Update on vaccination policies in Canada

9 minute read
30 August 2021


As the COVID-19 situation progresses in Canada, many employers across the country are assessing whether and how to implement vaccination policies. Since the government of Canada's August 13 announcement (detailed below), the trend to mandate COVID-19 vaccination in the workplace and beyond appears to be on the rise. In this bulletin we are providing a brief summary of recent announcements of vaccination policies across Canada.


On August 13, 2021, the Government of Canada announced plans to implement mandatory COVID-19 vaccinations across the federal public service as early as the end of September. By no later than the end of October, the federal government will also require employees in the federally regulated air, rail, and marine transportation sectors to be vaccinated. There are exceptions to the mandatory vaccination policy for individuals with medical, religious or other human-rights related grounds. Those who do not comply risk losing their jobs.

This vaccination requirement will also pertain to certain travelers, including all commercial air travelers, passengers on interprovincial trains, and passengers on large marine vessels with overnight accommodations, such as cruise ships. 

The Government expects that Crown corporations and other employers in federally regulated sectors will also require vaccination in the workplace. Federally regulated sectors include:

  • banks, including authorized foreign banks;
  • grain elevators, feed and seed mills, feed warehouses and grain-seed cleaning plants;
  • First Nations band councils (including certain community services on reserve);
  • port services, tunnels, canals, bridges and pipelines (oil and gas) that cross international or provincial borders;
  • radio and television broadcasting;
  • road transportation services, including trucks and buses, that cross provincial or international borders;
  • telecommunications, such as telephone, internet, telegraph and cable systems;
  • uranium mining and processing and atomic energy; and
  • any business that is vital, essential or integral to the operation of one of the above activities.

Following the federal government's announcement, Canada's major banks, TD, BMO, RBC, CIBC, and Scotiabank, each shared plans to require COVID-19 vaccination of their employees by varying deadlines in the fall. Those who do not vaccinate will be required to complete regular COVID-19 testing.


To date, the Alberta government has not announced an intent to implement mandatory workplace vaccination policies to Alberta public employees.

Some municipalities have announced their plans regarding COVID-19 vaccination. The Town of Banff is requiring employees of the municipality to be fully vaccinated against COVID-19 by September 23, 2021. Those who do not comply risk losing their jobs. By contrast, the Town of Okotoks has stated that town employees will not be required to receive the COVID-19 vaccine.

Post-secondary institutions such as the University of Calgary, the University of Alberta, and the University of Lethbridge have announced that starting on September 1, 2021, all staff, students and faculty will be required to be fully vaccinated. Those who are not fully vaccinated, and those who would prefer not to disclose their vaccine status, will need to regularly complete a rapid screening test and receive a negative result before they participate in in-person activities. Members of the public, contractors and other individuals who work on or visit university campuses will also be required to be fully vaccinated or complete regular COVID-19 testing. Non-medical face masks must be worn in all public indoor areas on the University of Alberta, University of Calgary, and University of Lethbridge campuses where physical distancing is not possible and with certain exceptions.

British Columbia

On August 23, 2021, the B.C. government announced that proof of vaccination will be required to access non-essential business, services, and events, effective September 13, 2021 until January 31, 2022, subject to extension. Proof of vaccination will not be required to access essential services, such as grocery stores, transit, pharmacies, and medical facilities.

As of September 13, 2021, one dose of an approved vaccine will be required for entry to the following settings:

  • Indoor ticketed concerts, theatre, dance, symphony and sporting events;Indoor and outdoor dining at restaurants, pubs and bars;
  • ​Nightclubs and casinos;
  • Movie theatres; 
  • Gyms, pools and recreation facilities (not including youth recreational sport);
  • Indoor high intensity group exercise; 
  • Indoor organized gatherings like weddings, parties, conferences, meetings and workshops;
  • Indoor organized group recreational classes and activities like pottery and art (not including K to 12 school and before and after school programs); and
  • Post-secondary on-campus student housing (note: students must be partially vaccinated by September 7, 2021).

By October 24, 2021, entry to these settings will require eligible people to be fully vaccinated.

Individuals will be able to show proof of vaccination using the B.C. Vaccine Card, available either in paper or electronic form through a website yet to be launched, along with photo ID. Visitors from out-of-province will also be required to show proof of vaccination. Children under the age of 12 who are currently ineligible to be vaccinated are exempt from the policy. Individuals who have not been vaccinated due medical or other reasons will not be exempt from the policy, meaning they will not be able to access the above-noted services until the proof of vaccination requirement is lifted. This requirement has a tentative end date of January 31, 2022.

On August 12, 2021, the B.C. government announced that employees in long-term care house and seniors' assisted living facilities must be fully vaccinated by October, 12, 2021.


On August 17, 2021, Ontario made COVID-19 vaccinations mandatory in high-risk settings, including hospitals, ambulance services and home and community care service providers for employees, staff, contractors, students and volunteers. The vaccination policies in these high-risk settings must be effective by September 7, 2021, and at a minimum will require these individuals to provide proof of one of three things:

  • Full vaccination against COVID-19;
  • A medical reason for not being vaccinated against COVID-19; or
  • Completion of a COVID-19 vaccination educational session.

Those who do not provide proof of full vaccination against COVID-19 will be required to complete regular antigen testing.

Vaccination policies will also be implemented in other higher-risk settings such as:

  • Post-secondary institutions;
  • Licensed retirement homes;
  • Women's shelters; and
  • Congregate group homes and day programs for adults with developmental disabilities, children's treatment centres and other services for children with special needs, and licensed children's residential settings.

The August 17 announcement followed the provincial directive on July 1, 2021, requiring all Ontario long-term care homes to implement COVID-19 vaccination policies for staff, student placements, and volunteers.

Post-secondary institutions such as University of Toronto, Seneca College, UOttawa, Western University and Queen's University have announced that students, staff and faculty returning to campus must be fully vaccinated. Individuals who are not vaccinated will be required to adhere to other public health measures (e.g. wearing a mask) and complete regular COVID-19 testing.

The City of Toronto has stated that all its employees will be required to have two doses of a COVID vaccine by October 30, 2021 with accommodations for those legally entitled to them. The Toronto Police Service announced August 24, 2021 that it, too, will mandate vaccination for all members.

It is also worth noting that Toronto's Medical Officer of Health, Dr. Eileen de Villa, has strongly recommended that local employers institute a workplace vaccination policy to protect their employees and the public from COVID-19.

Should you have any specific questions about this article or would like to discuss it further, you can contact the authors or a member of our Gowling WLG Employment, Labour & Equalities Group.

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