What you should know about the new State Department rules (PHFFA)

Plus some helpful charts and a "cheat sheet" summary attached below

FEBRUARY 12, 2026

We recently had the privilege of hosting two conversations with some of the leading NGOs and companies working in international development to discuss the State Department’s new rules — Promoting Human Flourishing in Foreign Assistance (PHFFA) — that expand restrictions on foreign assistance funds related to abortion, gender, and equity. Across both events, a few themes stood out: compliance is getting more complex, documentation matters more than ever, and legal strategy can no longer be reactive; it must be anticipatory.

As the new rules themselves contemplate, this will create one-time and recurring compliance costs and obligations for an estimated 2,500 organizations. Rather than each organization navigating this in isolation, there is real value in comparing approaches and identifying compliance best practices. This includes not only well-drafted board policies, but behavioral and operational protocols like risk checklists and internal escalation channels. 

If you are working through PHFFA compliance — whether as a prime, sub-recipient, contractor, or advisor — we welcome the opportunity to exchange perspectives. Periods of regulatory change are easier to manage when

we learn from one another.

Here are some practical charts and a "cheat sheet" summary of the rules to help organizations navigate risk, strengthen internal systems, and position themselves for long-term resilience in an era of heightened scrutiny and uncertainty.

Mission Driven Counsel PHFFA Diagrams White Background.pdf

Download PDF • 189KB

Mission Driven Counsel PHFFA Summary 2.12.26.pdf

Download PDF • 216KB