Registrar’s Directive: Funeral homes and transfer services must implement a mandatory COVID-19 vaccination policy

Effective Sept. 10, 2021

This Registrar’s Directive requires that funeral establishments and transfer service operators implement a mandatory COVID-19 vaccination policy.

This directive goes into effect on Friday, Sept. 10, 2021. 

Vaccination policy

All funeral establishments and transfer service operators must implement a COVID-19 vaccination policy that requires its employees, staff, contractors, volunteers, students and interns to provide:

  1. Proof of full vaccination against COVID-19; or
  2. Written proof of a medical reason, provided by a physician or registered nurse that sets out:
    (i) A documented medical reason for not being fully vaccinated against COVID-19, and
    (ii) The effective time period for the medical reason; or
  3. Proof of completing an educational session about the benefits of COVID-19 vaccination prior to declining vaccination for any reason other than a medical reason. The approved session must, at a minimum address:
    (i) How COVID-19 vaccines work;
    (ii) Vaccine safety related to the development of the COVID-19 vaccines;
    (iii) The benefits of vaccination against COVID-19;
    (iv) Risks of not being vaccinated against COVID-19; and
    (v) Possible side effects of COVID-19 vaccination.
  4. An establishment may decide to remove the option set out in paragraph 3 and require all employees, staff, contractors, volunteers and students to either provide the proof required in paragraph 1 or 2.
  5. Where an establishment decides to remove the option set out in paragraph 3, the educational session referred to shall be made available to all employees, staff, contractors, volunteers, students and interns.
  6. Every establishment’s vaccination policy shall require that where an employee, staff, contractor, volunteer student or intern does not provide proof of being fully vaccinated against COVID-19 in accordance with paragraph 1, but instead relies upon the medical reason described at paragraph 2, or the educational session described at paragraph 3, the employee, staff, contractor, volunteer, student or intern shall:
    1. Submit to regular antigen point of care testing for COVID-19 (rapid test) and demonstrate a negative result, at intervals to be determined by establishment which must be at a minimum of once every seven days.
    2. Provide verification of the negative test result in a manner determined by the establishment that enables the establishment to confirm the result at its discretion.


The Province of Ontario has ordered mandatory COVID-19 vaccination policies for high-risk settings, such as hospitals, ambulance services, and long-term care facilities, to protect our most vulnerable.

The BAO has always considered funeral services as being high-risk environments because they involve attending those places, handling infected decedents, serving vulnerable seniors and hosting events in confined places that involve consoling, hugging, tears, runny noses. The bereavement sector was designated an essential service at the start of the pandemic, and has played a key role in ensuring that the sector maintains the capacity to deal with surges in death numbers.

Bereavement sector employers have a duty to protect the health and safety of their employees and the families they serve.

Accordingly, pursuant to the Registrar’s authority to consider risks to public and health and safety in the licensure of an establishment, the Registrar is directing funeral establishments and transfer services to implement a mandatory COVID-19 vaccination policy to protect their employees and the public from COVID-19 by Sept. 10, 2021.


Measures from the previous Registrar’s Directive remain in place:
Registrar’s Directive: Capacity limits removed; Physical distancing, mask-wearing requirements remain

The bereavement sector has continued to serve client families safely and with care and compassion throughout the pandemic. Supporting your employees to get fully vaccinated is a further extension of that care and compassion. 

Thank you for your ongoing commitment to the health and well-being of staff, their families, the bereavement sector and the community at large.

-Carey Smith, Chief Executive Officer & Registrar