COVID-19 Vaccine Passports – Cross Canada Review

With the Delta variant surging, many provinces across Canada are implementing COVID-19 vaccine passports. While employers in certain industries (e.g., health care) are requiring their employees to be vaccinated, the COVID-19 vaccination passports most in the news focus on restricting individual access to certain businesses (e.g., restaurants, entertainment and sporting venues).

Here is a quick update on the state of mandatory COVID-19 vaccinations in Canada.*


While the federal government announced:

COVID-19 vaccine passports

  • mandatory COVID-19 vaccinations for:
    • federal public sector workers;
    • workers and travellers in federally regulated air, rail and marine transportation sectors;
  • Crown corporations and other federally regulated employers are expected to require COVID-19 vaccination for their employees

there are (currently) no legislated COVID-19 vaccine passports or other mandates. And, any further developments at the federal level will be determined by the outcome of next week’s election.


Effective September 20, 2021, specified businesses must implement a new “restrictions exemption program” (i.e., COVID-19 vaccine passport) or adhere to COVID-19 restrictions. Per the restrictions exemption program, these businesses must only provide services to persons age 12+ who give:

  • proof of vaccination (a single dose that was received at least two weeks prior is sufficient until October 25, 2021, when full vaccination is required);
  • a documented medical exemption; or
  • a negative COVID-19 test within 72 hours of service (paid for by the individual).

Businesses that do not implement the restrictions exemption program are subject to capacity limits and restrictions. See the Alberta announcement for a summary of impacted businesses.

In addition, all employees and contracted healthcare providers – including physicians and other frontline healthcare workers – must be fully immunized against COVID-19 by October 31, 2021.

British Columbia

Per Provincial Health Officer order, persons who are 12+ must:

mandatory vaccination

  • be partially vaccinated by September 13, 2021;
  • fully vaccinated by October 24, 2021; and
  • provide proof of vaccination

to access certain events, services and businesses. This includes indoor organized gatherings like weddings, parties, conferences, meetings and workshops, and businesses like restaurants, casinos and gyms. See the full list of businesses.

In addition, all staff and volunteers in long-term care and seniors assisted living facilities must be fully vaccinated against COVID-19 by October 12, 2021. Effective October 26, 2021, this will be expanded to all health care workers.


Per Manitoba Public Health Order, members of the public cannot access specified activities and services unless they provide proof that they are fully vaccinated. This includes businesses in hospitality, entertainment and sports and recreation industries.

Manitoba also announced that it will require provincial employees that have ongoing contact with “vulnerable populations” to be fully immunized or to undergo regular testing by October 17, 2021. This includes: healthcare, educational, and child care workers and those who work in congregate/residential settings and in correctional facilities. Those who are not fully vaccinated will have to undergo COVID-19 testing, up to three times a week, and provide proof of a negative test result before they can resume working.

New Brunswick

New Brunswick announced that effective September 21, 2021, everyone age 12+ will be required to show proof of vaccination when accessing certain events, services and businesses. Individuals who are unable to receive a vaccine due to a medical exemption will be required to show proof. Affected businesses include restaurants, sporting events, movie theatres and recreation facilities (see the announcement for the full list).

New Brunswick is developing a QR code that can be displayed on a phone, and in the meantime, people can provide a copy of their immunization record.

In addition, everyone travelling to New Brunswick (including New Brunswick residents returning home) must register through the New Brunswick Travel Registration Program, and upload proof of vaccination. People who are not fully vaccinated must isolate for 14 days.

Newfoundland & Labrador

Per the Special Measures Order (Re-Opening Travel), persons arriving in Newfoundland and Labrador from outside Atlantic Canada must self-isolate unless they are partially or fully vaccinated.

Nova Scotia

Per Nova Scotia’s public health order, persons arriving in Nova Scotia from outside Nova Scotia, Newfoundland & Labrador, and Prince Edward Island (and not engaged in “essential travel”) must self-isolate unless they are fully vaccinated.

In addition, Nova Scotia announced that, effective October 4, 2021, persons who are age 12+ will have to provide proof of full vaccination in order “to participate in most events and activities that bring groups of people together.” See the government policy for affected businesses.

COVID-19 vaccinationOntario

Employers/owners must comply with any public health advice, recommendations and instructions regarding a COVID-19 vaccination policy.

Per regulation, as of September 22, 2021, persons who are age 12+ will have to provide proof of their vaccination status and identity to access certain businesses, services and events. This mandate is subject to specified exemptions, including a medical exemption set out in writing by a physician or a nurse practitioner. Affected businesses include those in the hospitality, entertainment and sports and recreation industries (see the regulation for the full list). An enhanced vaccine certificate and verification app – with a unique QR code – will be available by October 22, 2021.

Per the Ontario Chief Medical Officer directive, hospitals and home/community care service providers must have a COVID-19 vaccination policy for employees, staff, contractors, students and volunteers, which requires these persons to provide proof of full vaccination against COVID-19 or a medical exemption.

Prince Edward Island

Per the COVID-19 Prevention and Self-Isolation Order, persons arriving in PEI from outside Atlantic Canada must self-isolate unless they are fully vaccinated (subject to certain other exemptions).

Per order, PEI also requires COVID-19 testing and vaccination measures in community care and long term care facilities.


Per Quebec order, a COVID-19 vaccination passport (plus proof of identity) is required for persons age 13+ to access non-essential services. This includes indoor organized gatherings like conventions and businesses in the hospitality, entertainment and sports and recreation industries. The passport provides proof of (full) vaccination in the form of a (scannable) QR code, and is available through an app or PDF on a mobile device (or can be printed).

People travelling to Québec must show photo ID and proof, issued by their country or Canadian province, that they have been fully immunized.


Effective October 1, 2021, everyone who is age 12+ must provide proof of COVID-19 vaccination or a negative test in order to access establishments, businesses and event venues that bring groups of people together. See the announcement for a list of affected businesses.

*This article does not review any COVID-19 vaccination requirements implemented by municipal governments.