COVID-status certification: introducing vaccine passports

The UK’s world-leading vaccination programme has played a crucial role in helping England move to and remain at Stage 4 of the roadmap. However, cases have risen significantly in recent weeks with the return of schools and firms introducing hybrid working patterns. The government’s winter Plan B has kept open the option of introducing certain measures should infections rise to levels which threaten to put unsustainable pressure on health services. This includes introducing mandatory COVID-19 Status Certificates in certain environments:

• All nightclubs and other venues open after 1am with alcohol, music and dancing
• Indoor events with 500 or more attendees where those attendees are likely to stand and mix to a significant degree, or move around during the event, such as music venues or large receptions
• Outdoor, crowded settings with 4,000 or more attendees where those attendees are likely to stand, or move around during the event, such as outdoor festivals
• Any settings with 10,000 or more attendees, such as large sports and music stadia.

The CBI has engaged with its membership, assessing the potential impacts of mandatory COVID-19 status certification in a Plan B scenario for businesses and their operations. The CBI also responded to the government’s call for evidence to inform the COVID-Status Certification Review in March.

Businesses recognise the role certification could play as a COVID-19 secure tool in building confidence, managing risk and controlling the spread of infection in large venues. Business also recognises the potential for this scheme to help incentivise vaccination in any cohorts where uptake rates are low. However, the potential pace of introducing a mandatory COVID-19 status certification scheme – with potentially as little as one week’s notice before it comes into force - fails to acknowledge the time needed to implement it in practise.

The CBI has set out some key areas it would like the government to urgently clarify:

• The government should publish the metrics that will trigger the scheme’s introduction, as well as the final regulations and detailed guidance no less than two and ideally four weeks before the scheme is launched.
• The government should publish business-specific legal counsel as a matter of urgency to help firms prepare in the best way possible.
• The government should provide clarity on its success measures for the scheme, and the criteria that will trigger its introduction, withdrawal and/or phasing-out.

The CBI has set out some key practical challenges with certification where government and business will need to work closely together to ensure a successful rollout of any scheme

The CBI members are united in their belief that the introduction of any prospective scheme should be done in partnership with the government and other stakeholders, to maximise confidence and minimise confusion.
In conversations with the CBI, firms have raised some practical challenges and questions with the scheme based on the draft proposals:

1. Ensure the scheme is operable as soon as mandatory certification comes into force
2. Provide further clarity where some venues and events may be borderline in-scope for mandatory certification
3. Raise public awareness of mandatory certification
4. Ensure consistency of enforcement by local authorities across England
5. Ease the burden of certification on business operations by providing detailed guidance on the policy ahead of launch
6. Monitor the impact of changes to the NHS COVID Pass on voluntary certification schemes
7. Provide clear forward guidance on any changes to the role booster vaccines will play in certification
8. Widen the recognition of overseas vaccination proofs to keep large venues and events open to international audiences.

Read the full submission here.

If you would like to discuss this work in further detail, please get in touch with Ed Richardson.