In the second week of December 2025, with roughly 10 weeks left on the clock, the briefing note prepared for the federal health minister’s use in question period described Canada’s supply of human avian influenza vaccine as a mark of preparedness.
It instructed the minister to say that the Government of Canada “is being proactive and has obtained 870,000 doses of human vaccine against avian influenza for provinces and territories.” If pressed on whether Canada had vaccines available, the note supplied a further line: the doses were “available for provinces and territories to order and use until February 2026.”
What the note did not say was how few had actually been ordered.
By the time the entire stockpile reached its Feb. 28, 2026 expiry date, provinces, territories and researchers had taken just 41,500 doses, according to the audit tabled May 4 by Commissioner of the Environment and Sustainable Development Jerry V. DeMarco on behalf of the auditor general. That is roughly 4.8 per cent of what Ottawa bought. The remainder, more than 828,000 doses, expired unused.
The briefing note is a public record. Under the Access to Information Act, the government proactively publishes the package of question period notes in use on the last sitting day in June and December each year. The avian influenza note, reference number HC-2025-QP-0012, is dated Dec. 12, 2025, is attributed to Health Canada, and lists Health Minister Marjorie Michel as the minister for whom it was prepared. Such notes are prepared by officials for a minister’s possible use and do not establish that any particular line was spoken in the House.
The audit findings themselves were reported across Canadian outlets in May. The contents of the government’s own December talking points, and the question of what the doses cost, appear not to have been reported.
The audit sets out a sequence. In June 2024, the Public Health Agency of Canada intended to acquire 800,000 doses without having conducted any analysis. In August 2024 it purchased 500,000 doses after estimating that was how many it would need. In February 2025 a more detailed analysis concluded it needed only 300,000. The following month, in March 2025, the agency purchased a further 370,000 doses, again, the audit says, without having conducted any analysis.
PHAC announced the first tranche publicly on Feb. 19, 2025, saying it had secured 500,000 doses of GSK’s Arepanrix H5N1 vaccine “leveraging an existing agreement,” with 60 per cent destined for provinces and territories and 40 per cent held in a federal stockpile. Then health minister Mark Holland called it a reflection of the government’s “commitment to being prepared.” Chief public health officer Dr. Theresa Tam said it enhanced Canada’s capacity to respond.
Neither that release nor the audit states a price.
A review of the federal proactive disclosure database of government contracts over $10,000 did not locate a contract corresponding to either purchase. PHAC’s disclosed contracts for calendar 2024 include large pharmaceutical buys, among them a $45.7-million amended contract with Elusys Therapeutics for “pharmaceutical and other medicinal products.” Its largest disclosed contract of any kind for calendar 2025 is a $1,997,279 purchase of computer servers. No record in either year matches a vaccine order of the scale the audit describes.
That absence is not, on its own, evidence of non-compliance. PHAC’s own wording, that it leveraged an existing agreement, suggests the doses may have been drawn against a pre-existing supply arrangement rather than bought under a new stand-alone contract, and search tools on the open government portal returned inconsistent results during this review. The database does contain one GlaxoSmithKline Inc. contract with PHAC dated March 10, 2026, valued at $685,797 and described only as “pharmaceutical and other medicinal products.” The entry does not identify the product, and it should not be assumed to relate to avian influenza vaccine.
What can be said is narrower and still unresolved: 19 months after the first purchase was announced, and roughly six months after the stock expired, no public record identified in this review discloses what Canadians paid.
Stockpiles are insurance, and doses expiring unused is not by itself a failure. A vaccine bought against a pandemic that does not arrive is a bet most public health authorities would make again. The auditor general’s criticism is narrower and harder to answer: that the purchasing decisions were not supported by the analysis that would show how large the bet should have been.
The question is not closed. The audit notes PHAC has already obtained financial approval to purchase more doses if needed, and recommends any further procurement be grounded in updated risk assessments, a cost-benefit analysis and demand forecasting. The December briefing note struck a similar forward-looking note, telling the minister the government would “continue to evaluate the potential need for further procurement of vaccine doses.”
Three things would settle what remains open: a written question on the Order Paper producing the contract value, an access-to-information request for the supply agreement and its call-ups, or a study by the House public accounts committee. This outlet has filed none of these and is reporting only what the documents show.
“While Environment and Climate Change Canada, the Canadian Food Inspection Agency, and the Public Health Agency of Canada took action to prevent and manage outbreaks of avian influenza, we found that they need to improve on planning, documentation, and the management of human vaccines to better prepare for future threats to public health and vulnerable wildlife,” DeMarco said when the report was tabled.
This is a developing story. Canadanewsmedia.ca has sought comment from the Public Health Agency of Canada and the Office of the Minister of Health and will update this report.
Sourcing note. Every fact above is drawn from a public record.
Question period note HC-2025-QP-0012, Health Canada, dated Dec. 12, 2025, published under the Access to Information Act, supports: the December talking points, the “870,000 doses” and “available to order and use until February 2026” language, the identification of the supplier as GSK Inc., the reference to an updated Arepanrix H5N1 formulation, and the “continue to evaluate the potential need for further procurement” line. search.open.canada.ca/qpnotes/record/hc-sc,HC-2025-QP-0012
2026 Report of the Commissioner of the Environment and Sustainable Development, Avian Influenza, tabled May 4, 2026, supports: the 870,000-dose total, the 41,500 doses distributed (39,200 to provinces and territories, 2,300 donated for research), the greater than 95 per cent expiry, the Feb. 28, 2026 expiry date, the June 2024 to March 2025 purchasing timeline, the finding that purchases proceeded without analysis, and the recommendation on future procurement. canada.ca/en/auditor-general/our-work/audit-reports/commissioner-environment-sustainable-development-202605-avian-influenza.html
Office of the Auditor General news release, May 4, 2026, supports the DeMarco quotation. canada.ca/en/auditor-general/media-room/bird-flu-response-working-but-risks-public-animal-health-remain.html
Public Health Agency of Canada news release, Feb. 19, 2025, supports: the 500,000-dose initial purchase, the Arepanrix H5N1 product name, the “leveraging an existing agreement” wording, the 60/40 distribution split, and the Holland and Tam quotations. canada.ca/en/public-health/news/2025/02/government-of-canada-purchases-avian-influenza-vaccine-to-protect-individuals-most-at-risk.html
Proactive disclosure of government contracts over $10,000, Open Government portal, supports: the absence of a matching vaccine contract in PHAC’s 2024 and 2025 records, the Elusys Therapeutics figure, the largest 2025 PHAC contract figure, and the March 10, 2026 GlaxoSmithKline entry. search.open.canada.ca/contracts
Originality check. Searches against CBC News, The Globe and Mail, The Canadian Press, CTV News, Global News, National Observer and The Logic found extensive May 2026 coverage of the audit’s expiry finding, and February 2025 coverage of the initial purchase. No coverage was found of the December 2025 question period note, or of the contract-disclosure question. Coverage of the audit is adjacent to this report but distinct from it.
Limitations. This report does not establish what the doses cost, does not establish that any disclosure obligation was breached, and does not establish the contents of the March 2026 GlaxoSmithKline contract. Those remain open questions, stated here as such.
