The Next Wave of COVID-19 Vaccination Requirements?

As the global community continues to manage the ever-evolving COVID-19 pandemic, countries have taken different approaches to addressing COVID-19 vaccinations. As we have discussed, Italy requires both public- and private-sector employees to possess government-issued health passes (i.e., the Green Pass) that demonstrate proof of (i) vaccination, (ii) a recent negative COVID-19 test result or (iii) recovery from COVID-19 in the six months prior to returning to the workplace. Although this measure stops short of requiring private-sector employees to receive COVID-19 vaccinations, it represents one of the world’s strictest COVID-19 vaccination requirements.

Generally, governments have not enacted or implemented measures that require all private-sector employees to receive COVID-19 vaccinations. A majority of countries have required, at most, that employees in public-facing roles in certain sectors (e.g., food and beverage establishments, gyms and fitness studios, and border control and COVID-19 frontline workers, as well as the healthcare, childcare and eldercare sectors) receive COVID-19 vaccinations.

Despite this general rule that governments have not required private-sector employees to receive COVID-19 vaccinations, there are exceptions. Saudi Arabia, for example, requires both public- and private-sector employees to receive COVID-19 vaccinations in order to enter the workplace. Similarly, in Indonesia, employers may allow only vaccinated employees to enter the workplace, except when employees (i) have recovered from COVID-19 in the prior three months or (ii) have received medical advice (evidenced by a doctor’s certificate) following a medical examination not to receive a COVID-19 vaccination. Also note that employers in Indonesia may issue a written warning to employees who do not comply with applicable COVID-19 prevention-and-control protocols. In addition, beginning October 18, 2021, every employee in the Dominican Republic must present a COVID-19 vaccination card evidencing that its holder has received two doses of a COVID-19 vaccine in order to enter an indoor workplace (but not an outdoor workplace). If employees in the Dominican Republic remain unvaccinated, they may enter the workplace only if they agree to receive a weekly PCR test, with seven days between each test. Finally, beginning October 21, 2021, Morocco will require all private-sector employees to be fully vaccinated against COVID-19.

We continue to monitor and analyze how countries are responding to the COVID-19 pandemic and how governmental actions affect employer–employee relations.