Vaccine certificate (passport) requirements and criteria for medical exemption

Advisory Alert

September 17, 2021

*Cette information est seulement disponible en anglais.

To: Local health system partners


Vaccine certificate (passports) and medical exemptions

The purpose of this Advisory Alert is to discuss the vaccine certificate (passport) requirements recently shared by the Government of Ontario and to review medical exemptions for the COVID-19 vaccine.

Launching vaccine certificate (passports) in Ontario

The Government of Ontario announced that, effective September 22, 2021, select settings* will require proof of vaccination for entry. Individuals will need to be fully vaccinated** (two weeks after a second dose) to enter select settings* and will be asked to provide proof of vaccination status (COVID-19 vaccine certificate or proof of medical exemption) along with valid identification. Requiring proof of vaccination aims to help slow the spread of COVID-19 and encourage every eligible Ontarian to get vaccinated, allowing us to protect our hospitals and support businesses. It is anticipated that, staring October 22, 2021, the Government of Ontario will provide an enhanced vaccine certificate, as well as a verification application, to give businesses the ability to read proof of vaccination via a QR code. For more details, read the Government of Ontario’s frequently asked questions backgrounder and additional guidance shared on September 14, 2021.

The select settings* are higher-risk indoor public settings where face coverings cannot always be worn. Proof of vaccination requirements will not apply to settings where people receive medical care, food from grocery stores, medical supplies, and other essential services. Aligned with public health and personal protective measures currently in place, indoor masking policies will continue to remain in place. Individuals who cannot receive the vaccine due to medical exemptions will be permitted entry with a doctor’s note until recognized medical exemptions can be integrated as part of a digital vaccine certificate. Children who are 11 years of age and younger and unable to be vaccinated are further exceptions to these requirements.

The Ministry of Health issued proof of vaccination guidance for businesses and organizations under the Reopening Ontario Act (PDF) on September 14, 2021. The document outlines baseline requirements with which specified businesses and organizations must comply. It also provides a definition for individuals who are considered fully vaccinated.

An individual is considered fully vaccinated (Government of Ontario, PDF) if they have received their final dose of one of the following options at least 14 days ago:

Medical exemptions to COVID-19 vaccination

There are likely to be few individuals with medical exemptions to COVID-19 vaccination. The largest group of individuals who receive a medical exemption will be those with severe allergic reactions or anaphylaxis to a previous dose and who have been assessed by an allergist/immunologist to review methods for possible (re)administration of a COVID-19 vaccine. In some cases, an allergist/immunologist may determine that the individual is unable to receive any COVID-19 vaccine and a medical exemption may be issued. Refer to the COVID-19 vaccination: allergy form (PDF) for more details.

Contraindications for Pfizer, Moderna, and AstraZeneca vaccines include hypersensitivity to the vaccine, any ingredients of the vaccine, or components of its container (Pfizer product monograph (PDF); Moderna product monograph (PDF); AstraZeneca product monograph (PDF)). An authorized COVID-19 vaccine should not be routinely offered to individuals who are allergic to any component of the specific COVID-19 vaccine or its container. Such individuals require an assessment by an allergist/immunologist to determine whether the vaccine is contraindicated or may be safely administered under controlled conditions supported by the allergist/immunologist. A medical exemption may be issued if the allergist/immunologist determines that the individual is unable to receive any COVID-19 vaccine. For a comprehensive list of components in each authorized COVID-19 vaccine and its container, please consult the corresponding product leaflet or information contained within the product monograph available through Health Canada’s Drug Product Database.

Other contraindications to the COVID-19 vaccine include:

Consult the latest National Advisory Committee on Immunization (NACI) recommendations on the use of COVID-19 vaccines through the NACI website or view ingredients of authorized COVID-19 vaccines that have been associated with allergic reactions in other products.

The Ministry of Health’s guidance on Medical Exemptions to COVID-19 Vaccination (PDF) contains a user-friendly table that summarizes conditions and/or adverse events following immunization that may qualify for a medical exemption to COVID-19 vaccination.

Medical exemption documentation

Notes for medical exemption should indicate that there is a medical reason for the individual’s exemption from being fully vaccinated against COVID-19, including the reason for the exception to COVID-19 vaccination, clear medical information that supports the exemption and the effective time period (permanent or time-limited). In some instances, the medical reason for the person not being vaccinated may be time-limited (for example, timing around a procedure or other medical treatment).

Administering COVID-19 vaccines with other allergies

There are existing protocols to administer COVID-19 vaccines to individuals with other types of allergies, as noted in the Ministry of Health’s Vaccination Recommendations for Special Populations (PDF). These other types of allergies do not on their own constitute grounds for a medical exemption. For example:

If additional support is needed, referral and consultation support for Physicians and Nurse Practitioners is available through Ontario’s eConsult Service and OTN Hub, or the Special Immunization Clinic (SIC) Network. More information about medical exemptions can be found in the Vaccine Information Sheets and Special Populations Document (PFD) available on the Ministry of Health’s website. Also, the College of Physician’s and Surgeons website contains COVID-19 FAQs for physicians to guide your practice. Medical exemptions are expected to be infrequent and should be supported by expert consultation.

Additional information

For more information on the COVID-19 vaccines, as well as for specific answers to your frequently asked questions visit our FAQ web page or call Public Health Sudbury & Districts at 705.522.9200 (toll-free 1.866.522.9200).



Original Signed By

Dr. Penny Sutcliffe
Medical Officer of Health and Chief Executive Officer

NOTE: All Advisory Alerts are found on our website.

*These select settings are higher-risk indoor public settings where face coverings cannot always be worn and will require proof of vaccination:

These mandatory requirements would not apply to outdoor settings where the risk of transmission is lower, including patios, with the exception of outdoor nightclub spaces given the risk associated with the setting.

**An individual is considered fully vaccinated (Government of Ontario, PDF) if they have received their final dose of one of the following options at least 14 days ago:

This item was last modified on September 17, 2021