I could see an argument for trans women being treated as AMAB men for this policy for sexual history when they were living as men, or perhaps while they still have a penis should be the determinant- the risks under those circumstances would be comparable . But for activity after SRS? The risks at that point are comparable to those of AFAB women, and their sexual history from that point should be judged by those standards.
Though I don’t think the MSM donation ban should exist anyway. Screening for HIV has improved dramatically- the reliability of the tests is much better, and the detection window is much shorter. It’s not 100%, very few medical tests are, but it’s quite good these days. And on the small chance it slips through? Treatment options are far superior. An HIV+ person who is treated by current standards can expect to live pretty much a normal life. It’s not ideal(especially when considering issues of access to treatment), but the consequences of HIV positive blood slipping into the supply are far less severe than they used to be.
I do think the ban was justified in the early days- little was known about how the disease spread except that it was spreading faster among gay men(at the time). But science marches on, and policy should change to reflect that. With the reduction in the chance for HIV+ blood to get into the supply, and the reduction in severity in the event it does, the importance of ensuring we have enough blood supply becomes more significant in the risk-benefit analysis.
It’s time to drop the ban.