This Official Information Act (OIA) request (submitted October 5, 2025, ref: H2025073669) seeks reports mandated by Condition 54 of the Pfizer Comirnaty COVID-19 vaccine’s provisional approval, as outlined in the New Zealand Gazette notice 2021-go338 (February 3, 2021). Condition 54 requires Pfizer New Zealand Limited to submit, within five working days of production, “any reports on efficacy including asymptomatic infection in the vaccinated group, vaccine failure, immunogenicity, efficacy in population subgroups and results from post-marketing studies.”

Submitted only one day ago, the request awaits a substantive response from the Ministry of Health (MoH), due by approximately November 7, 2025. However, this request echoes a consistent pattern of prior OIAs on FYI.org.nz, where identical or similar requests for Condition 54 reports have been met with MoH/Medsafe responses stating that such reports “do not exist” (OIA s18(e)) or are not held. Over four years since the vaccine’s provisional approval and with over 10 million doses administered in New Zealand, the absence of these mandated reports in the public domain raises critical questions about transparency and compliance with the gazette conditions, which have been reiterated in renewals through 2025 (e.g., 2023-go5134).

Corroborating Prior OIAs Highlighting Non-Disclosure:

The following requests, all publicly accessible on FYI.org.nz, sought similar Condition 54 reports but received no substantive documents, pointing to a systemic gap in public access to efficacy and failure data:

• Request #26209 (2024, Erika Whittome, ref: H2024038268): Identical to this request, seeking efficacy, vaccine failure, and subgroup reports. MoH stated it “did not have the information requested” and referenced prior responses. Follow-ups (refs: H2024040163, H2024040733) were redirected to unrelated systems (e.g., Te Whatu Ora’s E2B safety data), with no Condition 54 reports provided.

• Request #17184 (2021, T. Baker, ref: H202114374): Requested reports for Conditions 52 (duration of efficacy/boosters) and 54. MoH explicitly stated “no such reports exist” and refused release under OIA s18(e). Only commercially sensitive data was withheld; no efficacy reports were shared.

• Request #15967 (2021, T. Baker, ref: H202108049): Sought reports for Conditions 52, 54, 56 (Periodic Safety Update Reports), and 57 (safety reviews). No Condition 54 reports were released; responses were combined with another OIA, and follow-ups (ref: H202108894) yielded only procedural letters, not data.

• Request #17917 (2021, K. Smith, ref: H202114374 variant): Referenced Condition 54 in the context of efficacy inconsistencies and informed consent. MoH provided no reports, only general datasheets, with partial refusals.

• Request #19000 (2021, J. Doe, ref: H2022018490 variant): Focused on “negative vaccine effectiveness and vaccine failure.” Acknowledged by MoH, but no Condition 54-specific reports were released.

Broader Context for Public Awareness:
Medsafe’s public resources, such as the Comirnaty datasheets (e.g., JN.1 2024), note limited efficacy insights, such as lower protection in immunocompromised groups or reduced effectiveness against variants, but lack the detailed post-marketing reports mandated by Condition 54. Safety monitoring via the Centre for Adverse Reactions Monitoring (CARM) is robust, with summaries available (Medsafe Vaccine Reports), but these focus on adverse events (e.g., myocarditis) rather than efficacy, vaccine failure, or subgroup analyses. Observational data, such as one-dose effectiveness of 44–80% against infection (ref: H2023025722, MoH Response 2023), exists but does not fulfill Condition 54’s scope.

The provisional consent for Comirnaty, initially granted for nine months in 2021, has been renewed multiple times (e.g., October 2021, April 2022, November 2023) and transitioned to full approval for original formulations in November 2023, with variant-specific consents active until November 2025 (Medsafe Status). Despite this, no public evidence confirms that Condition 54 reports have been shared, even as global studies note variant-driven failures and immunogenicity variations.

Why This Matters:
The consistent non-disclosure across multiple OIAs suggests a gap between the gazette’s mandates and public access to critical data on vaccine performance, particularly for vulnerable subgroups or real-world effectiveness. This pattern, spanning 2021–2025, invites scrutiny of how regulatory conditions are enforced and whether efficacy data is being prioritized alongside safety. For those seeking to understand the vaccine’s real-world impact, these links provide primary sources to explore the issue independently and critically.

Sources: FYI.org.nz archives, New Zealand Gazette, Medsafe publications. This annotation is for public information to foster transparency and critical thinking, not as legal or medical advice.

So now MoH want to charge for the information that many have now requested (and not been supplied) .

This is unacceptable. This information formed part of the provisional consent process and the public have a right to this information.

This is LAWFARE.

Annotation: Ministry of Health’s Fee Imposition and Delays: A Pattern of Evasion on Condition 54 Reporting

This OIA request (ref: H2025073669, submitted 5 October 2025) exemplifies a troubling escalation in the Ministry of Health’s (MoH) tactics to withhold critical post-marketing data on the Pfizer Comirnaty vaccine’s efficacy and failures, as mandated by Condition 54 of its provisional approval (New Zealand Gazette 2021-go338, renewed through 2025). By imposing a $380 charge for “6 hours of work” just 25 days after acknowledgment, followed by a 30-working-day extension to 1 December 2025 under OIA s15A for “consultations,” MoH appears to be deploying financial and procedural barriers to deter access—classic obfuscation in the face of public interest.

The Charge as a Barrier: OIA guidelines (Ombudsman and Ministry of Justice) allow charges only for substantial compliance costs exceeding the first free hour, yet prior identical requests (e.g., #26209, #17184 on FYI.org.nz) were flatly refused under s18(e) (“information not held”) without fees. Here, the sudden pivot to billing—without evidence of novel effort—smacks of “lawfare,” as annotator John Armstrong aptly notes. For a vaccine involving 18+ million taxpayer-funded doses and enforced via public health orders affecting millions, demanding payment for transparency on real-world efficacy (e.g., asymptomatic breakthrough infections, subgroup performance in immunocompromised or elderly populations) undermines accountability. The requester’s objection, emphasizing public health mandates, is spot-on: this isn’t a commercial query; it’s oversight of a national rollout.

Extension and Stalled Progress: The 1 December deadline, tacked onto a charge reminder, buys MoH time amid mounting scrutiny. With the vaccine’s variant-specific consents expiring in November 2025 (Medsafe updates), urgency is paramount—yet no substantive response has materialized by 9 November. This mirrors historical delays: e.g., Request #15967 (2021) saw combined refusals and procedural redirects, yielding zero Condition 54 documents over years.

Broader Implications: Over 10 million doses administered in NZ since 2021, yet MoH/Medsafe’s public datasheets (e.g., 2024 JN.1 variant) offer only vague nods to “reduced effectiveness against variants” without the granular post-marketing reports Condition 54 demands. Global data (e.g., NEJM studies on waning immunity) highlights failures in subgroups, but NZ’s silence persists. Is Pfizer submitting these reports privately? If so, why the veil? Non-disclosure erodes trust, especially as CARM focuses on safety while efficacy gaps fester.

Public pressure via Ombudsman complaints (0800 802 602) or follow-up OIAs is essential. This isn’t isolated—it’s systemic. For deeper dives, cross-reference FYI requests #26209, #17184, and Medsafe’s Vaccine Reports. Transparency isn’t optional; it’s the bedrock of informed consent.
Sources: FYI.org.nz archives, NZ Gazette, Medsafe datasheets, OIA Act. This annotation promotes critical discourse, not advice.

Annotation: Global Shadows of Secrecy: FOI/FOIA Struggles for Pfizer & Moderna Vaccine Efficacy and Safety Data

This New Zealand OIA (ref: H2025073669) isn’t an outlier—it’s part of a worldwide saga of regulatory foot-dragging on post-marketing reports for Pfizer’s Comirnaty and Moderna’s Spikevax mRNA vaccines. From the US’s FOIA lawsuits forcing out 450,000+ pages of redacted Pfizer data to the UK’s MHRA admitting it ignored nearly half of Moderna death reports via FOI disclosures, governments and agencies have wielded delays, redactions, and exemptions like shields. As NZ’s Condition 54 mandates go unfulfilled, global requesters—from journalists to parents of injured teens—face a pattern of “transparency theater”: promises of openness drowned in procedural quicksand. With billions of doses administered, these gaps aren’t bureaucratic glitches; they’re barriers to accountability on efficacy waning, breakthrough infections, and subgroup harms (e.g., pregnant women, youth).

US: Lawsuits Unlock Buried Burdens
The epicenter of resistance? The FDA’s initial bid for 55 years to process a 2021 FOIA on Pfizer’s EUA data—prompting a federal judge to mandate 55,000 pages monthly. Public Health and Medical Professionals for Transparency (PHMPT/ICAN) unearthed 1,223 deaths and 42,086 adverse events in Pfizer’s first three months post-EUA, including myocarditis in teens and uninvestigated clots. For Moderna, ICAN’s 2021 FOIA to NIH was stonewalled—safety/efficacy data fully withheld—while a 2023 FDA inspection flagged manufacturing lapses like unclean equipment risking contamination. Revolving doors amplify distrust: Ex-FDA officials now at Moderna, blurring oversight. Recent 2025 emails reveal CDC downplayed efficacy dips to manage PR, echoing RFK Jr.’s pre-rollout warnings of manipulated expectations.

UK: Redactions and Unfollowed Deaths
MHRA’s FOI responses are a masterclass in evasion: 2022 requests for Pfizer authorization docs yielded partial releases, but 2023 queries on adverse events post-Moderna drew admissions of no follow-up on ~50% of 1,645 death reports. Redacted CHM minutes on Moderna’s bivalent approval (despite lower efficacy) persist, with MHRA citing “future publication” exemptions—unchanged after requesters’ appeals. Pfizer’s hidden April 2021 data on waning immunity (known months before public admission) surfaced via regulatory filings, not proactive disclosure..

Canada & Australia: Contract Cloaks and Redirects
Health Canada’s 2023 FOI exposed Pfizer’s October 2020 contract acknowledging unknown long-term effects and 200% clot risks—yet efficacy waned to near-zero against variants, per suppressed Israeli data. Australia’s TGA dodged 2022 FOIs on Pfizer comms with blanket “commercial sensitivity” refusals, mirroring NZ’s fee hikes and extensions. A 2024 Canadian analysis branded the “safe and effective” push “garbage science.”

EU & Beyond: Variant Veils and Pregnancy Perils
EMA faced 2023 rebukes for withholding SMS on vaccine deals; a Romanian court annulled elections over electoral fraud tied to vax narratives. Globally, FOIs reveal ignored signals: Pfizer’s lost 42,000+ event records (1,200 deaths), Moderna’s 14,000-page dump showing unprobed neurological harms, and biodistribution studies skipped in trials. Pregnancy data? Pfizer’s rat study (44 animals) greenlit shots for moms, despite 28 miscarriages in tracked human exposures; stillbirths doubled in vaccinated cohorts per Scotland/Canada data.

The Pattern: Profit Over Proof?
Across jurisdictions, tactics align: 75-year delays, s18(e)-style “not held” claims, $380+ fees (echoing NZ), and unblinded trials masking long-term efficacy drops (95% relative risk reduction hid 0.84% absolute). With 158,000+ Pfizer adverse reports in two months and Biden extending liability shields to 2029, requesters like Naomi Wolf (via “Pfizer Papers”) and Aaron Siri face censorship—her X suspension for “misinfo” on FOI-sourced miscarriage stats. Why? Conflicts: FDA staff purged (then rehired) for FOIA backlogsu, billions in profits.

This isn’t oversight—it’s opacity fueling distrust. As NZ’s inquiry looms, global precedents demand unredacted Condition 54 equivalents: subgroup efficacy, failure rates, variant impacts. File your own FOIs; amplify via Ombudsman or courts. True public health thrives on sunlight, not shadows.

Sources: FYI.org.nz, BMJ, Reuters, Substack (Demasi/Elijah), CHD, X archives (@Techno_Fog, @toadmeister). For critical thinking, not advice.

Annotation: AstraZeneca’s Shadow Play: Global FOI Battles Echo Pfizer & Moderna Opacity on COVID Vaccines

As New Zealand’s Ministry of Health drags its feet on Condition 54 reports for Pfizer’s Comirnaty—imposing $380 fees and extensions to December 1, 2025—it’s worth zooming out. AstraZeneca’s Vaxzevria (or Covishield globally) faced its own cascade of transparency hurdles, from redacted contracts to delayed clot data, mirroring the mRNA duo’s playbook of redactions, “commercial sensitivity” exemptions, and endless consultations. Yet AstraZeneca’s saga stands out: a viral-vector jab withdrawn worldwide in May 2024 amid “low demand” and rare Thrombosis with Thrombocytopenia Syndrome (TTS) risks, after billions of doses rolled out. With 97% of UK’s 14,000+ Vaccine Damage Payment Scheme claims tied to AstraZeneca, FOI requesters worldwide pried open cracks revealing ignored warnings, contaminated batches, and funding black holes. Here’s how it stacks up against Pfizer/Moderna’s fortress of secrecy—same tactics, but AstraZeneca’s blood-clot scandals added a visceral edge.

US: FOIA Wars on Contracts and Clots
AstraZeneca’s US transparency lagged mRNA peers from the start. KEI’s 2020 FOIA unearthed BARDA’s $1.2B AstraZeneca deal but hit walls on full terms, much like Pfizer’s 450,000+ redacted pages from PHMPT’s lawsuit. By contrast, Moderna’s NIH ties yielded partial dumps, but all three vaccines saw FDA’s infamous 55-year release bid crushed by courts. AstraZeneca-specific? FOIAs flagged TTS early (2021), yet FDA delayed EUA for months—critics like Dan Elton on X called for CRL transparency, as companies (even partners) puzzled over rejections. Pfizer/Moderna faced myocarditis scrutiny; AstraZeneca’s was clots (1 in 100,000, but fatal in 19% of cases per UK data 20 ). Pattern: All invoked “national security” for contracts, but AstraZeneca’s Oxford roots amplified public-funding demands—97% taxpayer-backed, per FOI to University of Oxford.

UK: MHRA’s Redaction Ritual, Amplified by AstraZeneca Atrocities
MHRA’s FOI log reads like a greatest hits of evasion: 2021 requests on AstraZeneca dosing yielded partials (FOI-21-041), while 2023 clot queries (FOI 22/715) dumped 71 fatal venous events but redacted follow-ups. By 2024, 13,984 VDPS claims (mostly AstraZeneca) spotlighted strokes, heart attacks, and paralysis—yet MHRA cited “future publication” to withhold. Pfizer/Moderna? Similar: 2022 FOIs on authorizations (FOI 21/992) listed leaflets but buried immunogenicity data. AstraZeneca edged darker—April 2021 CMO alerts on 79 thrombocytopenia cases (19 deaeren’t shared with families, per VIBUK’s X exposé. All three: ICO upheld redactions for “rolling reviews,” but AstraZeneca’s 2023 cessation FOI (FOI 23/858) got procedural stalls.

EU/EMA: Court Slaps and Contract Cloaks
EMA’s “exceptional transparency” for COVID meds rang hollow. AstraZeneca’s 2021 conditional approval docs leaked via court battles, but FOIs on supply contracts (asktheEU.org) hit exemptions—echoing Pfizer’s €71B “Pfizergate” appeal, where the Commission fought a July 2024 ruling for fuller disclosure. Moderna’s bivalent FOIs? Same veil. AstraZeneca withdrew EU authorization in March 2024, citing surplus, but EMA’s clinical database (linked in MHRA FOIs) hid subgroup efficacy gaps. BMJ slammed all trials for “decisions without data”—protocols released late (AstraZeneca pledged post-Pfizer/Moderna pressure in 2020), with IPD years away. Only 7% of global contracts published, per Transparency International.

Canada & Australia: ATIP/FOI Delays on Dirty Doses
Health Canada’s ATIP hell: A 2024 request on 1.5M AstraZeneca doses from a contaminated Baltimore plant (poor disinfection, per FDA) got a 195-day extension, then “analyst away” excuses into June 2025—consulting AstraZeneca on 2,000+ pages, admitting no independent data. Pfizer/Moderna? Similar procurement opacity in OAG audits 61 . Australia’s TGA: 2021 FOI 2494 released partial AstraZeneca docs but redacted efficacy, citing “sensitivity”—like Pfizer’s comms dodges 6 . Both nations: Delays prioritized Pharma over public (e.g., Canada’s 20M-dose AstraZeneca pivot amid mRNA lags 59 68 ).

The Triad’s Toxic Transparency: Parallels and Perils
Pfizer/Moderna/AstraZeneca shared sins: 2020 protocol pledges under pressure (BMJ), but <50% trial results public by 2025; FOIs met with s18(e)-style “not held” or fees; courts forced drips (EU’s 2024 slap, US’s 55K pages/month).
AstraZeneca diverged on fallout—clot admissions fueled 253 UK claims vs. Pfizer’s 102, and its 2024 pull exposed “surplus” as code for liability dodge. mRNA jabs? Waning efficacy buried deeper. Globally, 97% Oxford-Astra funding public, yet contracts secret—like Pfizer’s EU opacity. Result? Distrust: X rants on shed viruses, mandates, and “garbage science”.

NZ’s OIA echo chamber demands escalation—Ombudsman probes, class actions. AstraZeneca’s clot ghosts haunt; Pfizer/Moderna’s linger in subgroups. Full data now: For equity, not excuses.
Sources: FYI.org.nz, GOV.UK/MHRA, EMA, Health Canada ATIPs, BMJ, Politico, X (@VIBUK_Official, @RebelNewsOnline). For discourse, not advice.