Summary | He whakarāpopototanga

An overview | He tirohanga whānui

What have we learned from the COVID-19 pandemic, and the response to it, that can help us prepare for other pandemics in future? While our health system and economy may have come through the pandemic better than expected, and New Zealand recorded lower case numbers and fewer deaths per capita than other comparable countries, our society is still counting the cost of the pandemic and the response.

Phase One of the Royal Commission of Inquiry into COVID-19 provided its report in November 2024. It looked at seven broad areas of New Zealand's response to the pandemic, including border restrictions, the use of mandatory public health measures, efforts to keep the health system going, management of the economy, the use of vaccinations and more. That report contained six lessons and 39 recommendations.²

This second phase of the Royal Commission of Inquiry was established by the Government in December 2022³ to identify further lessons from the COVID-19 pandemic response. This followed public concerns about transparency and whether the first phase of the Inquiry had addressed some important issues, such as the adequacy of processes used to assess and monitor vaccine safety. This report sets out four broad future-focused lessons, along with 24 recommendations to give them practical effect.

Reflecting the Government's new terms of reference for this phase,⁴ our work has focused on the key decisions made by the Government in four main areas of the pandemic response over 2021 and 2022:

• vaccine approval and safety
• vaccine mandates, including the introduction of the Vaccination Assessment Tool and vaccine passes
• national and regional lockdowns, and
• the procurement, development and distribution of testing and tracing⁵ technologies.

These key decisions involved some very significant and far-reaching uses of government power to limit the ability of New Zealanders to move about freely, meet with others, and to attend public events, weddings, funerals, tangihanga, places of work and worship, for example. They required some New Zealanders to be vaccinated in order to keep working in their chosen professions. They also governed the approval and monitoring of a new vaccine, which had been developed at unprecedented pace. The decisions had major effects and deserve thorough review.

Phase Two | Wāhanga Tuarua

The scope of Phase Two is more narrowly focused than Phase One. We have been asked to analyse the period from February 2021 to October 2022.⁶ At the beginning of this period, New Zealand was following an elimination strategy: managing every case of COVID-19 with stringent measures such as lockdowns, border closures, social distancing, restrictions on gatherings and travel, contact tracing, testing and more.

Decision-makers expected that the more stringent restrictions would no longer be required once there was a sufficiently vaccinated population. International efforts to develop safe and effective vaccines for COVID-19 had been moving at unprecedented speed.⁷ Cabinet was advised that vaccination was a critical platform for reopening borders and leaving lockdowns, and could be the only way to bring the pandemic to an end.⁸ Officials had advised Ministers that vaccines could reduce the severity of illness, prevent the pandemic overwhelming the health system, reduce transmission rates and so reduce the need for 'blunt tools like border controls and lockdowns'.⁹

The vaccine strategy aimed to obtain a sufficient quantity of a safe and effective vaccine at an affordable cost as a way out of the pandemic. This was appropriate and consistent with the vast majority of scientific advice. We saw irrefutable international evidence of significant rates of death and serious illness from COVID-19.¹⁰ This evidence led to the New Zealand response recognising that relying largely on natural immunity against the virus would have involved a significant burden of sickness and deaths.¹¹

The elimination strategy came under increasing pressure with the outbreak of a more virulent and transmissible COVID-19 strain, Delta, in August 2021.¹² Later, the Omicron strain created larger waves of infection in 2022.¹³ Decision-making was clearly challenging with a rapidly evolving virus.

For much of 2021, New Zealand relied almost solely on Polymerase Chain Reaction (PCR) testing technology as accuracy was critical to support the elimination strategy. But the requirement for professionals to swab and process tests limited the capacity of the system, which came under pressure and struggled to manage demand during outbreaks, with backlogs and delays. The official PCR testing system was ultimately overwhelmed in early 2022.

Vaccines, lockdowns and growing unease | Ngā kano ārai mate, ngā rāhui, me te māharahara e tipu ake ana

The first COVID-19 vaccines were being rolled out to frontline workers from February 2021, and to the general public from late July, presenting options for the management of the pandemic and new challenges. New Zealand decided early on to rely on the Pfizer/BioNTech COVID-19 vaccine (Comirnaty) as the primary vaccine available in the national immunisation programme.¹⁴ Other vaccines, including the AstraZeneca vaccine (Vaxzevria), the Janssen vaccine (Janssen), and the Novavax vaccine (Nuvaxovid), were introduced later as second-line vaccines, to give people options if they did not want to take the Pfizer vaccine.¹⁵

From August 2021, the Government imposed a series of national and regional lockdowns. Auckland was locked down for more than three months from 17 August to 2 December, as vaccination uptake in some areas was still short of levels the Government considered necessary to manage the outbreak. Widespread, multi-faceted social and economic impacts – some arising from the virus itself and others from the public health measures imposed – were increasingly evident.

Trust in government and support for the pandemic response began to lessen as public fatigue and resentment grew, compounded by the introduction of workplace and occupational vaccination mandates in the second half of 2021.

While the rollout of vaccines decreased the risks COVID-19 posed to vaccinated people, it was becoming much less likely that the virus could be eliminated. In December 2021, New Zealand moved to a minimisation and protection strategy under the COVID-19 Protection Framework.¹⁶ There were no more lockdowns but people who could prove they were vaccinated had significantly greater freedoms than the unvaccinated. Rapid Antigen Tests (RATs) became the primary COVID-19 testing diagnostic tool for most of the population from the end of February 2022.¹⁷

Growing social divisions were highlighted when about 3,000 people occupied Parliament grounds for 23 days in early 2022. The occupation ended in violence on 2 March as people were forced to leave, underlining just how polarising the pandemic response had become.

Our task | Tā mātou mahi

Guided by our terms of reference, we considered the key pandemic response decisions with regard to the circumstances in which they were made, the instruments and policies available, the legal framework and the principles and conventions that applied to Executive decision-making at the time.

The Inquiry held public hearings in July 2025, in which we heard from individuals and organisations about the impacts of the lockdowns, approval and safety processes for vaccines, and the introduction of vaccine mandates. We also met with many business, community and representative groups, received more than 31,000 submissions from individuals and organisations, and obtained about 8,000 relevant documents from government agencies. We held 29 interviews with former ministers and senior public servants about the decisions taken, and a range of specialists and technical experts, to better understand the science and evidence. We are satisfied that we were thoroughly well-informed.

Many of the people we heard from expressed pain and anger about the impacts of the pandemic and response. Some of these impacts on people's lives continue to this day. There are lessons to be learned from their personal experiences. It is clear, however, that ministers and officials were facing a series of complex, high-stakes decisions in a rapidly changing environment and were doing the best they could at the time. Evidence shows New Zealand had among one of the best pandemic responses in the world.

Our assessment of key decisions
Tā mātou aromatawai i ngā whakatau matua

Vaccine safety and approvals | Te haumaru me ngā 
whakaaetanga o ngā kano ārai mate

The Inquiry examined key decisions regarding pre-market approval of COVID-19 vaccines by Medsafe, the approval of vaccine use in the Government's immunisation programme and Ministry of Health decisions on vaccine safety after approval had been granted.

Key decisions on vaccine approvals and monitoring vaccine safety were led out of the Ministry of Health. Many decisions devolved to Medsafe, a business unit of the Ministry of Health.¹⁸ Together, Medsafe and the Ministry of Health sought and followed extensive advice from medical and scientific experts, who closely monitored evolving international experiences of developing, approving and using COVID-19 vaccines.

Decisions carefully balanced the benefits of COVID-19 vaccines for the health and safety of New Zealanders, against any potential risks (all medicines have side effects). At the same time, the Government viewed widespread acceptance and use of vaccines as a key means to exit restrictive public health measures with consequential economic, social and educational benefits. Decision-makers took extensive steps to mitigate risks by strengthening systems for monitoring the safety of vaccines once they were in use. Through that process, they identified and responded to new risks as they emerged, including the rare risk of myocarditis and pericarditis associated with mRNA vaccines.

Decision-makers were fully aware of the need to secure and maintain public acceptance of the vaccine strategy, as the primary tool in responding to the pandemic. However, they did not anticipate the extent to which concerns about vaccine safety would emerge and seize attention. Communications about risks from COVID-19 vaccines were extensive and followed established procedures. Even so, shortfalls in clarity and effectiveness existed in terms of what providers heard about risks and, in turn, communicated to consumers.

Vaccine mandates | Whakature kano ārai mate

In considering the key decisions made in 2021 and 2022 regarding vaccine mandates, we have looked at the introduction and subsequent removal of Government-issued occupational vaccine mandates, the decision to introduce and remove the Vaccination Assessment Tool to facilitate employer-based requirements, and those imposed by the 'vaccine pass' system.

The decisions on vaccine requirements reflected the advice given and paid significant attention to experience in comparable jurisdictions. While advice on the vaccine pass system included an assessment of the potential impacts on social cohesion, the labour market implications could have been explored further.

There was insufficient monitoring of the use and impacts of vaccination requirements, including uptake of the Vaccination Assessment Tool, job losses and reinstatements, and limited enforcement activity. The lack of monitoring meant advice about continuing or removing these mandates was not well-informed by data about the outcomes resulting from various vaccine requirements.

The lack of monitoring has made it difficult to assess the extent to which the impacts of vaccination requirements were 'unforeseen'. The employment and wage scarring effects of occupational mandates were foreseeable and likely to be significant for a small segment of the workforce that declined to comply.

In hindsight, some vaccination requirements were introduced too slowly, some lasted too long and some went too far. The objectives of balancing public health goals and minimising social disruption were sometimes in tension, and ministers and senior advisers had well-founded fears that a lack of sufficiently robust public health measures could lead to considerable disruption due to the widespread transmission of COVID-19. Vaccination requirements enjoyed a very wide measure of support among the population. However, it is clear that vaccination requirements had significant social and economic implications, particularly for those who declined the vaccine.

Vaccination requirements are a valid intervention that should be kept in the toolbox for future pandemic responses. However, the scale of their intrusion on fundamental rights and freedoms, and their potential for severely negative impacts on those who choose not to be vaccinated, means they should be used with great care. Future requirements should be applied with more flexibility, monitored systematically and reviewed frequently against clear criteria. Decisions to end mandates should be actioned quickly, given their impact on individual rights.

Procurement, development and distribution of testing technologies | Te hoko, te whakawhanake me te tohatoha o ngā hangarau whakamātautau

 Here we considered key decisions that affected the ability of private organisations to acquire, develop or distribute testing tools and technologies during 2021 and 2022. We did not consider the procurement, development or distribution of other non-pharmaceutical materials and tracing technologies (such as masks, personal protective equipment or the NZ COVID Tracer app), since the most significant decisions were made before the period Phase Two is concerned with. These matters were addressed in the Phase One report.

Key decisions on testing technologies were well-informed on technical matters, but not on longer-term strategic choices and consequences. In particular, insufficient attention was given in advance to the testing tools and strategies to be applied after the elimination strategy ended. Officials and other commentators foresaw problems and consequences arising from the Government's conservative approach to testing technology and strategy and urged changes, but these calls were either not heeded or were picked up too late.

Ministers and senior officials faced difficult trade-offs in balancing the need for both accurate and accessible tests. However, decisions could have taken more account of experience and developments in comparable jurisdictions, particularly regarding the use of RATs. Although decision-makers sought to minimise disruption by continuing to prioritise the most accurate testing technologies, this decision may have actually increased disruption.

The reliance on PCR testing during much of 2021 reflected expert advice and was consistent with the elimination strategy (which required highly accurate tests to support contact tracing). However, the PCR testing system came under immense strain, to the point where it was overwhelmed in early 2022. The slowness in approving alternatives and allowing firms to import tests themselves meant that, in late 2021 and 2022, some people lacked easy access to a reliable test to help them and their employers to decide on actions such as self-isolation or returning to work.

Lockdowns | Ngā noho rāhui

Our assessment focused on decisions taken in the second half of 2021 which put in place, and maintained, Alert Levels 3 and 4 restrictions. We also considered decisions about the transition to the COVID-19 Protection Framework, as this represented the end of lockdown restrictions in Auckland. We assessed how well decision-makers were informed of potentially negative social and economic impacts and how they struck a reasonable balance with public health goals. We also assessed the advice that decision-makers received on relevant international experiences.

When making key lockdown decisions, decision-makers took into account information from a wide range of sources. As a result, we consider they were sufficiently informed as to the main impacts of their decisions. Their decisions closely followed the public health advice that was given to them, and they took into account the experiences of other comparable countries in an appropriate way. However, they would have benefitted from additional data and information relating to the potential impacts of the choices before them.

The approach to balancing interests was reasonable and evidence-based. Decision-making as circumstances changed was highly complex. By early October 2021 it was apparent to officials and decision-makers that the Auckland outbreak was not going to be eliminated in the near future. Social licence was diminishing. Vaccination rates were increasing. Decision-makers were not prepared for a scenario in which lockdown restrictions did not successfully eliminate the virus and would have benefitted from a clearer and more structured approach to balancing interests that were becoming less aligned. A more structured approach to strategy review could have identified the change in circumstances and allowed for consideration of a different strategy sooner.

Decision-makers chose to end the Auckland lockdown by transition to the COVID-19 Protection Framework. Ministers considered there would be confusion associated with a brief move to stage 3 of Alert Level 3 (with its new rules) prior to the new Framework, with further new rules. While this was a short period, decision-makers' options were limited as the new Framework was not ready for transition until the end of November 2021.

That said, there would also have been harmful economic and social impacts if the Delta variant had spread widely through the country without any lockdown. It may be that decisions would therefore have been the same, or not significantly different overall, if decision-makers had reassessed their strategy, changed their decision-making process or had been provided with additional data.

Looking back from 2026, with everything else that has occurred since 2021, it is difficult to attribute overall outcomes to a four- to six-week period in October/November 2021 when restrictions in Auckland might have been lower. However, we acknowledge the view of some submitters that significantly different outcomes could have occurred for some people and businesses if restrictions had lifted sooner.

The unexpected consequences of lockdown decisions have been both positive and negative. Macroeconomic impacts now appear to have been larger than was forecast at the time, but enduring impacts on business survival and revenue in Auckland have been less than first anticipated. While COVID-19's impacts on education in New Zealand were relatively limited compared to other countries, they should not be discounted. Longer-term impacts on individual earnings, employment, health and wellbeing may take time to appear and were not well understood at the time lockdown decisions were taken.

Once vaccines became available, decision-makers were able to reconsider the use of lockdown measures. This illustrates a vitally important point: all the strategies to manage a public health crisis are closely interconnected. For example, if the desired vaccination rate could have been achieved earlier, lockdowns could have been lifted earlier. Each component of the overall strategy needs to be reviewed on a regular basis to make sure that each is contributing to the overall policy objective, while limiting, as far as possible, social and economic disruption.

Having considered all the evidence put before us, we are left in no doubt that former ministers and their officials made strenuous efforts to make the right decisions as the pandemic relentlessly progressed. The Government clearly faced a situation of extreme difficulty in October and November 2021. This experience gives rise to some useful lessons about making the best decisions in the worst of circumstances.

Lessons | Ngā akoranga

This report is intended to strengthen Aotearoa New Zealand's preparedness for, and response to, any future pandemic by identifying those lessons learned from New Zealand's response to COVID-19 that should be applied in preparation for any future pandemic.

The lessons outlined here focus on four fundamentals which we consider absolute pre-requisites of a future pandemic response:

 
These lessons give rise to some specific recommendations which are set out after this section.

Government should focus on ensuring strong permanent strategic capability in the centre of government, and on using that capability well.

On the whole, decisions made during the pandemic response were balanced and reasonable. However, some were made with less information than could have been available – for example, certain mandate decisions. Also, New Zealand's pandemic strategy and settings did not adapt early enough to changing circumstances.

It would be beneficial for government to investigate a new strategic function to look at improving modelling capacity, strengthening estimates of the impacts of public health measures, improving the availability of real-time data and developing a framework for structuring advice to decision-makers.

High-quality, timely data and modelling are key to good decisions. Future decision-makers should ensure that epidemiological modelling can be undertaken quickly in an emerging pandemic. They should also take steps ahead of a future pandemic to ensure that they have the real-time data and estimates of likely impacts on economic and social outcomes.

Fostering and maintaining strong relationships between business, community organisations and government will help support flexible and effective pandemic responses.

Several long-standing processes in the existing system (such as the requirement to produce regulatory impact statements and consult widely on Cabinet proposals) are designed to ensure considered, well-informed decisions. Exceptions to these processes in a future pandemic should be kept as narrow as possible. The Cabinet Manual should be updated to require that decisions taken outside of regular quality assurance processes are promptly reviewed.

Elimination strategies can be very beneficial in terms of preventing large numbers of deaths and hospitalisations from a severe pandemic. But they are difficult to exit. Governments should present such strategies from the outset of a pandemic as temporary measures and establish mechanisms that trigger prompt, regular and transparent strategic reviews. Taking these measures is likely to build trust in government and help plan for the exit from any elimination phase.

The exercise of public health powers is fundamentally shaped by the legislative framework that authorises them. The COVID-19 Public Health Response Act 2020 was an improvement over the existing legislative framework, but we learned that aspects could be improved for a future response.

Before the next pandemic, primary legislation should be in place that sets out the most significant legal powers government can use in a pandemic response. For example, this could cover issues such as lockdowns, border closures and quarantine arrangements, and vaccine requirements.

Pandemic legislation¹⁹ should be developed according to usual law-making processes, including select committee assessment, public consultation and meaningful engagement with Māori. It should emphasise and affirm human rights, especially the rights and freedoms affirmed in the New Zealand Bill of Rights Act 1990 and obligations owed under national and international treaty law.

Except in true emergency situations, significant decisions should be made at the highest practical level of authority. This should normally comprise at least secondary legislation enacted by Order-in-Council (in other words, regulations proposed by Cabinet through the Executive Council and signed off by the Governor-General). 

Where human rights are to be restricted (for example, by a lockdown) there should be a high degree of transparency in relation to the advice received and the reasons said to justify limitations under section 5 of the Bill of Rights which must be 'reasonable limits prescribed by law as can be demonstrably justified in a free and democratic society.'

The legislation should contain appropriate safeguards and should clarify how, why and by whom powers are to be exercised, including powers to grant exemptions from public health-related measures. It should require the government's use of extraordinary powers to be subject to ongoing review, monitoring and disclosure, but should allow for government to use different response strategies and approaches as the pandemic progresses and circumstances change. Advice relating to the exercise of powers under pandemic legislation should be publicly released.

Even with pandemic powers in place in advance, bespoke legislation may still be needed to deal with whatever specific challenges the next pandemic presents. However, its use should be limited, and it should only be passed under urgency as a last resort. As much as possible, the most significant public health powers a government will need in a pandemic response should be provided for in legislation that has already been enacted through ordinary, transparent processes and consultation.

A strong economy helped New Zealand respond to the COVID-19 pandemic. New Zealand's economic policy decisions now and into the future will be important for determining the country's ability to mount a strong response to the next pandemic or other shock.

The imminent arrival of a potentially deadly pandemic will likely again require quick action on the part of government to limit its incursion and spread. There will again be uncertainty about the course and duration of a new pandemic, the nature and severity of the accompanying shock to the economy, the impact of the public health interventions available and the extent and type of economic supports required.

Short-term or easily reversible economic policy measures should be used to address immediate effects and buy time to gather more information, especially about the type, size and duration of the shock to the economy.

Not all decisions need be taken swiftly. Those made at speed should be reviewed as circumstances change and strategies adapt. Ongoing monitoring is needed to check that the chosen options are achieving their intended purpose, and whether significantly better options have become available, or previously unforeseen consequences have emerged.

The 'strategic function' recommended in Lesson One should prepare and maintain a short-form guide for decision-makers facing a pandemic or similar emergency.

We learned that macroeconomic forecasts were unreliable during the pandemic. Decision-makers should treat them with caution, and consider a range of plausible scenarios, or possible paths the economy could follow.

The government's lead economic advisor, the Treasury, and the independent Reserve Bank, should clarify the roles of fiscal and monetary policies in the event of a large economic shock of uncertain nature and duration. This would assist in responding to the next pandemic, reducing the potential for unaligned economic policy responses.

If fiscal stimulus is considered necessary in a future pandemic, measures should be timely, temporary and targeted. Short-term supports that automatically adjust as circumstances change are preferable, and infrastructure maintenance and renewal should be considered ahead of new investment. The Treasury and the New Zealand Infrastructure Commission should investigate the feasibility of an infrastructure maintenance priorities programme.

Quantitative easing and other unconventional monetary policies used during the pandemic had significant costs. The Government should review the sections of the Public Finance Act 1989 that deal with giving Crown guarantees and indemnities. The Act should specify more robust and transparent processes for giving large guarantees and indemnities.

Additionally, the Treasury and the Reserve Bank should initiate a research programme to analyse the costs and benefits of unconventional monetary policies used in New Zealand and other countries during the pandemic. This should be done before such policies are used in future.

The Treasury, in conjunction with relevant agencies, should develop policy options for financial assistance schemes during a pandemic.

We learned that economic circumstances changed quickly during the pandemic. Stats NZ, in consultation with the Treasury and the Reserve Bank, should investigate the costs and benefits of more frequent releases of a wide range of macroeconomic indicators.

New Zealand, like many other countries impacted by COVID-19, is in a weaker position to weather the next large economic shock than it was at the start of the pandemic. There is a pressing need to reduce public debt to provide a buffer for future pandemics or other economic shocks. The best approach to reducing debt involves economic growth driven by productivity improvements, accompanied by disciplined fiscal management. The Treasury should publish a regular report on financial resilience, and this should guide the objectives stated in the Government's annual Fiscal Strategy report.

Government agencies should take the opportunity now to better understand the impacts of the COVID-19 pandemic (and the response) on the reach and quality of public services. Doing so will mean they are better able to minimise and mitigate the impacts of service disruptions in a future pandemic and can learn from each other.

Ministers should set clear expectations that their agencies will use the experience of COVID-19 to evaluate and assess services, plan for maintaining service delivery during a pandemic and identify which services will require the most attention to catch up on lost or disrupted delivery.

New Zealanders showed considerable resilience in the face of COVID-19 and the response. Nevertheless, there were clear impacts we can learn from. The disruption of some public services during the pandemic had long-lasting effects, including interruptions in key preventative health programmes, such as childhood immunisation and cancer screening. While service disruption may be inevitable during a pandemic, it is possible to mitigate some impacts through planning, agility and new approaches.

Public trust in government and social cohesion came under increasing pressure as the pandemic progressed. New Zealand went into the COVID-19 pandemic with deep reserves of public trust and these were boosted further with early successes in eliminating the virus. However, adherence to lockdown restrictions began to wane as more of the population was vaccinated and people increasingly questioned whether some restrictions were still proportionate to the risks.

Declining levels of trust and social cohesion cannot be solely attributed to COVID-19, or the response. Other issues undoubtedly contributed. In New Zealand, as elsewhere, misinformation and disinformation affected several areas of the response, particularly the vaccination campaign and lockdowns.

Decision-makers have to strike a difficult balance between respecting freedom of expression and encouraging compliance with public health measures, in an environment of contested information. Future governments need to ensure good transparency and communication around decisions and the science and other evidence used.

An agency should be tasked with monitoring evidence of trust and social cohesion in New Zealand, and developing policy advice about improving both. This would involve developing a clear evidence base about social cohesion trends and impacts.

Recommendations | Ngā tūtohutanga 

Phase Two of the Royal Commission of Inquiry into COVID-19 Lessons Learned is making 24 formal recommendations to Government. These are set out here under each of the four lessons they relate to.

Recommendation 1A:
Limit exemptions to produce regulatory impact statements
The Ministry for Regulation should limit exemptions from the requirement to produce regulatory impact statements in future pandemics, as far as possible, to decisions that are genuinely time critical.

Recommendation 1B:
Update the Cabinet Manual regarding prompt and regular reviewsThe Cabinet Office should update the Cabinet Manual and/or CabGuide to require that all Cabinet decisions taken outside of regular quality assurance processes are promptly and regularly reviewed, ideally when the situation is less urgent.

Recommendation 1C:
Present elimination strategies as temporary
Decision-makers should explicitly present elimination strategies as temporary from the outset of a pandemic, including in the New Zealand Pandemic Plan. This would help shape and manage public expectations, and create an impetus for forward planning.

Recommendation 1D:
Investigate a new strategic function
The Prime Minister and Minister for the Public Service should investigate establishing a permanent strategic function, either in the Treasury or the Department of the Prime Minister and Cabinet, and set up a clear work programme for that function.

Recommendation 1E:
Set aims for the new strategic function to improve modelling, estimated impacts, data and a new framework for advice
The permanent strategic function at the centre of government should work with relevant agencies to:

• ensure the capacity to stand up epidemiological modelling quickly in an emerging future pandemic
• strengthen estimates of the expected impacts of public health measures on key health, economic, social and educational outcomes
• improve the data available to decision-makers in real time to monitor actual impacts of public health measures, once they have been implemented, and
• develop a framework for structuring advice to decision-makers in a future pandemic that enables them to effectively weigh impacts of public health measures across desired outcomes, and so to identify the important trade-offs.

Recommendation 1F:
Set an external trigger for regular and transparent strategic reviews
Decision-makers facing a severe pandemic should introduce an external trigger for regular and transparent strategic reviews. This could comprise:

• a statutory requirement to regularly review and report to Parliament on the adequacy of current pandemic strategic settings, and on anticipated future choices, and/or
• the establishment of an independent review board, which would review and report on pandemic strategies. Such a board should include expertise and perspectives from the public sector, the public health community and others from outside government.

Recommendation 2A:
Develop standing primary legislation for pandemics

• To create a clear and enduring legal framework for managing future pandemics, the Government should establish dedicated primary legislation.
• This framework should set out the most significant powers and tools available to government in a pandemic response, including restrictions on movement and vaccine requirements, ensuring restrictions on human rights are grounded in primary legislation.

Recommendation 2B:
Ensure pandemic legislation includes clear powers, safeguards and flexibility

• The pandemic legislation should clearly define the scope and limits of emergency powers, including:
  • the triggers for activating them
  • the appropriate decision-making authority
  • the circumstances under which exemptions from powers, penalties or offences may apply.
• The legislation should embed strong safeguards – both procedural and substantive, and both proactive and reactive. The legislation and use of powers should be subject to ongoing review and reporting, and decision-makers should be required to explicitly consider:
  • human rights, and how any limitation on those rights is justified, necessary and evidence-based
  • principles such as proportionality and the use of least restrictive measures (which should be set out in the legislation to guide decision-making and the use of public health tools)
  • social and economic considerations, in balance with public health advice.
• The legislation should provide for flexibility, enabling the response to be scaled and adapted as circumstances change. However, decision-makers should be required to weigh social, economic and public health considerations at every stage of the response.
• The legislation should provide for periodic review, to ensure it remains fit for purpose.

Recommendation 2C:
Enact the legislation through ordinary, transparent processes and consultation

• To ensure legitimacy, public trust and robust consideration of rights and Te Tiriti o Waitangi obligations, the legislation should be developed using the usual law-making processes, including select committee scrutiny, public consultation and regulatory impact analysis.
• The legislation should undergo careful vetting for consistency with the New Zealand Bill of Rights Act 1990.

Recommendation 2D:
Limit the future use of urgency and bespoke legislation

• Bespoke pandemic legislation should not be passed under urgency except as a last resort.
• If urgency is unavoidable, law-makers should still follow as many ordinary processes as possible.
• Any bespoke powers should include appropriate safeguards, including sunset clauses, to ensure they expire automatically after a short period unless Parliament renews them.

Recommendation 2E:
Enhance transparency through publication of advice

• Advice relating to the exercise of powers under pandemic legislation should be publicly released as far as possible.
• In relation to human rights, there should be:
  
  • publication of all advice provided to the government about consistency of secondary legislation and/or other legislative instruments with the New Zealand Bill of Rights Act, and
  • reports to Parliament of any instances where secondary legislation is considered to be inconsistent with the New Zealand Bill of Rights Act.

Recommendation 3A:
Prepare guidance for decision-makers in a future pandemic

The 'strategic function' recommended in Lesson One should prepare and maintain a short-form guide for decision-makers facing a pandemic.

Recommendation 3B:
Advise on prudent debt levels in the face of future shocks

At least once every four years, the Treasury should publish a Financial Resilience report on the country's fiscal resilience. In the report, the Treasury should advise on current and expected public debt levels, and whether those levels provide a sufficient fiscal buffer in the face of one or more adverse events comparable in fiscal cost to COVID-19, and on the costs and benefits of maintaining that buffer.

Recommendation 3C:
Outline plans to rebuild fiscal buffers

The Government should assess the objectives stated in its annual Fiscal Strategy reports in light of the Treasury's most recent Financial Resilience report (see Recommendation 3B above).

Recommendation 3D:
Improve coordination between fiscal and monetary institutions

The Government, advised by the Treasury and the Reserve Bank, should clarify the roles of fiscal and monetary policies in the event of a large economic shock of uncertain nature and duration.

Recommendation 3E:
Develop options for implementable income and business support before the next pandemic

The Treasury, in conjunction with other relevant agencies, should develop policy options for financial assistance schemes during a pandemic.

Recommendation 3F:
Increase the frequency of official economic statistics
Stats NZ, in consultation with the Treasury and the Reserve Bank, should investigate the costs and benefits of more frequent releases of a wider range of macroeconomic indicators.

Recommendation 3G:
Investigate the feasibility of an infrastructure maintenance priorities programme
The Treasury, in collaboration with the New Zealand Infrastructure Commission, should investigate the feasibility of an Infrastructure Maintenance Priorities Programme for publicly-owned infrastructure, with the aim of making it more likely that future fiscal stimulus would be timely, temporary and targeted, and value for money.

Recommendation 3H:
Seek a better understanding of unconventional monetary policies
The Treasury and the Reserve Bank should initiate a research programme to subject the unconventional monetary policies used in New Zealand and other countries during the pandemic to rigorous empirical and policy analysis.

Recommendation 3I:
Improve the process for, and increase transparency of, Crown indemnities
The Government should review the sections of the Public Finance Act 1989 that deal with giving Crown guarantees and indemnities. The Act should specify more robust and transparent processes for giving large guarantees and indemnities.

Recommendation 4A:
Research the impact of the COVID-19 response
The Ministers of Education, Health, Social Development and Employment, and the Minister for Disability Issues should, as a matter of priority, direct their agencies to carry out, publish and share with each other research into:

• how quickly their services were able to return to pre-pandemic delivery levels after COVID-19
• the factors that made it possible for some services to rapidly return to normal
• the factors and characteristics of services that took longer to recover after COVID-19
• the key health, social and educational outcomes that deteriorated during COVID-19 – some of which may not yet have fully emerged
• what interventions would most cost-effectively restore coverage levels or outcomes.

Recommendation 4B:
Ensure good transparency and communication of decisions in a pandemic
Governments facing a pandemic should:

• be guided by the best scientific evidence available at the time, in designing their responses and setting specific public health measures
• be open and clear about the science and evidence they are using (including its limitations), and that knowledge may change and develop over time
• be open and clear about where they are obtaining their information from, and how they have reached decisions, so others can review that material and the conclusions the government is drawing from it.

Recommendation 4C:
Task an agency to monitor research and advise on policy regarding trust and social cohesion measures
The Government should task an agency with responsibility for monitoring local and international research and policy into initiatives that increase trust and social cohesion, and for advising on lessons and policy options for New Zealand.

Recommendation 4D:
The agency responsible for research and policy regarding trust and social cohesion should develop a clear evidence base
The agency with responsibility for monitoring local and international research and policy should develop a clear evidence base about patterns and trends in trust and social cohesion in New Zealand.

Conclusion | Whakakapi

This report concludes that New Zealand's response to the COVID-19 pandemic was effective, yet also recognises areas where the Government's response could have been strengthened. While New Zealand displayed some remarkable resilience in coming through this pandemic, we must not miss the opportunity to build resilience for the future.

This Inquiry's lessons and recommendations are intended to inform and improve New Zealand's preparedness for future pandemics. We commend them to the Government.

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² The three-volume main report also included technical appendices (presenting additional epidemiological, legal and governance information) and was accompanied by three companion reports: a summary, 'Experiences of the COVID-19 pandemic' (summarising public feedback provided in Phase One), and a standalone document containing all the lessons and recommendations from the main report. All are available at NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase One, Main Report (2024), https://www.covid19lessons.royalcommission.nz/reports-lessons-learned/

³ The two phases of the Inquiry were established under the Inquiries Act 2013, together with the Royal Commission of Inquiry (COVID-19 Lessons) Order 2022 (which came into force on 8 December 2022) and two amendment orders, effective 2 August 2024 and 26 September 2024 respectively.

⁴ Royal Commission of Inquiry (COVID-19 Lessons) Amendment Order (No 2) (2024), https://www.legislation.govt.nz/regulation/public/2024/0177/latest/LMS984331.html

⁵ The most significant decisions on tracing had already been taken and implemented before February 2021 and are addressed in the Phase One report.

⁶ Royal Commission of Inquiry (COVID-19 Lessons) Amendment Order (No 2) (2024), Schedule 2, cl 4, https://www.legislation.govt.nz/regulation/public/2024/0177/latest/LMS984331.html

⁷ NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase One, Main Report (2024), Part 2 Section 7.2.1, https://www.covid19lessons.royalcommission.nz/reports-lessons-learned/main-report/part-two/7-2-what-happened

⁸ NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase Two, interview with Hon. Grant Robertson (28 July 2025)  
NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase Two, interview with Rt. Hon. Dame Jacinda Ardern (30 July 2025)  
Cabinet Minute, CAB-20-MIN-0509, Update on the COVID-19 Immunisation Strategy and Programme, (7 December 2020), https://www.health.govt.nz/system/files/2021-05/cab-20-min-0509_0.pdf

⁹ Ministry of Business, Innovation and Employment, COVID-19 Vaccine Strategy: Update on vaccine purchasing [n.d] p 4, para 17, https://www.health.govt.nz/system/files/2021-05/update_on_the_covid-19_immunisation_strategy_and_programme_december_2020.pdf

¹⁰ W. Msemburi, A. Karlinsky, V. Knutson and others. The WHO estimates of excess mortality associated with the COVID-19 pandemic. Nature 613, 130–137 (2023) (14 December 2022), https://doi.org/10.1038/s41586-022-05522-2  
UK Covid-19 Inquiry, Module 1 report: the resilience and preparedness of the United Kingdom, Chapter 1: A brief history of epidemics and pandemics (18 July 2024), https://covid19.public-inquiry.uk/reports/module-1-report-the-resilience-and-preparedness-of-the-united-kingdom/#section_4_chapter-1-a-brief-history-of-epidemics-and-pandemics

¹¹ NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase Two, interview with Sir Ashley Bloomfield KNZM (26 May 2025)

¹² The Delta variant (B.1.617.2) was first identified in a MIQ facility on 31 March 2021. The first community case of Delta was announced on 17 August 2021, although the ESR later reported an earlier sample had been collected on 20 June 2021. McGuinness Institute, Covid-19 Nation Dates, 2nd ed. (Wellington: MCG Publishing, 2023), pp 204, 226

¹³ NZ Royal Commission of Inquiry into COVID-19 Lessons Learned: Phase One, Main Report (2024), Part 2 Section 5.6.1.1, Figure 1, https://www.covid19lessons.royalcommission.nz/reports-lessons-learned/main-report/part-two/5-6-our-assessment

¹⁴ Cabinet Paper, CAB-21-MIN-0012, Pfizer recommendations for decision to use (9 February 2021), https://www.health.govt.nz/system/files/2021-05/pfizer_recommendations_for_decision_to_use.pdf,  
Cabinet Social Wellbeing Committee Minute, SWC-21-MIN-0138, COVID-19 Strategy: Janssen Decision to Use (22 September 2021)

¹⁵ Cabinet Paper, February 2021 update on the COVID-19 Immunisation Strategy and Programme (February 2021), https://www.health.govt.nz/system/files/2021-05/february_2021_update_on_the_covid-19_immunisation_strategy_and_programme.pdf

¹⁶ Cabinet Briefing, For signing: COVID-19 Public Health Response (Protection Framework) Order 2021 (30 November 2021), https://www.dpmc.govt.nz/sites/default/files/2023-01/For-Signing-COVID-19-Public-Health-Response-Protection-Framework-Order-2021.pdf

¹⁷ Ministry of Health, Memorandum: National guidance for access to Rapid Antigen Testing (RAT) February 2022 (28 February 2022)

¹⁸ Medsafe, How does Medsafe monitor medicine safety? (21 November 2023), https://www.medsafe.govt.nz/consumers/Safety-of-Medicines/Medicines-Safety-and-Pharmacovigilance.asp

¹⁹ Primary legislation comprises Acts (also known as statutes) that have been passed by Parliament, or proposed Acts (known as Bills) that have been introduced to Parliament.