As with previous global public health emergencies, the COVID-19 pandemic has had distinct and disproportionate impacts on women and their health and livelihoods. As the leader in global public health, it is incumbent upon the World Health Organization (WHO) to ensure gender is prioritized in pandemic response. We conducted a policy analysis of 338 WHO COVID-19 documents and found that only 20% explicitly discuss gender and over half do not mention women, gender, or sex at all. Considering the well documented gendered effects of pandemics and the WHO’s commitment to gender mainstreaming, this paper: 1) asks to what degree and how the WHO incorporates a gender inclusive approach; 2) maps where and how gender considerations are included; and 3) analyses what this suggests about WHO’s commitment to gender mainstreaming within its COVID-19 response and beyond. We demonstrate that WHO should increase its gender mainstreaming efforts and incorporate gender considerations related to health emergencies more often and in more policy areas.