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The Government of Ontario announced that starting September 22, 2021, individuals will be required to show proof of fully vaccinated status in order to gain access to certain businesses. While the regulations have not yet been published, the government has released key details concerning the plans.

“Fully vaccinated” means that an individual has received two shots of a government-approved vaccine, with the second shot having been received 14 or more days prior.

Access to the following businesses will be granted only if an individual provides proof of vaccination and a government-issued ID:

  • “Restaurants and bars (excluding outdoor patios, as well as delivery and takeout);
  • Nightclubs (including outdoor areas of the establishment);
  • Meeting and event spaces, such as banquet halls and conference/convention centres;
  • Facilities used for sports and fitness activities and personal fitness training, such as gyms, fitness and recreational facilities with the exception of youth recreational sport;
  • Sporting events;
  • Casinos, bingo halls and gaming establishments;
  • Concerts, music festivals, theatres and cinemas;
  • Strip clubs, bathhouses and sex clubs;
  • Racing venues (e.g., horse racing)”

During a press conference on September 1, 2021, Deputy Premier and Minister of Health Christine Elliott said that employees of these establishments are not expected to be covered by the vaccine verification system. This leaves employers to determine whether to create their own employee vaccination policies.

The government stated that, in accordance with currently effective public health steps, masks will still be required for indoor spaces.

The province is working on a “digital vaccine receipt” to be released at a later date. Until then, patrons will be required to show the paper or PDF copy of the vaccine receipt given to them when they received their vaccines.

Essential retail (such as grocery stores), as well as personal care services and places of worship, are not included in the plan. The province will equip all businesses with the vaccine verification app to allow nonessential retailers not covered by the new directive to implement their own policies regarding entry.

At this time, it appears that only patrons with medical exemptions may be granted entry to the establishments noted above without proof of vaccination. Individuals who cannot receive the vaccine due to medical exemptions will be permitted entry into the establishments mentioned above with a doctor’s note until recognized medical exemptions can be integrated as part of a digital vaccine receipt.

More details on these proposed regulations are expected to be released in the near future. For now, businesses in these areas may wish to review their current vaccination policies and plans in anticipation of these new requirements.

Ogletree Deakins will continue to monitor and report on developments with respect to the COVID-19 pandemic and will post updates in the firm’s Coronavirus (COVID-19) Resource Center as additional information becomes available. Important information for employers is also available via the firm’s webinar and podcast programs.


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