Abstract
Background/objectives
Pathogen access and benefit-sharing (PABS) sits between two practical needs. Public health depends on rapid access to pathogen materials and sequence information, while countries also seek a fair share of the benefits arising from their use. Comparative evidence on the domestic rules governing this exchange remains limited. This study maps national PABS frameworks and examines what their variation may mean for the emerging WHO PABS System.
Methods
This study conducted a systematic mapping and comparative analysis across all 193 United Nations Member States. International legal databases, official national sources, and targeted searches were used to identify relevant binding frameworks. Legally enforceable policies were identified, and data were extracted across the following four aspects of PABS legislation: (1) Resource Classification, (2) Access Protocols, (3) Benefit-Sharing, and (4) Regulatory Mechanism. Country-level sources, screening decisions, and coding rules are documented in the
Supplementary materials
.
Results
Ninety-three countries had confirmed frameworks covering pathogen-related genetic resources, while three cases remained legally unclear. Restricted access and formal requirements for prior authorization, benefit-sharing, and compliance were common among confirmed frameworks. DSI was less settled. National approaches ranged from explicit inclusion or exclusion to silence, and the pattern differed markedly across regions. Contractual requirements and legal sanctions also varied.
Conclusion
The national PABS landscape is fragmented rather than convergent. A future WHO PABS System will have to operate across different domestic approaches to authorization, documentation, sequence information, and benefit-sharing. More predictable interfaces between national systems may therefore be more workable than uniform national legislation.