The Welsh Government’s response to the UK Covid-19 Inquiry Module 4 report: Vaccines and therapeutics

The Rt Hon Baroness Hallett DBE, Chair of the UK Covid-19 Inquiry, published her fourth report and recommendations, Vaccines and Therapeutics, on 16 April 2026. The report considers the development, procurement and deployment of Covid-19 vaccines and therapeutics across the UK.

The Inquiry’s report provides an important opportunity to reflect on one of the most significant public health programmes delivered in Wales. The Covid-19 vaccination programme helped protect people from serious illness, reduced pressure on NHS and care services, and supported the gradual return of services and daily life after earlier pandemic restrictions. Wales was one of the first countries in the world to begin vaccinating against Covid-19, and whilst the report rightly recognises the vaccine rollout in Wales was an overall success, there are lessons to learn from the experience and choices made at the time. As a new government we want to ensure we learn those lessons. Success must also be considered in the context of the great loss, uncertainty and hardship experienced across Wales during the pandemic. Some people lost loved ones, some experienced serious illness, and many continue to live with its wider effects and consequences. We offer our sincere condolences to those who were bereaved, and our sympathy to all those whose lives were affected.

The delivery of the vaccination programme and the arrangements supporting access to therapeutics were only possible because of the commitment, professionalism, and compassion of NHS Wales staff, social care colleagues, public health partners, primary care contractors, general practitioners, community pharmacies, volunteers, local authorities and community organisations who supported it. They delivered at pace, often in exceptionally difficult circumstances, while adapting to evolving evidence, operational pressures and the needs of different communities. We remain deeply grateful to everyone who contributed to that effort.

The report makes clear that there are areas where systems and approaches can be strengthened and as a new Welsh Government, we are committed to taking on board the learning identified. The report highlights the importance of clear planning, effective coordination, strong data and evidence, trusted public communication and fair access to vaccination and treatments.

The new Welsh Government will respond to these findings in an open, evidence-led way that is focused on practical improvement. We will use the evidence and experiences reflected in the Inquiry evidence and report, to inform how Wales prepares for and responds to future public health emergencies. This includes consideration of how we deliver our vaccination programmes to improve equitable access and better respond to the needs of our population across Wales.

Mabon ap Gwynfor MS
Cabinet Minister for Health and Care

Nerys Evans MS
Deputy Minister for Public and Preventative Health 

Health and public health policy are devolved matters. This means the Welsh Government makes decisions about the planning and implementation of vaccination programmes across Wales. This includes leadership and planning how vaccines are delivered, improving access, tackling differences in uptake, and making sure people receive clear information and advice.

Development of policy and other measures to respond to the Inquiry’s recommendations will take place within the context of Welsh policy and Welsh legislative frameworks, informed by relevant statutory duties and obligations, including those relating to equality, human rights, rights of the child and wellbeing.

This document sets out the Welsh Government's response to the Inquiry’s recommendations. Of the 5 recommendations for Module 4, recommendation 5 is concerned with areas of policy wholly reserved to the UK government, while recommendation 1 is for the UK government to lead. Therefore, this response sets out the Welsh Government’s full response to recommendation 2, 3 and 4, and comments regarding recommendation 1 where it relates to Wales.

Delivery milestones are provided in the Table of Actions section of this response. We have worked collaboratively with our partners in the NHS in Wales, including Public Health Wales and Directors of Public Health in the development of our response and how the recommendations will be implemented.

The Welsh Government has agreed with the Inquiry that we will provide 6-monthly updates on progress against module recommendations, in May and November each year. An update on this module will be provided in the May 2027 update report.

Recommendation 1: Establish a pharmaceutical expert advisory panel

The UK government should establish a standing pharmaceutical expert advisory panel, in consultation with the Department of Health and Social Care and the Department for Science, Innovation and Technology.

The panel should include ministers, civil servants and representatives from industry and academia, and be led by an independent Chair with experience of working in a relevant industry. The panel’s role should be to:

• oversee the UK’s preparedness to develop, procure and manufacture pharmaceuticals (vaccines and therapeutics) in the event of a pandemic or health emergency, assisting with cross-government strategy development
• ensure that the UK government and devolved administrations, their agencies, industry and academia are aligned around shared goals in developing vaccines and therapeutics for pandemic diseases
• oversee strong links between government and the pharmaceutical industry
• advise the UK government on how to incentivise pharmaceutical companies to invest in manufacturing facilities and research in the UK, and
• advise the UK government on its research investments, with a view to ensuring a diverse portfolio of pharmaceutical research in the UK.

During a pandemic, the panel should form the basis of specialist taskforces, which would be responsible for securing and developing medical interventions and leading on their procurement on behalf of the 4 nations of the UK. They should have sufficient autonomy, delegation and direct access to senior ministers, similar to that which worked well in the Covid-19 pandemic.

Welsh Government response

1.1 The Welsh Government agrees that a Pharmaceutical Expert Advisory Panel should be established. As this recommendation is directed to the UK government to lead, the Welsh Government will work with the UK government and other relevant partners to support this work as it develops.

1.2 The Welsh Government recognises the potential value that a panel could have in strengthening the UK’s preparedness for future pandemics or health emergencies. It could provide an important mechanism for supporting access to independent advice, strategic oversight and constructive challenge on the development, procurement and manufacture of vaccines and therapeutics.

1.3 Relevant work is already underway across the UK to understand preparedness, manufacturing capability and supply chain resilience for vaccines, diagnostics and therapeutics. This work provides an opportunity to consider issues such as likely demand, stock levels, storage and transport requirements, supply chains, manufacturing capacity and reliance on single suppliers. The Welsh Government will continue to contribute to this work and will seek to ensure that Wales’s responsibilities, interests and experience are reflected.

1.4 The Welsh Government considers that any new panel will add most value if it has a clear and well-defined role, complements existing strategies and governance arrangements, and avoids duplicating work already underway. We will work with 4-nation partners to support an approach that strengthens preparedness and can, where needed, provide the basis for specialist taskforce arrangements during a future pandemic or health emergency.

Recommendation 2: Formalise work with communities about vaccine equity strategies

The UK government, Scottish Government, Welsh Government and Northern Ireland Executive should maintain networks with local communities to produce targeted vaccination strategies and communications.

To achieve this:

• The Scottish Government, Welsh Government and Northern Ireland Executive should establish local community networks, mirroring the approach being taken by the UK Health Security Agency.
• All 4 governments should work with their network to identify specific and measurable actions to improve vaccine uptake and reduce inequalities and consult with these networks on communications campaigns and delivery approaches.
• All 4 governments should publish a report annually on progress against these actions.

Welsh Government response

2.1 The Welsh Government fully recognises the importance of fair access to vaccines and trusted information. One of our key concerns is the divide in vaccination uptake between the most and least deprived in society, as well as other specific demographic groups and we are committed to addressing the discrepancy in health equity including wider determinants. Reaching and supporting communities who may face barriers to vaccination will remain central to the Welsh Government and the NHS in Wales future planning and approach.

2.2 The Welsh Government will continue to work with the UK government and the other devolved governments where shared principles, learning or coordinated action would add value. Wales’s approach reflects both the UK Health Security Agency’s community network model and the Welsh legislative, partnership and policy arrangements.

2.3 The National Immunisation Framework was published in 2022 and set out a programme of work to support the ongoing development of vaccination services in Wales. It reflected learning from the pandemic, and placed a clear focus on improving equity, access and uptake.

2.4 Since its publication, work under the framework has included the central procurement of the influenza vaccine, the development of equity strategies for each health board, and collaborative work to promote equal access and opportunity to receive vaccinations across Wales.

2.5 The framework also provided an opportunity to review governance arrangements for vaccination programme planning and delivery, with the aim of strengthening oversight. As part of this, a Vaccination Oversight Board was established, chaired by the Director of Public Health, to support decision making and assurance. The arrangements also included a Vaccination Equity Expert Group, chaired by a Health Board Director of Public Health, and a Vaccination Equity Network, to share learning and best practice.

2.6 Work supported through the Vaccination Equity Group includes the development of a health equity toolkit, which was rolled out to health boards in March 2026. A review of Health Board Equity Strategies and wider equity work, undertaken by a Clinical Research Fellow, has identified specific areas of improvement, including the need for a more consistent approach to local equity strategies across Wales.

2.7 Work has now begun to develop a new 5-year vaccination strategy. This will continue to focus on reducing inequity and improving uptake across Wales, by strengthening vaccination access, engagement and digital support. The forthcoming strategy will draw on existing activity to improve equitable access to vaccinations across Wales, supported by our renewed governance mechanisms.

2.8 Our approach will build on existing activities and learning from within Wales and elsewhere including use of behavioural science, co-production and asset-based approaches and public engagement and feedback including the Public Health Wales Time to Talk surveys. This includes strengthening links with community organisations, making better use of behavioural insights, developing clearer tools and standards, and working with partners to identify measurable actions to increase community engagement and trust and demonstrate improvements in take up and equity. This will continue to support co-production, statutory partnership working and the Well-being of Future Generations approach.

2.9 Progress will continue to be reported through national public health reporting arrangements, including reporting across deprivation and wider demographic factors. Reporting on this basis will strengthen further as work progresses towards a single vaccination record, which is discussed in more detail in our responses to recommendations 3 and 4.

Recommendation 3: Improve monitoring and evaluation of vaccine uptake and delivery

Each of the 4 UK public health or health security agencies should work together to:

• maintain accurate, UK-wide insight into the state of vaccine uptake and hesitancy, and
• understand the measures proven to be effective in increasing uptake across the 4 nations of the UK.

There should be collaboration and some standardisation in the agreed approach across the four nations for monitoring and publishing routine vaccine uptake and vaccine confidence levels in order to better understand regional variations and patterns. Each nation should set and regularly review its minimum acceptable standards of vaccine uptake, which would trigger targeted uptake campaigns if not reached.

The effectiveness of vaccine uptake campaigns should be evaluated against clear, standardised measures. This includes retrospective analysis of the Covid-19 uptake campaigns, as well as evaluation of routine vaccination uptake campaigns.

Welsh Government response

3.1 The Welsh Government recognises the importance of accurate, consistent information on vaccine uptake in supporting confidence. Good quality data is essential to understanding where uptake is lower, identifying barriers, and supporting targeted action to reduce inequalities. There are historic challenges in the use of healthcare data to deliver effective public health outcomes that must be addressed, with vaccination uptake a priority across all programmes. This was set out in the National Immunisation Framework for Wales and continues to be part of national efforts to improve our vaccination infrastructure.

3.2 Public Health Wales has a central role in taking this forward, as one of the four public health agencies referenced in the recommendation. The Welsh Government, Public Health Wales, Directors of Public Health and Vaccine Programme Wales have reviewed existing surveillance data, evaluation of vaccine uptake and opportunities to strengthen monitoring work, including through national communication campaigns and improved data reporting.

3.3 Wales already contributes to regular national data forums attended by Public Health Wales. These forums provide an established way for the 4 nations to share data, compare approaches and consider where greater consistency or standardisation in reporting would help improve understanding of vaccine uptake and confidence across the UK. The ability to compare, and where appropriate combine, statistics across the UK is important for understanding variation, identifying shared learning and supporting public trust. It is also consistent with the Code of Practice for Statistics, which emphasises coherence, transparency and statistics that meet user needs.

3.4 The Welsh Government is also working with Digital Health and Care Wales to improve the collection, quality, and reporting of vaccination data through the ongoing development of the Welsh Immunisation System. This includes improving insights into vaccine uptake by deprivation, linked to the Welsh Index of Multiple Deprivation, and supporting more detailed reporting across a range of population characteristics, including sex, socio-economic status and rurality.

3.5 The Welsh Immunisation System already supports linked data between primary and secondary care as part of a single vaccination record for the Influenza, Covid-19 and Respiratory Syncytial Virus (RSV) programmes.  The Welsh Government is committed to taking a planned approach to moving other vaccination programmes into this single record. This will support a move away from fragmented reporting arrangements towards a more consistent national approach. It will improve the ability to monitor uptake, identify variation and support targeted action where needed.

3.6 Welsh Government sets out expectations for vaccination uptake as part of its regular directions to the NHS in Wales ahead of programme delivery, or when programmes expand or change. The NHS in Wales also has high-level performance improvement targets for specific programmes set out in the NHS Wales Performance Framework. These targets are regularly reviewed as part of the same governance arrangements described in the response to recommendation 2. The Welsh Government also works closely with NHS Wales Performance and Improvement colleagues and NHS leaders to support improvements across the seven health boards.

3.7 Where vaccination uptake falls below expected levels, the NHS in Wales and the Welsh Government will continue to use, targeted catch-up campaigns where appropriate. The campaigns will be considered alongside other actions to improve uptake, such as changes, to how services are delivered, regulatory changes, or targeted communications. The Welsh Government fully recognises the importance of quality health data in understanding and driving improved performance and is committed to a health outcomes approach. This is why this Government has agreed to establish a Health and Care Data Audit Commission to oversee an audit of health data sources in Wales and the development of a health outcomes framework.

3.8 The Welsh Government and the NHS in Wales will continue to work with 4-nations partners to review approaches to vaccine confidence and uptake. We will also continue to commission, use and share research, such as in the recently published Public Health Wales study on RSV vaccination effectiveness in preventing hospitalisation, to support learning and improvement.

Recommendation 4: Proportionate access to linked healthcare records for use in the assessment of safety signals

The UK government and devolved administrations should work together, with their respective health delivery services, to facilitate and coordinate regulatory bodies’ access to healthcare records in order to make the post-authorisation safety monitoring of new vaccines and therapeutics more efficient.

In particular, the Medicines and Healthcare products Regulatory Agency should be granted specific and proportionate access to comprehensive and comparable data from across the 4 nations of the UK, including linked primary and secondary healthcare data records. This should include data on vaccines and therapeutics administration. This improved linkage must be accompanied by strong safeguards for patient confidentiality, which the Information Commissioner’s Office should work with the 4 governments to ensure.

Welsh Government response

4.1 The Welsh Government recognises the importance of ensuring that health data and digital systems can support the timely access to good quality data to facilitate safety monitoring. This must be done in a proportionate way, with strong safeguards for patient confidentiality.

4.2 Public Health Wales already provides health surveillance data to the Medicines and Healthcare Regulatory Agency including through the yellow card scheme and other established arrangements. This helps support clinical safety, and public confidence in national vaccination programmes and therapeutics. However, the Welsh Government accepts that there is more to be done in delivering this recommendation and enabling the safe and consistent access to linked data.

4.3 As set out in the response to recommendation 3, Wales has made significant technical progress through the ongoing development of the Welsh Immunisation System. This is helping to create a national vaccination record, using linked data, while supporting public health surveillance, recording and clinical audit.

4.4 The Welsh Immunisation System currently supports several major programmes, including Covid-19, influenza and Respiratory Syncytial Virus (RSV). Further work is planned to expand this approach across all vaccination programmes. This will support improved surveillance, service planning and the assessment of safety signals, to inform both the work of the Medicines and Healthcare products Regulatory Agency and Public Health Wales.

4.5 Work has started on a refreshed Digital and Data Strategy for health and care in Wales. This will set the long-term direction for improving digital services and making better use of data.

4.6 Implementing this recommendation in full, will require careful consideration of the legislative and governance arrangements needed to support ongoing, proportionate access to linked health data. Any arrangements must continue to protect patient confidentiality and comply with the relevant data protection requirements.

4.7 Progress to date has been limited in part by the current regulatory framework. The Welsh Government is exploring potential changes to address these barriers. This includes working with the UK government on matters reserved to the UK government, including data sharing and governance, to support a more sustainable and effective approach to the safe and responsible use and sharing of public health data.

4.8 The Welsh Government and Public Health Wales will continue to work actively with the Medicines and Healthcare Products Regulatory Agency to improve access to health surveillance information needed to support safety monitoring, in line with this recommendation.

Recommendation 5: Reform the Vaccine Damage Payment Scheme

The UK government must reform the Vaccine Damage Payment Scheme as soon as possible. The reform should include as a minimum:

• increasing the £120,000 payment, at least in line with inflation to date
• subsequently applying annual increases in line with inflation
• introducing multiple levels of payment, commensurate with the degree of injury suffered, and
• any transitional arrangements necessary to provide for fairness between applicants to the existing scheme and applicants to the revised scheme.

Welsh Government response

5.1 The Vaccine Damage Payment Scheme is entirely reserved to the UK government. The Welsh Government does not have responsibility for reforming the scheme but recognises the case for reform and agrees that it is important to ensure that appropriate support is available in the rare circumstance of vaccine harm.

5.2 The Welsh Government is engaged in 4-nation discussions on the future of the scheme. We will continue to work with the UK government and other devolved governments on how the scheme can be improved, including on the issues the Inquiry has highlighted.

Recommendation 2

• Publish a new vaccination strategy, which will centre on reducing inequity and improving uptake across Wales - May 2027
• Work with UK Health Security Agency, UK government and devolved governments to share best practice and understand where coordinated action would add value - Winter 2026
• Undertake a review on how to build on existing networks, avoid duplication, and agree a proportionate approach to implementing and acting on the feedback from community networks - September 2027
• Build annual reporting requirements into the forthcoming vaccination strategy - May 2027

Recommendation 3

• Undertake priority work to improve reporting for winter respiratory programmes - Winter 2026
• Work with Public Health Wales and Vaccination Programme Wales to develop a prioritised action plan aimed at improving surveillance data, evaluation of vaccine uptake, and identify opportunities to strengthen public health monitoring - May 2027
• Implementation of school aged vaccinations into the Welsh Immunisation System and Single Vaccination record - March 2028
• Use existing national data discussions to consider UK-wide approaches, including where greater consistency or standardisation of data and reporting would be beneficial - March 2028

Recommendation 4

• Review current data-sharing arrangement with the Medicines and Healthcare products Regulatory Agency in respect to post-authorisation safety monitoring and identify improvements - Autumn 2027
• Consider the legislative and governance arrangements needed to support proportionate access to linked health data while maintaining safeguards for patient confidentiality - TBC