Ontario Government Releases Regulations and Guidance for Vaccine Certificates

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Ontario Government Releases Regulations and Guidance for Businesses and Organizations on the Vaccine Certificates

On September 14, 2021, the Ontario Government presented their guidance and regulations surrounding the Vaccine Certificates and proof of vaccination which will be implemented next week. This means that as of September 22, 2021, patrons will be required to be fully vaccinated and provide proof of their vaccination status as well as proof of ID to enter certain businesses and organizations. The focus will remain on higher-risk indoor public settings.

Highlights from these documents released today are as follows:

Purpose of implementing these additional health measures are:

  • Limiting COVID-19 transmission and outbreaks
  • Encouraging vaccination
  • Supporting Ontario’s businesses in remaining open

General Guidelines:

  • proof of vaccination rules are for patrons only, not staff, businesses can implement their own proof of vaccination policy if not covered by these regulations, but need to seek their own legal advice.
  • Other public health and workplace safety measures will still apply, including masking, screening, and contact tracing.

Note: NOTO will be working with industry colleagues to seek legal advice and develop templates to support businesses who wish to put their own proof of vaccination policies in place for staff.
In order to be considered “fully vaccinated”, patrons must have received:

  • The full series of a COVID-19 vaccine authorized by Health Canada, or any combination of such vaccines (Pfizer-BioNTech, Moderna, AstrZeneca, Johnson & Johnson)
  • One or two doses of a COVID-19 vaccine not authorized by Health Canada, followed by one dose of a COVID-19 mRNA vaccine authorized by Health Canada
  • Three doses of a COVID-19 vaccine not authorized by Health Canada
  • They received their final dose of the COVID-19 vaccine at least 14 days before providing the proof of being fully vaccinated.
  • Trial vaccines will NOT be accepted

Proof of Vaccination:

  • Proof of vaccination can be shown on paper or on mobile device (e.g., PDF)  
  • Accepted ID does not need to be photo ID – only requires name & date of birth (information must match proof of vaccination document)  
  • Accepted forms of ID:  
    • Birth certificate   
    • Citizenship card   
    • Driver’s licence   
    • Government-issued ID card (Ontario issued or other), including health card   
    • Indian status card/indigenous membership card   
    • Passport   
    • Permanent resident card 
  • The patron must provide proof of being fully vaccinated and proof of ID at the point of entry to the required setting   
  • Patrons cannot pre-display or upload proof of vaccination: no data retention of data allowed   
  • The business or organization must review and confirm proof of ID and vaccination – they are responsible for ensuring they meet the requirements to check for proof of vaccination and ID from patrons  
  • The patron seeking entry is solely responsible for demonstrating that they are legitimate holders of the vaccination receipt  
  • Patrons are not allowed to enter a business or organization if the name and date of birth on both documents do not match 

Businesses and Organizations that will require proof of vaccination (as of September 22nd, 2021)

  • Indoor areas of commercial film & TV productions w/ studio audiences   
  • Indoor areas of waterparks
  • Indoor areas of concert venues, theatres, cinemas   
  • Indoor areas of restaurants, bars, other food & drink establishments (excluding outdoor patios & takeout)  
  • Indoor food service/food courts (e,g., café at costco)   
  • Indoor AND outdoor areas of food & drink establishments with dance facilities (e.g., nightclubs, restoclubs; excluding takeout)  
  • Indoor areas of horse racing tracks, car racing tracks, & other similar venues  
  • Indoor areas where spectators watch sporting events   
  • Indoor areas of casinos, bingo halls, other gaming establishments  
  • Indoor areas of facilities for sports & recreational fitness activities, including personal fitness training  
  • Indoor meeting & event spaces (e.g., banquet halls, conference/convention centres) 

Note: If someone needs to use your indoor washroom facilities in your dining hall or restaurant and they are only in for that purpose and out immediately following, you do NOT need to request proof of vaccination.

  • Children under 12    
  • Patrons under 18 entering the indoor premises of a sports and recreational facility in order to participate in an organized sport ONLY   
  • Patrons with a medical exemption (must present ID AND written document) – must have written documentation from a doctor or nurse stating they are exempt for a medical reason from COVID-19 vaccination 
  • At weddings, funerals, rites, and ceremonies you do not need to show proof of vaccination if: The service is held in a meeting or event space and you are attending the wedding funeral, rite, or ceremony but not the social gathering (e.g., reception) 
  • The associated social gathering is held in a business licensed under the Funeral, Burial, and Cremation Services Act 


  • All provincial offence officers: by-law, police, public health inspectors, regulatory officers from ministries & agencies can enforce proof of vaccination 
  • Non-compliance by individuals and business can result in charges & fines   
  • Provincial offence officers may take a measured approach to enforcing orders that balance public safety, health, & other risks businesses owners are managing   
  • Starting this week, officers are visiting businesses and organizations to raise awareness of new proof of vaccination requirements   
  • The government will also provide information on tools and resources to help businesses and organizations implement the necessary COVID-19 safety plan measures – e.g., workplace violence & harassment measures   
  • In the event of harassment or threats of violence, contact law enforcement 

Links for more details and specifics:

If you have any concerns or questions that you are unable to find answers for in this article or in the links provided, please let us know and we will find the answers for you. NOTO would like to take a moment to thank our colleagues at TIAO for providing a thorough overview of these new regulations on their TIAO Industry Call and for keeping us updated on this topic.

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