The government of Canada recently announced that effective October 30, 2021, a mandatory vaccine policy will be implemented requiring all travellers to be fully vaccinated before boarding planes, trains or marine vessels.¹ Specifically, all travellers (ages 12 and up) departing from Canadian airports, trains and cruise ships must be fully vaccinated in order to travel. This includes air passengers traveling on domestic, trans-border, and international flights departing from airports in Canada.
Travellers who are in the process of being vaccinated will have a grace period – until November 30, 2021 – during which they will be able to travel if they show a valid COVID-19 molecular test within 72 hours of their scheduled departure.
Alternatively, travellers can show a positive COVID-19 molecular test if at least 14 days, but no more than 180 days, have passed since the test was conducted.
The Canadian government is implementing this new policy with the goal of limiting the spread of COVID-19 across Canada and limiting future outbreaks.
WHY THIS MATTERS
Employers and globally-mobile employees need to be aware of this new policy as it will have a significant impact on the transportation options available to unvaccinated travellers seeking to exit Canada.
Vaccine Requirements for Travellers
By November 30, all travellers within Canada must be fully vaccinated. Some individuals may be exempt from these requirements in limited circumstances such as emergency travel or if an individual is medically unable to be vaccinated.
Transport Canada has indicated that unvaccinated foreign nationals who normally reside outside of Canada, and who entered Canada prior to October 30, 2021, will be allowed to depart Canada with a valid COVID-19 molecular test until February 28. This transitional measure will not apply to domestic flights.²
To board a flight, travellers (ages 12 and up) must:
- have received at least 2 doses of an accepted COVID-19 vaccine or a mix of two accepted vaccines; or at least one dose of the Janssen/Johnson & Johnson vaccine;
- have received their second dose at least 14 days prior to their travel date;
- have no signs or symptoms of COVID-19; and
- be prepared to show proof of vaccination for their trip.³
The Canadian government has indicated that those who falsify information or fail to comply with these requirements will face serious consequences, including significant monetary penalties.
A standard digital Pan-Canadian proof of vaccination for international travel is currently being developed by the government and will be used to facilitate travel once it is available.
Impact on Travellers within Canada
Requiring travellers to be fully vaccinated may have several implications for employers and employees alike, raising several questions. While we await further details from the Canadian government, below is a number of key issues that travellers should consider.
- Following the transition period, and starting November 30, those taking a connecting flight from within Canada will not be able to board their connecting flight to reach their final destination in Canada if they enter as a non-vaccinated individual. For example, if an unvaccinated traveller flew from the United States to Vancouver, British Columbia, and needs to take a connecting flight to Kitimat, British Columbia, he or she may not be able to do so.
- The option of exiting Canada by land via private vehicle is still available to those who are eligible to enter the United States.
- Travellers entering Canada that are vaccinated with a vaccine not approved by Canada may have the option of getting re-vaccinated in Canada with an approved vaccine.
- Unvaccinated business travellers who are authorized entry to Canada by the government of Canada will be allowed to depart Canada with a valid COVID-19 molecular test. While these individuals are required to complete the mandatory 14-day quarantine, they can request an exemption from quarantine upon entry to Canada.
The information provided above is general in nature as there are limited details currently available on the new requirements, KPMG Law LLP will continue to work with government officials to gather more details and share them once available.
Employers and employees who have questions about the vaccine requirements are encouraged to contact their qualified immigration counsel, employment counsel or KPMG Law LLP for further guidance.
1 See "Mandatory COVID-19 vaccination requirements for federally regulated transportation employees and travellers" on the government of Canada website.
2 October 29 Transport Canada news release, “Government of Canada provides further details on new vaccine requirements.”
3 See “COVID-19 Boarding flights and trains in Canada” on the government of Canada website.
* Please note that KPMG LLP (U.S.) does not provide any immigration services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.
The information contained in this newsletter was submitted by the KPMG International member firm in Canada.
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