While DNDi welcomes continued efforts to finalize the WHO Pathogen Access and Benefit-Sharing (PABS) system, it is clear that significant technical and political challenges remain.

Access to pathogens, materials, and data should be contingent on clear, enforceable, and transparent benefit-sharing terms agreed upfront.

While the latest draft introduces a differentiated contractual approach across user groups, the core requirement should be consistent: all users—commercial and non-commercial—must be subject to proportionate, enforceable obligations. This includes minimum benefit-sharing requirements for manufacturers (such as monetary contributions, non-exclusive licensing, and technology transfer), as well as traceability, compliance upon commercialization, and reporting obligations for other participants. Experience in other areas including our own shows that it is possible to create core conditions with appropriate flexibility to address different R&D and access stages and circumstances.

Member States and the PABS system should also ensure public access to information on recipients of PABS materials and data, the agreements concluded with manufacturers and others, and relevant regulatory approvals. Strengthening both enforceability and transparency will be essential for equity.