The gendered leagues exist to promote women in chess. They need to do this because women have historically been discriminated against. These new rules feel like they are asking trans women to prove they are oppressed enough to deserve to play in women’s leagues.

Some of the requirements for the change in status is problematic as well.

the National Rating Officer should require from the player sufficient proof of a gender change that complies with their national laws and regulations.

That is a hard requirement to meet in large chunks of the world. Many countries don’t legally recognize gender change so it may be quite literally impossible to comply with “national laws and regulations.” There’s some carve out for asylum and refugee status. But it is possible to be a trans woman in a country, not be able to legally change your gender, and not feel unsafe enough to seek asylum.

I’m reading more on the titles now. So from the actual FIDE document:

If a player holds any of the women titles, but the gender has been changed to a man, the women titles are to be abolished. Those can be renewed if the person changes the gender back to a woman and can prove the ownership of the respective FIDE ID that holds the title. The abolished women title may be transferred into a general title of the same or lower level (e.g., WGM may be transferred into FM, WIM into CM, etc.).

And from what [FIDE titles]https://en.m.wikipedia.org/wiki/FIDE_titles) are on Wikipedia. It seems there is an underlying misogyny in how women’s titles work. It seems to me the proper solution is to get rid of the separate title requirements.