On September 19, 2025, significant amendments to the (IHR) came into force. Described by the World Health Organization’s Director-General as a “historic opportunity to protect future generations from the impact of epidemics and pandemics, with a commitment to equity and solidarity,” these amendments mark a pivotal moment in global health law. Chief among these amendments is the requirement for all IHR parties to establish or designate a National IHR Authority.
In a recent article published in , Common Law’s Professor Roojin Habibi and her co-author (Senior Legal Advisor, Resolve to Save Lives), examine the promise and the challenges of this new national requirement. While the IHR have long relied on “national focal points” to ensure communication with the WHO, these entities have often lacked the authority, resources, or intersectoral reach to implement the Regulations effectively.
The creation of National IHR Authorities aims to address these gaps by giving States a dedicated entity with sufficient seniority and authority to overcome bureaucratic, political, and jurisdictional barriers that have hampered IHR implementation in the past.
As Professor Habibi’s article emphasizes, the effectiveness of this reform will depend on how States choose to translate the new requirement into their domestic legal frameworks. The amended Regulations leave much flexibility to national governments, recognizing the diversity of constitutional and health system arrangements worldwide. This flexibility, however, brings the risk of uneven implementation. “The idea is solid,” says Professor Habibi, “but the rubber hits the road on details and contextualized approaches to realizing its potential.”
The article calls on WHO, States Parties, and other stakeholders to work together to identify strategies and develop guidance for reviewing existing structures, ensuring complementarity, and granting the new National IHR Authorities sufficient authority to succeed.
This analysis underscores both the potential and the complexity of the IHR amendments, emphasizing that turning legal commitments into practical realities requires political will, institutional innovation, and sustained collaboration at the national and international levels.
As of July 2025, Canada has issued until it completes “the remaining steps of its internal treaty adoption process.” It remains to be seen how Canada will act to implement these new amendments.
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