Covid-Status Certification Contents

1The Government’s review and the purpose of Covid-status certification system


1.The Government, in its COVID-19 Response Spring 2021 Roadmap, committed to reviewing the potential use of Covid-status certification.1 On 15 March 2021, the Government launched a review into the use of Covid-status certification to help “handle COVID-19 from summer onwards”. The objective of the review was to consider whether “COVID-status certification could play a role in reopening our economy, reducing restrictions on social contact and improving safety”.2 In correspondence with the Committee, the Rt Hon Michael Gove MP, Chancellor of the Duchy of Lancaster and Minister for the Cabinet Office, (the Minister), committed to setting out the conclusions of the review ahead of step 4 of the Government’s roadmap, which would be no earlier than 21 June, and to appearing before the Committee at that point.3

2.In response to the Government’s announcement that it was considering introducing Covid-status certificates for use in the UK, the Committee undertook this inquiry to consider the implications of, and concerns surrounding, the potential introduction of such a certification system. The Committee took evidence in public and received over nine thousand written submissions, an unprecedented number for a House of Commons inquiry. Due to the Government’s timetable for this Review and the unprecedented volume of evidence received, we have been unable to publish all evidence before the publication of this report, as would normally be the case. We will endeavour to process each submission as quickly as possible.

The timeline of consideration of a Covid-status certification system

3.When asked about how long the idea of Covid certification had been under consideration by the Government, the Minister told us:

It has been under consideration now for a few months because we recognise that the example of Israel—a country that introduced a green pass certificate system—provided the potential for this country to be able to open up more of the activity that had been necessarily restricted in order to reduce the spread of the virus.4

4.The Government has, however, discussed the use of certification at various points prior to this review. It was reported in September 2020 that the Government’s “moonshot” plan would involve Covid-free passes.5 In November 2020, it was reported that the Vaccines Minister, Nadhim Zahawi MP, had said that “immunity passports” may be needed before entering hospitality and sports venues.6 It was also reported at this time that Baroness Harding, Head of the NHS Test And Trace programme, was looking into including immunity passports as part of the NHS Covid-19 App.7 However, the following day, when asked about passports, the Minister responded that “I certainly am not planning to introduce any vaccine passports and I don’t know anyone else in government who is.”8 On 7 February, Minister Zahawi then ruled out “vaccine passports”, saying that, as vaccines are not mandatory, the introduction of certification would be “discriminatory”.9 The following week however, Rt Hon Dominic Raab MP, Secretary of State for Foreign, Commonwealth and Development Affairs, said that Covid passports were under consideration for use at “the international, domestic or local level”, only for the Secretary of State for Health and Social Care, Rt Hon Matt Hancock MP, to say the following day that Covid passports for domestic use “is not anything we are planning to introduce here.”10

5.The Minister, when asked about whether there had been consideration prior to his review, said:

There certainly have been debates about what the best way might be of allowing venues in which people inevitably mix socially to reopen, so there will have been consideration at different times of what the testing protocols might be or what other regimes might be in place in order to ensure that people can congregate in as safe a way as possible.11

6.The Minister committed to providing the Committee with “the best available timeline of when different options were considered during the course of our evolving response to the pandemic”.12 This timeline was not provided to the Committee prior to agreement of this Report.

7.It is clear that the idea of certificates has been under consideration within government for at least six months. Ministers and officials have given conflicting statements on the possibility of certification being introduced as a measure, and on the extent to which proposals were actively under review. At times, these statements have been directly contradictory. At the very least, this demonstrates a lack of coordination and effective interworking between different departments and teams in the Government’s response to Covid. On at least two occasions, a Minister has said that certificates were actively being considered, only for the suggestion to be immediately denied by another Minister. Given that the review into the potential use of Covid-status certification was subsequently launched, this indicates either that several senior members of the Government were unaware of the Government’s policy direction in this area, or there was an effort to downplay to the public the seriousness with which the introduction of a Covid-status certification system was being considered. Either way, the Government’s approach to certification has risked damaging trust in government and in the measures put in place to tackle the pandemic.

The purpose of Covid-status certification system

8.The first question that must be answered in relation to any proposals for a Covid-status certification system is what is the purpose of introducing such a system. This was a point emphasis to us by both Professor Jonathan Wolff, the Alfred Landecker Professor of Values and Public Policy at the University of Oxford, and Rt Hon David Davis MP.13 The key questions are:

9.Professor Melinda Mills, Professor of Demography at the University of Oxford, emphasised the importance of getting clear answers to these questions, as well as how certification would achieve the purposes of the introduction of such a system. She highlighted that the review she had chaired for the Royal Society had identified the purpose of such certificates system as being “to aid the return to pre-COVID-19 activities and allow travel without compromising personal or public health”.14 Another review of this policy area conducted by the Ada Lovelace Institute has similarly set out the purpose of introducing such as system as being “to allow differential access to venues and services on the basis of verified health information relating to an individual’s COVID-19 risk, and would be used to control the spread of COVID-19”.15 Professor Mills explained that certificates could be used for access to or reduction of restrictions internationally for travel, or domestically for access to large sporting or entertainment events, small events such as weddings and funerals, or businesses such as restaurants, pubs or supermarkets.16 So a further key question is:

10.In setting up the review, the Government said that certification was being assessed to see if it could help reopen the economy, reduce restrictions and improve safety. When asked what the problem to which the Government believes certification is the solution, the Minister said:

certification can be a tool that means we reduce the risk of transmission and make venues and activities safer… What it does do is dramatically reduce the risk. If one can have confidence that people in a venue have been vaccinated, or have immunity in another way or have recently received a valid test that confirms their negative status, you know that that venue will be safer.17

11.In addressing what a Covid-status certification system would cover, the Minister acknowledged that the Government had pre-empted the conclusion of its review by including a function in the general NHS app, rather than the specific NHS Covid-19 app, whereby vaccination status could be displayed for the purposes of international travel (see paras 75–79). He also confirmed that were certification to be introduced for domestic purposes such a system would be introduced England-wide, rather than regionally (i.e. not tied to local restrictions, tiering etc.).18 He expressed a preference that such a system would be UK-wide, but conceded that the decision in relation to the devolved nations would rest with the relevant administrations. He said:

We have been talking to the other devolved administrations about the approach that we would take. The devolved administrations to be fair to them—and if I have anything wrong in characterising their position I am sure that they will be in touch—broadly, the Welsh Administration sees a lot of merit in working closely with the approach that we have taken, but they want to come in behind and they want to see slightly more evidence of the efficacy of the approach that we have been taking. The Scottish Government does believe in the potential for domestic certification to play a role, but they take a slightly different approach towards the potential delivery of it. In the meantime, we are working towards an agreed approach towards paper-based recognition of vaccination and testing.19

12.In terms of the types of locations, venues and events that would be included in any such system, the Minister could not provide details. However, he told us that there were places that would have to be excluded from any such system, due to their use being “essential”, stating that such premises included “a Jobcentre, a library, essential retail, Government offices and so on. I don’t think it would be right or wise under any circumstances to require certification for those”.20 When asked if certificates would be used for travel on planes, trains and buses around the UK, he said:

One of the things that we were thinking about with venues is that if you have a requirement that someone has Covid-status certification before going to a particular event, and that event is one that is likely to lead to people congregating significantly, that is one way of reducing risk. No, we are not envisaging having it on corporation buses, on the Underground or such like.21

13.The Minister also indicated that the Prime Minister had already ruled out the inclusion of smaller venues such as standard bars and restaurants.22 The two venues that the Minister did identify as being places where a Covid-status certificate may be required for entry were nightclubs and large sports events such as premier league football matches.23

14.As Professor Wolff explained, the logic behind the Government’s position appears to be that a Covid-status certificate tells you if someone is vaccinated or tested, and on the basis of this information whether they are ‘safe’, either because they do not have the virus and cannot pass on any infection or have a dramatically lower chance of doing so, and so they can go to public places.24 This tallies with what the Minister told us, when he said the purpose of introducing a Covid-status certification system was to make venues safer. The question that Professor Wolff and others raised, however, was whether the certificate system actually does achieve this purpose and, if so, at what cost.

Assessing proposals for certificate system

15.If a certificate system is to be introduced by the Government, there needs to be a clear set of criteria and evidence by which to judge the policy proposals. Professor Mills told us that in order to assess whether a certificate system can achieve its purpose, there a four main elements:

1. The science around Covid infection and immunity;

2. Ethical and discrimination issues;

3. Technical issues, about how certificates would work; and

4. Data privacy and security.25

16.Reviews already carried out into Covid-status certification systems have produced a recommended set of criteria by which to assess the feasibility of proposals. For example, the Royal Society’s rapid review of Covid-status certification, chaired by Professor Mills, concluded that certificates are feasible, provided that twelve criteria are met.26 Similarly the Ada Lovelace Institute has also set out six criteria that it believe any Covid-status certification system should satisfy.27

17.Professor Wolff, David Davis and Silkie Carlo, Director of Big Brother Watch, also all indicated that any assessment on the feasibility of a Covid-status certification system has to include a consideration of proportionality.28 What we infer they mean by this is that any system must include an assessment of whether the measures proposed to be put in place are an appropriate and proportionate solution to the problem that is faced. Any proportionality assessment is therefore a cost-benefit analysis. Professor Wolff, in addressing how a cost-benefit analysis could be carried out for a Covid-status certificate system, told us that:

When we do traditional cost-benefit analysis we normally have a good indication of the probabilities and the harms. In this case we know so little about probabilities: will there be a new variant, what will happen when we relax lockdown? … We don’t know the probabilities and they are very hard to assess.29

18.While it would still contain a significant amount of uncertainty, Professor Wolff said that he thought that we needed to see:

some serious modelling of different scenarios and thinking about what would happen if we had this and what would happen if we did not, and obviously it is not evidence yet but thinking about data and what difference we expect this to make. If it turns out to make almost no difference, it is a lot of fuss about nothing. If it turns out to make an enormous difference so that we could get back to normal with very minimal risk to public health, some of the resistance may be mitigated. At the moment, it is all a bit of a hope and a prayer. We do not have serious models about what is likely to happen if we introduce the scheme.30

19.We asked the Minister whether a cost-benefit analysis had been carried out as part of the review and whether it would be published alongside the review. He confirmed that such analysis would be published alongside the review, but framed the analysis as considering whether “the deployment of certification and the investment in that infrastructure would enable the economic and social life of the country to return more quickly and safely”.31 The Minister told us that his assessment of the cost and benefits were “finely balanced”.32

20.When we asked the Minister what the likely financial cost of introducing such a system would be, he said:

I cannot give a hard and fast figure but I would be keen to come back to the Committee after consulting with colleagues in NHSX.33

Asked what the expected cost to business and individuals would be, the Minister told us:

… the one thing they have been clear about is that none of us like the idea of Covid-status certification but if it is a way of ensuring that you can have a full venue it is a cost that they would be willing to bear.34

21.Kathy Hall, Director General of Delivery in the COVID-19 Task Force at the Cabinet Office, added to this that the cost to businesses and individuals would depend on the model adopted.35 The Government has not provided the Committee with the information on the likely costs to the public purse or to businesses and individuals of any of the models under consideration.

22.We asked the Minister what modelling has been carried out to assess the impact of having a Covid-status certification system on the results of the next stage of easing of restrictions compared with proceeding with that easing without such a system in place. He told us that “We know that it would have a beneficial effect in those venues where it was deployed but we must be careful not to overstate the effect that it would have”.36 Dr Susan Hopkins, Epidemiological Consultant at Public Health England, added to this, saying:

Most events that people go to are smaller events, meeting indoors. That is where most of the transmission occurs. Clearly the risk of a large event, both travelling to the event, the socialising around the event and the event itself, can potentially be reduced by the use of testing, vaccination or, alternatively, knowing people’s prior infection status. All those things together are likely to reduce the risk of transmission by 30% to 50%, not eliminating it as we have mentioned earlier but maybe even higher.37

23.When pressed further on what modelling for potential scenarios has been conducted, the Minister said, “we can make judgments and estimates but they always must be provisional, but yes, we can”.38 The Minister committed that the Government “alongside any announcement will lay out our best and clearest thinking about why Covid-status certification might be appropriate in particular venues”.39

24.It is imperative that if a Covid-status certification system is to be introduced, the Government publishes the criteria against which the efficacy of that system is to be assessed, together with a clear statement and explanation of whether or not the Government believes that the system being deployed satisfies those criteria.

25.It is also essential that a cost-benefit analysis is carried out and made public alongside any announcement regarding the introduction of a Covid-status certification. Such a cost-benefit analysis should include not only financial but also social and societal costs and benefits.

26.It is highly regrettable that the Government has not, despite committing to do so, provided the Committee with likely financial costs to the public purse or to businesses and individuals of different models of Covid-status certification. Full costings must be provided alongside any announcement in regards to Covid-status certification.

27.We recognise that conducting detailed modelling, especially with so many unknown variables and uncertainties, is difficult and imprecise. Nonetheless, we believe that it is the best guide to the potential impacts of the range of different scenarios that cannot necessarily be directly tested. We expect all such modelling to be published alongside any announcement. If such modelling has not been conducted, the Government should provide a clear explanation for why they have opted not to use modelling and what account they have taken of different scenarios in its absence.

28.Given the large number of areas where the Government was unable to provide the Committee with information and answers in regards to: criteria against which the efficacy of that system is to be assessed; the cost-benefit analysis proposals; modelling of different scenarios with and without a certificate system, combined with the Minister’s own assessment that the case of a Covid-status certificate system is “finely balanced”, the Committee does not think the Government has made a case for any form of domestic Covid-status certification system.

1 Cabinet Office, COVID-19 Response - Spring 2021, 22 February 2021

4 Q65

5 Richard Sparrow, UK coronavirus: PM confirms ‘rule of six’ to apply in England from Monday; Whitty warns of rapid case rise – as it happened, Guardian, 10 September 2020

6 Richard Vaughan and Paul Gallagher, ‘Covid vaccines: ‘Immunity passport’ may be used for admission to pubs, restaurants and sporting venues,, 30 November 2020

7 Ashley Cowburn, ‘Covid app could start recording whether user has had vaccine, Dido Harding suggests’, The Independent, 30 November 2020; Rory Cellan-Jones, ‘Coronavirus: NHS Covid-19 app to gain self-isolation payments’, BBC, 30 November 2020

13 Q3

15 Ada Lovelace Institute, Checkpoints for vaccine passports, 10 May 2021

16 Q2

24 Oral evidence taken on Tuesday 23 March 2021, HC (2019–21) 1315, Q3

25 Q3

26 (1) meets benchmarks for COVID-19 immunity; (2) accommodates differences between vaccines in their efficacy, and changes in vaccine efficacy against emerging SARS CoV-2 variants. It should be (3) internationally standardised with; (3) verifiable credentials for (4) defined uses, and based on (6) a platform of interoperable technologies; (7) secure for personal data; (8) portable and; (9) affordable for individuals and governments. And it should meet (10) legal; and (11) ethical (equity and non-discrimination) standards; and, (12) the conditions of use should be understood and accepted by passport holders. The Royal Society, Twelve criteria for the development and use of COVID-19 vaccine passports, 14 February 2021

27 (1) Scientific confidence in the impact on public health – this includes setting scientific pre-conditions, including the level of reduced transmission from vaccination, as well as accurate testing regimes.
(2) Clear, specific and delimited purpose – there may be greater justification for some use cases of digital vaccine passports than others, such as for care home workers.
(3) Ethical consideration and clear legal guidance about permitted and restricted uses, and mechanisms to support rights and redress and tackle illegal use – there are important legal tests, in particular respecting the right to private life, which must be considered where people are required to disclose personal information. There are also wider concerns around fairness, equality and non-discrimination, social stratification and stigma at both a domestic and international level.
(4) Sociotechnical system design, including operational infrastructure – designing a vaccine passport system will require consideration of wider societal systems, and a detailed examination of how any scheme would operate in practice.
(5) Public legitimacy – there are sensitivities involved in building technical systems that require personal health data to be linked with identity or biometric data for many countries. Public confidence in a COVID vaccine passport system – one that is seen as trusted and legitimate – will be crucial to its success.
(6) Protection against future risks and mitigation strategies for global harms – if governments believe they have resolved all the preceding tensions and have determined that a new system should be developed, they will also need to consider the longer-term effects of such a system and how it might shape future decisions or be used by future governments. Ada Lovelace Institute, Checkpoints for vaccine passports, 10 May 2021

28 Oral evidence taken on Tuesday 23 March 2021, HC (2019–21) 1315, Q3, Q9 Q31, Q40

29 Oral evidence taken on Tuesday 23 March 2021, HC (2019–21) 1315, Q11

30 Oral evidence taken on Tuesday 23 March 2021, HC (2019–21) 1315, Q39

Published: 12 June 2021 Site information    Accessibility statement