Canada’s first COVID-19-related Order-in-Council, issued under Section 58 of the Quarantine Act (S.C. 2005, c. 20), came into effect on February 3, 2020. Since then, Canada has implemented various iterations of its travel restrictions and requirements to minimize the risk of Canada’s exposure to COVID-19. However, on September 26, 2022, the Government of Canada issued a news release confirming that it will lift all COVID-19 travel restrictions and requirements as of October 1, 2022.

Overview of Canada’s COVID-19 travel restrictions

For the first half of the COVID-19 pandemic, Canada’s travel restrictions prohibited foreign nationals from travelling to Canada for an “optional or discretionary” (i.e., non-essential) purpose. Until relatively recently, there were two sets of travel restrictions implemented by parallel Orders-in-Council; one restricting the entry of foreign nationals travelling to Canada from the United States, and another restricting the entry of foreign nationals travelling to Canada from any country other than the United States.

Following the introduction of COVID-19 vaccines, Canada began the process of relaxing its travel restrictions for foreign nationals deemed to be “fully-vaccinated against COVID-19” near the end of 2021:

• Fully-vaccinated United States citizens and lawful permanent residents of the United States have been exempt from the travel restrictions since August 9, 2021.
• All other fully-vaccinated foreign nationals have been exempt from the travel restrictions since September 7, 2021.

Canada’s current travel restrictions appear in the Minimizing the Risk of Exposure to COVID-19 in Canada Order (the Current Order-in-Council). The Current Order-in-Council consolidates the prior parallel Orders-in-Council and now applies to all foreign nationals, regardless of their country of departure or citizenship.

Foreign nationals who do not qualify as fully-vaccinated persons under the Current Order-in-Council are prohibited from travelling to Canada, although some limited exemptions are available.

Overview of Canada’s COVID-19 travel requirements

Since the beginning of the COVID-19 pandemic, Canada has also implemented several travel requirements, which apply to all travellers (including Canadian citizens and permanent residents of Canada):

• A self-quarantine/self-isolation requirement, which was implemented on March 25, 2020;
• A pre-departure COVID-19 testing requirement applicable to air travel, which was implemented on January 6, 2021;
• A pre-arrival COVID-19 testing requirement applicable to land/water travel, which was implemented on February 15, 2021;
• A post-arrival COVID-19 testing requirement, which was implemented on February 21, 2021;
• A mandatory hotel quarantine requirement for air travellers, which was implemented on February 21, 2021 (this requirement ended on August 9, 2021, for all travellers, regardless of vaccination status); and
• The ArriveCAN requirement, which was implemented on November 21, 2020.

Once COVID-19 vaccines became available, Canada relaxed its COVID-19 travel requirements for fully-vaccinated travellers. These fully-vaccinated travellers are exempt from almost all COVID-19 travel requirements imposed by the Current Order-in-Council. At this time, they are only subject to the following travel requirements:

• The first post-arrival COVID-19 test requirement, performed at the time of entry, but only if randomly selected; and
• The requirement to complete the ArriveCAN questionnaire.

Foreign nationals who do not qualify as fully-vaccinated persons remain subject to all travel requirements imposed by the current Order-in-Council, although some limited exemptions are available.

Transport Canada has also issued numerous COVID-19-related Interim Orders since the pandemic began, which impose health checks, vaccination requirements, and/or mask requirements on persons travelling by air, rail, or water:

• The current requirements applicable to travel by air (internationally and within Canada) appear in the Interim Order Respecting Certain Requirements for Civil Aviation Due to COVID-19, No. 73.
• The current requirements applicable to travel by rail within Canada appear in the Order under Section 32.01 of the Railway Safety Act due to COVID-19, No. 23.
• The current requirements applicable to international travel by water appear in the Interim Order Respecting Cruise Ship Restrictions and Vaccination Requirements Due to the Coronavirus Disease 2019 (COVID-19).

End to COVID-19 travel restrictions and requirements

As mentioned above, Canada will lift its COVID-19 travel restrictions and requirements on October 1, 2022. In its news release, the Government of Canada has confirmed that this development was facilitated by several factors, including the following:

• Modelling indicating that the peak of the Omicron BA.4 and BA.5-fueled wave has largely passed;
• Canada’s high vaccination rates, lower hospitalization and death rates; and
• The availability and use of vaccine boosters.

As of October 1, 2022, all travellers (including Canadian citizens, permanent residents of Canada, and foreign nationals) will no longer be required to do the following:

• Submit their quarantine and vaccination information through ArriveCAN;
• Provide proof of COVID-19 vaccination;
• Undergo pre- or post-arrival COVID-19 testing;
• Comply with COVID-19-related self-quarantine/self-isolation requirements; and
• Monitor/report if they develop signs or symptoms of COVID-19 after they arrive in Canada.

Although ArriveCAN will become optional on October 1, 2022, travellers may continue to use the Advance Declaration feature to submit their customs and immigration declarations before arrival. This feature, which will be expanded to most major Canadian airports over the next few months, will not be mandatory but is intended to save travellers time upon their arrival in Canada. 

The news release claims that using the Advance Declaration in ArriveCAN cuts the amount of time a traveller spends at a kiosk by roughly one-third. Despite this claim, it is unknown how many travellers will continue to use ArriveCAN after October 1, 2022. Of course, if the Canada Border Services Agency also establishes a separate inspection line for individuals who have completed an advance declaration prior to arrival (which should speed up the inspection process further), this may encourage travellers to continue using ArriveCAN once it has become optional. 

The news release also confirmed that Transport Canada’s COVID-19 measures will end on October 1, 2022. As of that date, it will no longer require travellers to:

• Provide proof of fully-vaccinated status for travel by air and water;
• Undergo health checks for travel on planes and trains;
• Wear masks on planes and trains (although the wearing of masks is still recommended); and
• Complete the ArriveCAN questionnaire within 72 hours of travel to Canada.

The Government of Canada’s news release confirms that the above developments relate to Canada’s federal COVID-19 travel restrictions and requirements only. For example:

• All travellers must continue to follow any applicable provincial or territorial COVID-19 requirements; and
• All foreign nationals must continue to meet the entry requirements under the Immigration and Refugee Protection Act (S.C. 2001, c. 27).

Finally, the Government of Canada’s news release reminds travellers that they should not travel if they have symptoms of COVID-19. Those who do have symptoms upon arrival in Canada should inform a flight attendant, cruise staff member, or border services officer. Such travellers may be referred to a quarantine officer who will decide whether a further medical assessment is required.

For more information, please reach out to the authors Henry J. Chang and Jonathan Mor.