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Policy for Mandatory Vaccination: Canada and the Mission Network

Table of contents

Policy context and scope

This policy has two chapters which must be read in conjunction with one another.

Chapter 1 is the policy approved by the Treasury Board for the Core Public Administration.  This chapter will apply to all Global Affairs Canada’s (GAC) indeterminate and term employees, casual, student, secondment, volunteers, interchange staff in Canada and GAC employees abroad who are not part of Canada’s diplomatic and consular mission network.

Independent contractors in Canada will be subject to guidance issued by Public Services and Procurement Canada as per their contract terms.

Chapter 2 is the policy approved by the Deputy Minister of Foreign Affairs, addressing those areas specific to her accountability for Canada’s diplomatic and consular mission network.

Chapter 2 applies to:

Chapter 2 does not apply to:

The application of Chapter 2 to honourary consuls and their staff is awaiting further clarification.

Requirements for mandatory vaccination for Canada-based and locally engaged staff (Chapter 1 or 2) apply without regard to duty location or work arrangement (e.g. telework, remote work, work outside of the mission premises).

Policy Statement

All persons who fall within the scope of both Chapter 1 and Chapter 2 are required to be fully vaccinated against COVID 19 and maintain that status.

Managers in Canada and Heads of Mission abroad are to ensure compliance with this policy, as per the parameters of their applicable chapters, including the authorization of any exceptions for the unable to be vaccinated. Those persons unable to be vaccinated, so confirmed by their managers in Canada or the Head of Mission according to the requirements of this policy, will be deemed compliant and subject to a rapid-testing program.

The Assistant Deputy Minister of Human Resources will monitor this policy and report on its effectiveness to the Deputy Minister of Foreign Affairs, via the ADM COVID 19 Committee.

Authorities for missions and the network abroad

The Minister of Foreign Affairs has the legislative authority for the administration of the foreign service, coordinating the direction given by the Government of Canada to heads of missions, and the management of diplomatic and consular missions (DFATD Act par. 10 (2) (g, h and i)). As the Minister’s deputy, the Deputy Minister of Foreign Affairs may exercise the powers, functions and duties of the Minister in this regard.

The Deputy Minister of Foreign Affairs employs locally-engaged staff at missions abroad (Locally-Engaged Staff Employment Regulations), and has been delegated authority from Treasury Board with respect to locally-engaged staff terms and conditions, and related policy instruments (TB Policy for staff engaged locally outside Canada, Locally-Engaged Staffs' Terms and Conditions Regulations).

Heads of Mission have the management and direction of their mission and its activities and the supervision of the official activities of the various departments and agencies of the Government of Canada in the country or portion of the country or at the international organization to which they are appointed. (DFATD Act, subsection 15 (2)).

The Memorandum of Understanding on Operations and Support at Missions (April 2021) lays out the requirements for adherence by all federal and provincial organizations that are part of the diplomatic and consular mission network to Government of Canada and GAC directives, norms, policies and standards applicable to missions (Sections 5 and 6) for all staff and dependants at missions.


This policy has been recommended by the ADM COVID 19 committee and approved by the Deputy Minister of Foreign Affairs. This policy is expected to be reviewed periodically as the framework for the core public administration and the global environment evolves.

Effective dates:

This policy is effective on 6 October, 2021. Compliance with this policy is mandatory by November 15 2021. Note: the timing of mission network implementation and compliance is subject to the availability at each mission of vaccines and rapid testing kits.


“Fully vaccinated” under Chapter 2 of this policy refers to COVID-19 vaccines approved for emergency or ongoing use by the World Health Organization (WHO).

People are considered fully vaccinated 14 days after they have either:

Vaccines on the World Health Organizations Emergency Utilization List can be used to meet the definitions of non-Health Canada authorized and fully vaccinated above.

Definitions will be adjusted if and as required when the National Advisory Committee on Immunization (NACI) makes any future recommendations. Where a host-government authority has mandated a vaccine that is not WHO listed, inclusion may be considered, based on medical advice to the Deputy Minister of Foreign Affairs or her delegate.

Tracking and Privacy

While protecting the privacy of individuals in accordance with existing privacy frameworks including the Privacy Act, human resource officers, managers in Canada, Heads of Mission and relevant officers at mission shall be made aware of the vaccination status of all persons to whom this policy applies.

Managers in Canada and Heads of Mission (or authorized delegate) shall also review and validate all vaccination attestations and any request for accommodations (see Chapters 1 and 2 for additional guidance on attestation and accommodations).

Given the inability of approx. 80% of persons at missions to use the standard system for the core public administration (GC-VATS) for vaccine attestation/accommodation requests, all persons to whom Chapter 2 applies will be required to attest their vaccination status using a simple cloud-based form developed for that purpose.

While there may be some minor duplication of effort for the approx. 20% abroad who are Canada-based federal staff and who will also have to attest in the GC-VATS designed for the core public administration, this mission-level form will allow Heads of Mission to be provided an integrated report for all persons at their mission to whom Chapter 2 applies.  In time, there may be a way to automatically reconcile the attestation systems and reporting, but that is not possible in the immediate term.

Specific information on the attestation procedure, reporting requirements, attestation by an employee on behalf of other employees without access to the internet, and timelines for attestation and reporting will be sent to missions in due course.

Missions are required to report attestation results to HQ human resources authorities for the purposes of monitoring compliance and to highlight specific cases where there is are follow up actions for exceptions, accommodation or non-compliance.

Chapter 1: Framework for Implementation of the Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police


The Treasury Board Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police (Policy on Vaccination) became effective on October 06, 2021.

This framework, intended to complement the Policy on Vaccination, is an evergreen document, and will evolve as science and public health guidance evolve.

Timeline for implementation and compliance

October 6, 2021 – Effective Date of the Policy on Vaccination

October 6, 2021 to October 29 – Attestation Period

October 29, 2021 until November 14, 2021

November 15, 2021 – Full Implementation Date of the Policy on Vaccination, or 2 weeks following the “Attestation Deadline” as defined in Appendix A of the Policy on Vaccination

Key considerations

Vaccination Attestation Requirement


Required Training Session

Working Abroad


When collecting personal information for the delivery of this program, institutions are reminded to ensure they respect the following legal and policy requirements:

Direct Collection

Section 5 of the Privacy Act requires that wherever possible, personal information should be collected directly from the individual. As such, vaccination status of public servants should be collected from the employees themselves and not via provincial or territorial authorities.

Safeguards for Uses and Disclosures

As per Section 6.2.19 and 6.2.20 of the Directive on Privacy Practices, institutions must identify which positions or functions in the program or activity have a valid reason to access and handle personal information and limit access to and use of, personal information by administrative, technical, and physical means. Measures should be taken for minimal intrusiveness, such as:

Retention Schedules

As per section 4 of the Privacy Regulations, with some exceptions, personal information shall be retained for a period of at least 2 years following the last time it was used for an administrative purpose, such as determining access to the workplace.

Privacy Notice Statement

As per section 6.2.9 of the Directive on Privacy Practices, a privacy notice is required. It should include the purpose and legal authority of the collection; any uses or disclosures associated; the consequences for refusal; the right to access and correct any personal information collected; and the right to complain to the Privacy Commissioner regarding the handling of the information.

Duty to accommodate (for employees unable to be vaccinated)

Nothing in this framework supersedes the Directive on the Duty to Accommodate. The employer has a duty to accommodate individuals’ needs when those needs relate to one or more of the prohibited grounds of discrimination under the Canadian Human Rights Act, up to the point of undue hardship. In the case of vaccines, this could include:

Deputy heads are responsible for:

Deciding if the duty to accommodate applies

Step 1: Requesting accommodation when unable to be fullyvaccinated
Step 2: Gathering relevant information

Supporting documentation:

Step 3: Making an informed decision

Implementing accommodation when warranted

When the manager decides that the duty to accommodate applies, accommodation must be provided up to the point of undue hardship. Given the public health considerations, the choice of accommodation should also ensure the safety and security of the workplace, along with privacy obligations.

The following are recommended accommodation measures:

Step 4: Implementation

Managers must promptly advise employees of the decision, the rationale for the decision, the accommodation to be provided, if applicable, and the steps that must be taken to implement it:

Step 5: Recordkeeping

Partially vaccinated employees

The Policy on Vaccination and framework will provide flexibility to employees demonstrating willingness to be vaccinated, and who have taken concrete steps to do so.

Employees unwilling to disclose their vaccination status or who choose not to be fully vaccinated

Timeline for Compliance

Effective date of the Policy on Vaccination (October 6, 2021):
Step 1: Advise employees of consequences of not meeting the vaccination requirement
Attestation Deadline (October 29, 2021, or 2 Weeks After the Attestation Deadline as defined in Appendix A of the Policy on Vaccination):
Step 2: Attestation period
Full Implementation Date of the Policy on Vaccination (November 15, 2021) or 2 weeks following the “Attestation Deadline” as defined in Appendix A of the Policy on Vaccination:
Step 3: Mandatory Testing for those unable to be vaccinated and who must report to work on-site
Step 4: Consequences begin

Employees are placed on leave without pay and the employer stops assigning employees hours of work.

Chapter 2: Complementary issues under the authority of the Deputy Minister of Foreign Affairs, not covered by Chapter 1

The context of the diplomatic and consular mission network

Canada’s missions are operationally essential for the management of Canada’s global relationships and services to Canadians, including their physical presence in a host country. During the pandemic, missions have maintained that physical presence at higher levels than most departments in Canada.

Some persons at the mission may be unable to be vaccinated because of age, medical, religious or vaccine supply issues. The stakeholders and visitors with whom the mission has to engage may also be unvaccinated.   The risk environment outside of Canada can change rapidly. Many circumstances we take for granted in Canada, in the context of mission network, are beyond the control of the Government of Canada and the direct support of Canadian medical services.

The risks of COVID 19 and COVID 19 transmission, even for the fully vaccinated, are globally too complex to manage without the full application of a baseline of mandatory vaccination for all persons who are part of the diplomatic and consular mission network.

The ability for the department and provincial health care systems to directly support emergency medical conditions for Canada-based staff and their families abroad is extremely limited, especially in the COVID environment.  Locally engaged staff may not have access to adequate medical support.  Exceptions to universal mandatory vaccination for all persons who are part of the diplomatic and consular mission network abroad, must also be extremely limited – so as to help protect those unable to be vaccinated and to maintain the integrity of our operations abroad.

Because there are so many factors beyond the control of the department, to ensure operational effectiveness, missions are also required to maintain supplementary infection prevention measures (as per health authority guidance) in order to help mitigate risk.

In that context, the broadest possible baseline vaccination regime is necessary for all missions to ensure the health and safety and basic viability of Canada’s operations abroad, given the degree of globalized risk and the speed of change in the pandemic.

The increasing requirements for full vaccination applied by many governments for travelers to board aircraft and other means of public transportation also have an impact on the need for mandatory vaccination.

Consequently, mandatory vaccination forms part of the terms and conditions of employment, where permitted by law and/or as a condition of assignment abroad.  Mandatory vaccination requirements are also subject to the applicable obligations for accommodation for those unable to be vaccinated.

Consequences for non-compliance with this policy

The following are the measures for non-compliance with this policy, subject to the applicable requirements for mandatory training and notifications prescribed in Chapter 1:

Subsequent Compliance with this policy

Unable to be vaccinated and accommodation abroad

Where medical or religious objections to vaccination have been put forward by a person to seek an exemption from this policy (unable to be vaccinated), Heads of Mission (or delegate) are to ask for the person to provide a written justification for exemption and associated recommendations for accommodations from the employee’s medical professional or religious advisor.  For CBS at mission also subject to attestation in GC-VATS, that application should be used instead for accommodation request details and permissions.

Further guidance on CBS attestation and the Treasury Board policy on accommodation/approval process can be found in Chapter 1 and in the Return to Work policy of Global Affairs Canada.

Under Canadian law, an employer would not have an obligation to accommodate employees who do not have substantiated medical or religious grounds, but who are simply unwilling to be vaccinated.  

The ability for Global Affairs Canada to accommodate a person’s needs at missions may be more limited than the forms of accommodation that could be offered in Canada, based on various factors at a given mission.

For CBS, a change to the assignment resulting in a repatriation back to Canada may then be the appropriate accommodation, if viable alternative mitigations are not possible. 

For an LES, an end to the employment relationship, if no other suitable substantive duties or working arrangements can be found locally, might eventually be appropriate given that they cannot be offered a different assignment nor repatriation.

In all applicable cases, accommodations must be considered.  If not possible, the reasons why accommodation cannot be made must be fully documented before a decision is taken by the relevant authorities as per existing assignment, contracting and employment frameworks. 

Local legal advice on these issues will be sought as per Annex A – methodology for LES policy application, with guidance from the LES Bureau - HLDS. 

For cases involving CBS, please contact the Labour Relations bureau – HWL/HWH.

Methodology for LES policy application, mission by mission

While the default approach will be in almost all case to apply mandatory vaccination for all LES at the mission including the use of state immunity if so required, issues of regular vaccination and testing supply, local legal issues as well as limits to accommodation will guide the practical approach used for each mission in the application of mandatory vaccination for LES.

Heads of Mission are to follow HLDS policy guidance in the application of this methodology, see Annex A below.

Heads of Mission in partnership with HLDS and supported by JUS/JLA will seek local legal advice on the ability of the employer to ask for employee vaccination information, local privacy requirements, employer vaccination mandates, changes to terms and conditions of employment, and administrative/disciplinary measures as a result of non-compliance. This advice along with operational realities will contribute to the risk analysis for guiding the local LES implementation of this policy using the standardized methodology.

Mitigation measures abroad

Health and safety and operational risk mitigation measures, in addition to mandatory vaccination, can include:

If no regular supply and distribution of vaccines, testing, and authorized booster shots for new arrivals/eligible family members and new local hires

If there is no regular supply or a disruption to the distribution of vaccines and rapid testing kits, the application of the mandatory policy to be fully vaccinated at missions may have to be temporarily modified or suspended until a regular supply is secured.

This means managing the exceptional level of risk until the situation can be normalized.  Compliance is still required as quickly as practical.  Mandatory vaccination is at the core of the safety-risk strategy abroad, with other risk-mitigation measures supplemental to a broad baseline of full vaccination.

A delivery frequency of twice or three times per year to missions is being planned, subject to a confirmation of vaccine and test-kit supply.  This means that during the gaps between deliveries, some new hires, new independent contractors or dependants who have reached the qualifying age may not be vaccinated for several months if they rely on a GAC delivery and there is no other stock on hand.

While the solution in many cases will be in-country sources for the vaccine or travel to a neighbouring mission, there will be some outlying missions where vaccines can only be secured via a GAC delivery.

In the situation of no available supply of vaccines, this policy permits up to a six-month period with the corresponding infection prevention measures in place along with evidence that all reasonable efforts are being made to come into full compliance before other consequences for non-compliance will be considered.

In the case of lack of vaccine supply at the mission, maximum infection prevention measures are to be used in combination with enhanced flexibility for work outside of the mission premises.  These mitigations are only meant to be a short-term risk-management solution and are not to be used as a long-term strategy to manage the safety risk. The long term strategy starts with universal network-wide full vaccination.

Children under 12 abroad

Vaccine supply plans from Canada will include children under the age of 12 when vaccines for this age group are approved by Health Canada.

Certification documentation of fully vaccinated abroad

While employee attestations (subject to managerial approval, audit and potential administrative or disciplinary action for false attestations) will initially be accepted as proof of full vaccination status, missions may also require certified documentation from locally engaged staff and foreign independent contractors (e.g. host-government vaccination passport) where it is available.

Personal information collected under this policy will be kept private and shared only as necessary and on a need-to-know basis for the implementation of this policy in accordance with privacy requirements, including the Privacy Act where applicable.

Questions or clarifications

Questions or clarifications related to this policy are to be addressed to HFD, HED and/or HWD for CBS issues, HLD for LES issues and AAO for mission contractor issues.

Annex A: Mandatory vaccines for LES at mission - HOM decision matrix

Text version

This Decision Matrix is Annex to and follows the policy requirements established in the GAC Policy for Mandatory Vaccination.

Date Modified: