IIRC gender reassignment in the equality act protects anyone who has stated an intent to transition, regardless of if they've done any medical stuff, that's what the "proposing to undergo" bit means (good tbc, people who don't do any medical stuff should be protected)

"you can discriminate anyone based on vibes" is not the already unreasonable exception to human rights the interim guidance was, while still pretending to comply

it's straight up declaring the framework of universal human rights is no longer part of the law at all