Gender identity and gender expression are embedded in the Gender Equality Act in the concept of gender. This is done by stating that the prohibition to discriminate on the basis of gender covers also discrimination of the basis of gender identity or gender expression. People with intersex conditions are also covered. The prohibition to discriminate includes both public and private services, education and employment and even labour unions. So it covers e.g. health care, restaurants, primary schools and universities etc.
The Act obliges central and local governments, education providers and employers to work pre-emptively against discrimination on the basis of gender identity or gender expression. It is not enough to wait until there is an identified risk e.g. because of someone has come out as trans.
The public sector, education providers and employer, have an obligation to promote gender equality by proactive measures and systematic planning. After the reform this must include the prevention of discrimination also on the basis of gender identity and gender expression.