Functioning of the International Health Regulations During the COVID-19 Pandemic

The International Health Regulations (IHR), which entered into force in 2007, were designed to strengthen global capacity to prevent, detect, and respond to public health threats. Framed as a legally binding agreement among the World Health Organization (WHO) Member States, the IHR aims to support national preparedness while enabling coordinated international alert and response to health emergencies.

During the prolonged and unprecedented COVID-19 pandemic, the effectiveness of the IHR has been widely questioned. Critics argued that the Regulations constrained rapid action and failed to keep pace with the scale and speed of the crisis. However, findings from the Review Committee on the Functioning of the IHR (2005) during the COVID-19 Response offer a more nuanced assessment, shifting the focus from regulatory design to implementation failures.

This article reflects on those findings and the implications for strengthening global health governance, drawing on the work of the IHR Review Committee, which brought together 20 experts with diverse public health expertise from around the world.

International Health Regulations and COVID-19: What Went Wrong in Practice

The IHR Review Committee found that the Regulations themselves remain fundamentally sound and appropriate for managing public health emergencies. Rather than structural deficiencies within the IHR, the COVID-19 response revealed persistent shortcomings in how the Regulations were applied by Member States and operationalized by the WHO.

Many countries implemented the IHR only partially, lacked sufficient awareness of their obligations, or chose to disregard specific requirements. At the same time, the WHO did not consistently make full use of the authority granted under the IHR, both in letter and in spirit. These combined gaps significantly weakened the global response during the early and most critical phases of the pandemic.

Within its mandate, explicitly focused on IHR-related aspects of the COVID-19 response, the Review Committee identified a collective failure across three interrelated domains:

Compliance, Accountability, and Empowerment

Inadequate compliance with IHR obligations, particularly those related to preparedness and core public health capacities, contributed to COVID-19 evolving into a protracted global crisis. The Committee underscored that IHR implementation must be elevated to the highest levels of government and embedded within a whole-of-government approach to health security.

Central to this effort is the strengthening of IHR national focal points. These entities must be institutionally positioned, adequately resourced, and granted sufficient authority to engage across sectors during emergencies. Without robust national legal frameworks aligned with the IHR, effective preparedness and response remain out of reach.

To address persistent gaps, the Committee highlighted the need for stronger review and accountability mechanisms. Periodic, obligatory assessments of national IHR capacities, similar in spirit to universal periodic reviews in other international governance frameworks, could play a critical role in improving compliance and transparency.

Early Alert, Notification, and Response

Timely alert and response are essential to triggering meaningful global action. Yet during COVID-19, early warning systems did not function as intended. Initial reporting from several countries was incomplete, and delays in recognizing human-to-human transmission, including asymptomatic and pre-symptomatic spread, undermined early containment efforts.

Despite the WHO issuing risk assessments, technical guidance, and early warnings, including the declaration of a Public Health Emergency of International Concern, many national responses were slow or insufficient. The Review Committee concluded that introducing additional alert levels would not have resolved these challenges. Instead, more consistent adherence to existing IHR obligations could have enabled faster, more decisive action.

The Committee also emphasized that trust, collaboration, and routine engagement between countries and the WHO, outside crisis periods, are essential to improving early alert and response. Strengthening established networks and information-sharing mechanisms remains a priority.

Political Will and Sustainable Financing

Effective implementation of the International Health Regulations depends on sustained political commitment and predictable financing at national and international levels. The Review Committee noted that resources allocated to IHR implementation, including within the WHO itself, remain limited and inconsistent.

As of early 2021, the WHO’s IHR-related functions were supported by approximately 200 full-time staff equivalents, fewer than the staffing levels of some national public health institutes. This imbalance highlights the need for Member States to provide the WHO with a stronger mandate and more stable funding to fulfil its global health protection role.

Strengthening the IHR for Future Health Emergencies

In April 2021, the Review Committee issued 40 recommendations across ten thematic areas to strengthen IHR implementation. These include enhancing legal preparedness, improving data sharing and risk assessment, clarifying responsibilities related to travel measures, advancing digitalization and communication, and reinforcing compliance and accountability frameworks.

The Committee also recognized the potential value of developing a global, legally binding convention on pandemic preparedness and response. Such a framework could complement the IHR by addressing gaps related to equitable access to countermeasures, global supply chains, and the management of zoonotic risks.

Moving from Lessons to Action

The COVID-19 pandemic demonstrated that global health security is only as strong as the collective commitment to uphold shared rules and responsibilities. The functioning of the International Health Regulations during the COVID-19 pandemic shows that the challenge lies not in the absence of guidance but in the failure to fully implement what is already agreed upon.

The evidence is clear, the recommendations are well established, and the path forward is known. What is now required is decisive action by Member States and by the WHO to translate the lessons of COVID-19 into a more resilient, accountable, and effective global health system.