Commercial landlords will be expected to verify requisite vaccinations of any building personnel, including contractors and subcontractors, who enter into premises that the Canadian government leases. Public Services and Procurement Canada (PSPC) has instructed subject landlords to submit attestations by October 29, approximately two weeks before the COVID-19 vaccination mandate for the federal public service comes into force on November 15.

As outlined, all workers who are directly or contractually under a commercial landlord’s oversight must confirm that they have received two doses of recognized valid vaccine in order to gain access to tenant space the federal government occupies. Landlords must certify that all such personnel comply and then continue monitoring and ensuring adherence. These obligations will also be included in all new leases that the federal government negotiates.

“This approach will ensure that federal workplaces and the buildings in which they are located are kept safe, and that all personnel who work in them are protected,” the PSPC advisory states.

There will be leeway for allowable exemptions, but commercial landlords will have to report the circumstances to federal facility managers as soon as they become known and receive approval. PSPC is pledging to post notices within its tenant spaces to reiterate requirements for building personnel, and it has promised to provide landlords with more details about how and where to submit attestations.

“PSPC’s landlords who do not provide the required attestation, or who are subsequently discovered to have provided a false attestation, may be subject to additional measures,” the advisory warns.