts only where an ask’s object is review, clearance or priority-alignment of an agency’s awards. This Quote’s object is the scope of the pro-life policy’s exemptions. Status unchanged.

Action
eliminate
Object
PLGHA exemptions for U.S.-based NGOs, public international organizations, and bilateral agreements
ID
673