Mandatory COVID-19 Vaccination for Many Manitoba Front-Line Employees

On August 24, 2021, the Province of Manitoba announced that it will require all provincial employees who work with vulnerable populations to be fully immunized for COVID-19. Employees who are not immunized or who cannot provide proof of full immunization will be required to undergo regular testing.

In accordance with the Province’s announcement, provincial public employees who work with vulnerable populations will include the following individuals:

  • direct health-care providers and workers, including but not limited to physicians, nurses, allied health professionals, support service staff and others deemed appropriate for each site/area/program in public and private health-care settings;
  • educational workers including teachers, school and educational support staff, practicum students, bus drivers and custodial staff;
  • child-care workers including staff and practicum students working in licensed early learning and child care facilities;
  • public servants and funded-agency employees who work in high-risk settings with direct, ongoing contact with the public or clients; and
  • Manitoba Justice employees who work with vulnerable people and in correctional facilities.

By October 31, 2021, provincial public employees who work with vulnerable populations will be required to be fully immunized and provide proof of vaccination, or otherwise undergo regular testing. Full immunization means an individual has received all doses of either an approved two-dose or single-dose COVID-19 vaccine, and two weeks have passed since the final dose was administered. A worker must receive their first dose by September 7, 2021, the start of the school year, and their second dose by October 17, 2021.

Employees must additionally provide proof of vaccination, which will include the digital or physical Manitoba Immunization Card, or a secure printed provincial immunization record from either public health or the Shared Health online portal.

In turn, provincial public employees who work with vulnerable populations, and who are not fully immunized or cannot provide proof of vaccination, will be required to undergo regular COVID-19 testing. Employees will be further required to provide proof of a negative test result before they can return to work. Full-time employees, for instance, may be required to undergo testing up to three times a week. As employees may choose to undergo regular testing instead of receiving the vaccination, the Province indicated that full immunization is not a condition of employment.

Similar rules will apply to all government staff in the Legislative Assembly and Members of the Legislative Assembly.

Dr. Brent Roussin, Manitoba’s chief provincial public health officer, further indicated that, “public health officials also recommend that private businesses and organizations follow the province’s lead and consider mandating COVID-19 vaccination for their employees to protect their customers and staff, and to reduce the chance of an outbreak at their workplaces.” Accordingly, private employers may consider the Province’s guidance when developing their own approach to vaccination requirements.


On August 27, 2021, Dr. Roussin reiterated his recommendation for private businesses to consider mandating vaccinations for their employees. Dr. Roussin further indicated that the Province is still working on the details for administering the rapid testing required of employees who work with vulnerable populations and who choose not to be vaccinated, such as selecting the rapid test to be administered, the testing venue and who will be administering the test. The Province also provided further information on the new public health measures earlier announced relating to indoor mask use and events/activities accessible only to fully vaccinated Manitobans. The new measures are summarized in our blog MB Caution Yellow: Province Announces New Public Health Measures.

For more information on mandatory COVID-19 vaccination for federal workers, see our blog Canada to Require COVID-19 Vaccinations for Federal Workers.

Employers who are directly impacted by this announcement, and those who wish to discuss their vaccination strategy, should contact a member of our labour and employment team for further advice.

Note: This article is of a general nature only and is not exhaustive of all possible legal rights or remedies. In addition, laws may change over time and should be interpreted only in the context of particular circumstances such that these materials are not intended to be relied upon or taken as legal advice or opinion. Readers should consult a legal professional for specific advice in any particular situation.