by Michael Hollister
Exclusive published at Michael Hollister on September 16, 2026
3.488 words * about 18 minutes readingtime
2 government institutions say the exact opposite about the same text. In its own question-and-answer document, the World Health Organization says the amended International Health Regulations give it “no ability to impose any health measure, including lockdowns” – no authority to impose any health measure on a country’s population. The United States Department of Health and Human Services reads the same rules in precisely the opposite way: They would give the WHO the power to order global lockdowns. 2 authorities, 1 set of regulations, contradictory findings. And neither is speaking off the cuff; both are citing a document that has been in force since September 19, 2025.
That divide is the real subject. Those who argue about the WHO’s role in a health emergency almost never argue about the wording itself. They argue about what they have been told the wording says. On 1 side is the image of an organization that can bring states to heel with the stroke of a pen. On the other is the assurance that almost nothing has changed legally. Between them lies the text – and the text can be read.
The sober path through it leads neither through outrage nor reassurance. It begins with the question of what the individual articles actually order, what they recommend, and what they simply do not authorize. Anyone who separates these 3 levels cleanly arrives at a conclusion that serves neither camp. It is more uncomfortable than either.
And the text has already been punctured around the edges: Several States Parties rejected the 2024 amendments, so the earlier versions remain in force for them.
The Question the Text Can Answer
What powers does the WHO actually have in a health emergency – and which powers are falsely attributed to it?
This is not a matter of opinion, but a textual question, and the distinction is decisive. Whether the war in Ukraine violates international law cannot be settled conclusively on paper – competing legal interpretations confront one another, and no outsider can adjudicate them. Whether a set of regulations grants an organization coercive power over populations, by contrast, has a verifiable answer. It is either in the text or it is not. The textual finding can therefore be stated clearly. What must be attributed are not the facts, but the competing interpretations drawn from the same facts – those of the WHO and those of the U.S. government. This discipline is not a formality here. Few subjects are as charged, and few mix so many half-truths into what can be substantiated. That is precisely why only what withstands scrutiny against the wording carries any weight – and what does withstand that scrutiny must be stated plainly, in both directions.
2 instruments are at issue, and public debate constantly confuses them. The first is the International Health Regulations, whose latest amendments were adopted in 2024 and have applied since 2025. The second is the Pandemic Agreement, adopted in May 2025 but still not in force. What 1 permits says nothing about the other. And what they create together is a mechanism subtler than either narrative suggests.
Please log in here to read this analysis.
If you do not yet have a reader account, you can register here free of charge.
Access is activated immediately.
