comes to an end. There is similarly no provision, beyond the standard system of State reporting, for the recording, examining , and scrutinizing the emergency measures taken. The brevity and informal format of the CESCR’s Letter should not mask the serious and problematic alterations that it contains. While, in the abstract, a ‘conceptual shift’ may not appear to threaten the advancement of socio-economic rights, the general applicability of, and substantial freedom afforded by, the changes should raise concerns. If derogation-style changes to the ICESCR’s regime of non-retrogression are to be made, close attention should be paid to the consequent substantive and procedural changes they bring to the ICESCR more generally. Without such scrutiny the doctrine of non-retrogression risks aiding States during economic crises, while doing little to protect individuals’ socio-economic rights. 15

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