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GUIDANCE

COVID Pass: guidance for


businesses and events
How businesses and event organisers must check the
COVID-19 status of their customers.

First published: 8 October 2021

Last updated: 10 December 2021

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Contents

Context

Why the Welsh Government Is introducing the COVID Pass

When

Settings

Nightclubs and similar venues

Exemptions and exceptions

How customers can demonstrate their COVID-19 status at your venue or


event

How will the COVID Pass work?

Proof of a negative lateral flow test

What about individuals from outside the UK

Enforcement

Obligations on the person responsible for operating the premises

Will businesses or events need to collect or store personal information

Annex 1: examples of premises or events

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Annex 2: how customers can demonstrate their status

Context

On 17 September the Welsh Government announced that people attending


large events and nightclubs (or similar premises) will have to prove they are
either fully vaccinated or have had a negative COVID test. This system was
extended to cinema’s theatres and concert halls from the 15 November.

Why the Welsh Government Is introducing the


COVID Pass

There has been an increase in the number of COVID cases and community
transmission across Wales. We are preparing for a winter which could be very
difficult, with COVID and seasonal flu both in circulation, potentially putting the
NHS and wider services under enormous pressure.

SAGE’s very clear advice was to take early and what it calls “low-cost
interventions” which may reduce the need for tougher measures later to control
the spread of the virus. We take this advice seriously because none of us want
to see businesses having to close again and further lockdowns introduced, if
they can be avoided.

COVID Passes have been introduced – to form part of the range of reasonable
measures to mitigate the spread of COVID through the community, and the
associated harms that it brings. There is also some evidence of so-called super
spreading events associated in the UK and globally with nightclubs, sports
events, and festivals.

It is important to note that the COVID pass is only one of a range of measures
which could be implemented, the extent of the measures will be dependent on
the individual risk assessment. However, in respect of certain premises it will be

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a legal requirement to be implemented.

Likewise, if the COVID pass is not mandated for use in particular settings, it
could still form part of the reasonable measures that the responsible person may
identify should be implemented following undertaking the bespoke risk
assessment.

Settings, where the COVID pass has been mandated, are classed as “higher-
risk” premises and events because it is not as easy to introduce reasonable
measures, such as ventilation or social distancing to mitigate against the risk of
coronavirus.

The compulsory use of the COVID Pass as a condition of entry will help to
reduce – but not remove – the risks of people infected with coronavirus entering
and spreading the virus at busy venues and events.

It is important to note the use of the COVID Pass, in and of itself, will not remove
all the risks associated with these venues. It will be important for people
attending events and venues to continue to exercise caution and premises
should consider what other reasonable measures they can put in place to further
reduce the risk to staff and attendees.

Regulation 16 of the Health Protection (Coronavirus Restrictions) (No. 5)


(Wales) Regulations 2020 as amended (the “Coronavirus Regulations”)
imposes requirements on people responsible for premises open to the public
and people responsible for work undertaken at premises to carry out COVID risk
assessments. In addition they will need to take reasonable measures to
minimise the risk of exposure to coronavirus on the premises, and to minimise
the risk of spread of coronavirus by those who have been on the premises.

When

This guidance applies now. The changes came into effect from 07:00 on
Monday 11 October 2021 for nightclubs and large events and from 07.00 on the
15 November for cinema, theatres and concert halls.

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Settings

The requirements mean people over the age of 18 in Wales need to show their
COVID19 status to attend the following venues or events:

• nightclubs and similar venues (see definition below)


• cinemas, theatres and concert halls
• indoor venues with more than 500 people in the audience where some or all
of the audience are not normally seated
• any outdoor or indoor venues with over 4,000 in the audience, where some
or all of the audience are not normally seated
• any event, which has more than 10,000 people in attendance

An event is considered to be unseated when some attendees are seated and


some are standing.

For multi-day events, multi venue events or events with separate shows during
the day – it is the number of people attending at any time on any day or for any
show. It does not include staff, contractors, performers, or volunteers involved in
the delivery of the event.

In determining whether or not events are to be treated as outdoors,


consideration should be given to any indoor facilities on site which may be
occupied by people for most of the day (for example hospitality). In such
circumstances, this may mean that the event should be treated as an indoors
one. However, a concourse that is provided solely for the provision of food or
drink for take away consumption outdoors at the event and provision of toilets
should not be considered to be an indoor event.

Nightclubs and similar venues

The requirement to check individuals’ COVID passes will be required in any


venue that meets three main considerations:

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• firstly, a venue that is authorised to serve or supply alcohol
• secondly, a venue that is open late at night between the hours of midnight
and 5am
• thirdly, a venue where music is provided for dancing, (this includes silent
discos)

The venue must meet all three considerations to be captured by the requirement
to operate a COVID pass.

However, the venue is captured by the requirement to operate the pass at all
times (not just between the hours of midnight and 5am) if music is provided for
dancing.

It will be for each venue to determine what measures to put in place, and
whether the COVID pass should begin from the time the venue opens or from
the time the venue opens its dancefloor and provides music for dancing, based
on a range of factors including the venue’s hours of operation and nature of
business.

Annex 1 provides examples of how the scheme will apply to certain venues and
events.

Exemptions and exceptions

Staff, contractors, performers or volunteers involved in the delivery of the event


are not required to show a COVID Pass or proof of a negative lateral flow test in
the last 24 hours to help minimise the spread of the virus. However, in order to
protect themselves and others and to help us keep the sector open, venue
owners and event organisers may wish to consider encouraging all those on
site to take regular lateral flow tests prior to an event as part of their risk
assessment.

The following are examples of the types of premises that are specifically
exempted from the requirement. Premises at which:

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• an outdoor event that does not require an entrance fee or ticket to attend is
being held, and where the event site has multiple points of entry (this would
cover, for example, a free fireworks display in a public park, or a farmers
market)
• a protest or picket is being held
• a mass participation sporting event is being held outdoors (such as a
marathon, triathlon or cycle race)
• the celebration of a marriage or civil partnership, or the life of a deceased
person (when such celebrations are taking place) is taking place, for such
time as the premises are either being used solely for that purpose or have a
separate function area complete with all facilities to avoid mixing between
guests attending the event and other people attending the premise. This
does not include other life events (for example, birthdays)
• a drive in theatre
• a drive in cinema

The following people will not need to provide evidence to enter a venue or event

• under 18s (although it may still be part of the reasonable measures that a
venue has adopted )
• people working, volunteering or performing in the venues

How customers can demonstrate their COVID-19


status at your venue or event

COVID status can be demonstrated in either of the following ways:

• via the digital NHS COVID pass - people who are fully vaccinated in Wales
can already download a certificate proving their status. The NHS COVID
Pass lets individuals demonstrate their coronavirus (COVID-19) vaccination
records in a secure way NHS COVID Pass: prove your vaccination
status;
• a paper based certificate of vaccination – this does not include vaccination
cards (see annex 2 for examples of paper certificates that can be accepted);
and

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• confirmation of a negative test result by email or text provided by gov.uk
• confirmation of a positive test within the last 6 months which has been
followed by the appropriate period of isolation i.e., 10 days) - this can be
evidenced in the COVID pass or by text or email

We are aware that there are a very small number of people in Wales (less than
100) who are not able to receive a vaccination or able to take a lateral flow test.
We are working to develop and design a digital system which will automatically
update the COVID pass so that the exemptions are recorded on the system and
the pass will read as valid or eligible to enter a venue or event.

However, that is not available at the current time. On this basis, the venue or
event should:

• clarify the exemption being claimed (not the details just the reason)
• confirm that individuals who are clinically exempt from receiving a
vaccination or from wearing a face mask should be asked to provide
evidence of a negative lateral flow test
• if individuals claim they are clinically unable to take a lateral flow test, then
the venue should recognise the exemption and allow that individual entry. In
these circumstance, venues will not be required to consider evidence of the
exemption.

How will the COVID Pass work?

The NHS COVID Pass can be accessed via a smartphone, tablet or computer.
The domestic pass option will produce a 2D machine readable barcode that can
be:

• opened and shown on a phone


• downloaded into smart phone wallets
• downloaded as a PDF download shown on smartphone or tablet screen or
printed by the customer

Businesses or events will be able to scan the COVID pass via a Verifier App for

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instance the NHS Verifier App or will be able to operate validation by sight. If
venues opt to use a verification app, it is advisable they ensure they activate any
‘domestic’ reader option to avoid processing unnecessary health data.

Proof of a negative lateral flow test

In normal circumstances lateral flow tests should be done at home – results take
around 20 to 30 minutes and they should have been taken up to 24 hours before
entrance to the event or visiting a venue, to minimise the risk of spreading the
virus.

We are encouraging all people attending a venue or event show proof of a


negative lateral flow test taken within the last 24 hours.

Once the test is completed all results need to be registered on this website
(on GOV.UK). These test results will automatically show up on the NHS COVID
Pass.

If the lateral flow test is positive then a follow up PCR test should be booked
immediately online, by calling 119 or via the NHS COVID-19 app. That person
must self-isolate immediately.

Results confirmation will also be emailed or sent via a text message - this is also
considered as proof of a negative test.

Anyone who does not have symptoms can get free lateral flow tests:

• in most pharmacies
• from a local collection point
• ordered online and delivered

Get rapid lateral flow COVID-19 tests if you do not have symptoms.

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What about individuals from outside the UK

Individuals will need to provide proof of vaccination from the country where they
were vaccinated. Check if they were vaccinated in a country or territory that is on
the list of approved vaccination programmes and what is acceptable proof:
Countries whose COVID-19 vaccine programmes are recognised in Wales.

The NHS Verifier app will be able to scan EU COVID certificates.

All other attendees will need to provide proof of a negative lateral flow test.

Enforcement

The Coronavirus Regulations set out a specific and separate system for
enforcing the requirement in Regulation 16 to take all reasonable measures to
minimise the risk of exposure to COVID. This provides that enforcement officers
from local authorities can require measures to be taken in relation to premises,
and they can if necessary close them. Closure can be required either because
reasonable measures aren’t subsequently taken or because the breach of the
requirements is sufficiently serious to justify closing a premises immediately or
with very limited notice.

The enforcement system is set out in Schedules 8 and 9 to the Coronavirus


Regulations and is based on the issue of a “Premises Improvement Notice” or a
“Premises Closure Notice” or both, depending on the circumstances.

The COVID pass requirements form part of the bespoke risk assessment and
could be one of the reasonable measures that are required to be put in place in
line with the duties under Regulation 16. The specific provisions applying to the
reasonable measure itself are set out in Regulation 16A.

It is important to note that this new evidence checking requirement forms part of
a range of reasonable measures which should generally be implemented
dependent on the steps identified as part of the bespoke risk assessment. It

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does not remove the need to consider and implement other measures.

The bespoke risk assessment should also set out the rationale and justification
of how each business and setting has chosen to operate this requirement, which
will normally be by means of individuals wishing to attend or enter having to
produce a COVID-pass. What is considered reasonable in terms of checking will
vary at different times and for different venues depending on a range of
circumstances, including the capacity and entry procedures. There may be
circumstances where checking everyone entering a particular premises might
give rise to particularly large queues and bunching of people, but with other
premises, they will already have procedures for checking by means of a queuing
system, where it would be reasonable also to check whether each individual has
a valid COVID pass.

For example, it is normal for night clubs to control numbers by operating a queue
outside of the premises, and the expectation is that they would check every
person wishing to enter, but carrying out checks on every person entering at
major football or rugby matches could exacerbate safety issues as it could lead
to larger than normal queues forming outside.

Each venue will need to undertake a risk assessment to ensure that it can justify
what it considers to be a reasonable measure in the context of checking, taking
account of its other statutory duties for example health and safety of its
customers, wider public order issues and potential terrorism risks.

We will use the current enforcement regimes as set out in the Reasonable
measures to minimise risk of coronavirus in workplaces and open
premises: guidance for enforcement officers guidance for monitoring
compliance. This means businesses and events will need to ensure their
proposed arrangements comply with the regulations and are included in their
bespoke risk assessments as the mandated reasonable measures to ensure
compliance;

Penalties may include:

• fixed penalty notice with the maximum fine for repeated breaches by
businesses being £10,000

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Offences apply where a person commits an offence if without reasonable excuse
they:

• do not ensure a premises issued with a closure notice is closed and no


business is carried on or service is provided on or from the premises
• do not ensure that no person enters or is on any premises issued with a
closure notice
• obscure or damage a notice or sign required to be displayed

A wider offence applying to individuals linked to the possession of false or


misleading evidence of vaccination or testing status where that evidence is
required as part of the requirement for providing evidence for entry has also
been introduced.

Where there are reports of individuals providing falsified or misleading


information, a police officer or a police community support officer (PCSO) will be
able to take action under the regulations.

Obligations on the person responsible for


operating the premises

The Regulations confirm that events and venues must take reasonable
measures to put in place checks that people entering the premises are eligible to
enter. What is considered reasonable will vary at different times and for different
venues depending on the capacity and its normal operating procedures (for
example, it is normal for night clubs to control numbers by operating a queue
outside of the premises, but it may not be safe for there to be large queues
outside of a major football or rugby match).

On this basis each venue will need to undertake a risk assessment to ensure
that it can justify what it considers to be a reasonable measure in the context of
checking, taking account of its other statutory duties for example health and
safety of its customers, wider public order issues and potential terrorism risks.
However, our expectation is that nightclubs and venues with lower attendance
would undertake a 100% check.

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To reduce queues a venue could ask for a COVID Pass in advance by way of a
booking, a pass would be required for all individuals listed on the booking, and
the venue would need to confirm the individuals booked are the ones who attend
the event. Passes in advance would not apply for attendees who needed to
show a lateral flow tests unless the booking and lateral flow test was provided
within 24 hours of the event, to minimise the risk of spreading the virus.

Will businesses or events need to collect or store


personal information

Businesses or events will need to ensure that they have considered the data
protection implications of how they operate. The requirements put in place will
not be a need to store any personal information about individuals entering a
premises or event. The COVID pass (which is already available) will only show
an individual’s name, and whether the COVID pass is valid – it will not include
confirmation of how they are eligible, nor will businesses be required to store
any information.

If individuals do not have a COVID pass, they will be able to provide evidence (in
the form of a text or email) that they have had a negative lateral flow test 24
hours before entry, to minimise the risk of spreading the virus. There is no need
for businesses or events to take or record any information from these individuals
either. Please refer to the information commissioner’s offices guidance for
nightclubs and organisers of large events at the following link Looking after
your customers’ personal data when completing vaccination and COVID
status checks – Advice for nightclub businesses and organisers of large
events (on ico.org.uk) . Venues are encouraged to add information on their
websites, ticking information, posters at the entrance and that staff able to
explain the process, etc.

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Annex 1: examples of premises or events

Example scenario Certification requirements

A venue opens at 4pm and This venue must operate checks to ensure that only those
closes at 3 am. It is licenced who can provide proof they are fully vaccinated, exempt or
to serve alcohol after have had a negative test result is present from 10pm to
midnight and has a 3am as the venue meets all of the conditions of the
dancefloor with a DJ from scheme.
10pm until the venue closes
at 3 am. To help manage the operation of the scheme, the venue
could choose to start asking for proof of status at the point
the dance floor opens at 10 pm or any time before.
However, it will be for the venue to decide how to operate
the scheme.

A venue opens at 4 pm and The venue would not need to check the status of those
ceases operations at 11 pm. who enter this venue as it ceases operation before
Live music is available midnight so does not meet all of the conditions set out
between the hours of 5 and above.
9 pm and the dancefloor is
open during these hours.

A venue that normally This venue must operate COVID checks at all times that
opens between midday to the DJ is present and music is being played for people to
3am has in the run up to dance.
Christmas, booked a DJ for
the premises for each day
from Midday to 3am. There
is no dancefloor but, music
is being played and people
are dancing.

A local pub which normally This venue must operate COVID checks at all times that
opens at 10am to 11pm Sun the music is being played for people to dance.

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Example scenario Certification requirements

to Thurs but opens 10am to


1am on Fri and Sat with the
provision of a DJ. There is
no specific room to dance/
no dance floor however,
customers dance regularly
at the premises

A football match taking This event will need to apply checks to those entering the
place at a football stadium event because the event will exceed the event attendee
which has sold 50,000 threshold.
tickets.

A music festival taking place This event does not need to apply checks prior to entry to
at an outdoor venue which this event as, although the venue has a maximum capacity
can accommodate 5,000 of 5,000, the event organiser capped ticket sales at 3,000.
attendees. The event This means the event attendance will be below the
organiser capped ticket threshold for outdoor events.
sales at 3,000. The event
organiser sells all 3,000
tickets.

An un-ticketed event is The event does not need does not need to apply checks
being held in an open prior to entry as it is un-ticketed, being held in an open
space. The event will space and there are no fixed entry or exit points.
include a fireworks display.
There are no fixed entry or
exit points.

A ticketed event such as an This event does not need to apply checks prior to entry as
illuminated trail, light show the number attending is below the threshold for outdoor
or firework display is being events.
held outdoors. The events
might be held over a series
of days, however, ticket
sales for each event are

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Example scenario Certification requirements

limited to 4,000 customers


per event.

An outdoor festival has a The event does not need to apply checks prior to entry as,
total attendance of 10,500 although the total event attendance is over the threshold,
customers over three days the attendance each day would be below the threshold for
of live music, However ticket outdoor events
sales each day are limited
to 3,500 customers.

A Rugby match taking place This event will need to apply checks to those entering the
at a stadium that has sold event because the event will exceed the event attendee
4,200 ticket, 2,500 are threshold.
tickets for terracing and
1,700 are seated.

A football match taking This event will not need to apply checks to those entering
place at a stadium that has the event.
sold 6,000 seated tickets.

An event has been Both the event and the hospitality will need to apply checks
organised outdoors with an prior to entry to the event
attendance of 8,000.
However the event also has
501 people who are indoors
for most of the day watching
the event from executive
boxes or a bar (or similar).

A wedding venue, holding This event will not need to apply checks to those attending
an evening reception, the wedding, provided there are separate facilities to avoid
providing music for dancing the need for guests to mingle with other people attending
until 1am. the premises. However, it could be considered as
reasonable as part of the reasonable measures introduced
to minimise transmission and spread of the virus as part of

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Example scenario Certification requirements

the coronavirus risk assessment for the event/activity,


especially if there is a risk that wider mixing will take place.

A pub holding an evening This event in the function room would not need to apply
wedding reception in a checks to those attending the wedding provided there are
separate function room and separate facilities to avoid the need for guests to mix with
facilities with a dancefloor other people attending the premises. However, it could be
with a DJ providing music considered as reasonable as part of the reasonable
for dancing until 1am. measures introduced to minimise transmission and spread
of the virus as part of the coronavirus risk assessment for
the event/activity, especially if there is a risk that wider
mixing will take place.

A pub holding an evening This venue must operate COVID checks at all times that
wedding reception which is music is being played for people to dance, including for
also open to the general anyone attending the wedding reception itself.
public in the same area and
has provided music for
dancing past midnight.

To reduce queues, a venue The venue would need to confirm the individuals booked
could ask for a Covid Pass are the ones who attend the event. Passes in advance
in advance by way of a would not apply for attendees who needed to show a
booking. A Covid Pass lateral flow tests unless the booking and lateral flow test
would be required for all was provided within 24 hours of the event.
individuals listed on the
booking.

A community venue that It is not a legal requirement to mandate checks to those


normally opens for attending the film showing as the normal function is a
community events and community venue not a cinema. However, it is strongly
meetings will host a film recommended that consideration is given to voluntarily
showing in the run up to implementing these checks as part of the coronavirus risk
assessment for the venue

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Example scenario Certification requirements

Christmas to raise funds for


the venue/charity.

A community venue that It is not a legal requirement to mandate checks to those


normally opens for attending the carol service as the normal function is a
community events and community venue not a theatre / concert hall. However, it is
meetings will host a carol strongly recommended that consideration is given to
service in the run up to voluntarily implementing these checks as part of the
Christmas to raise funds for coronavirus risk assessment for the venue
the venue/charity.

A church will host a carol It is not a legal requirement to mandate checks to those
service in the run up to attending the carol service as the normal function is a
Christmas to raise funds for community venue not a theatre / concert hall. However, it is
the church/charity. strongly recommended that consideration is given to
voluntarily implementing these checks as part of the
coronavirus risk assessment for the venue

A venue is holding an This event will not need to apply checks to those attending
outdoor cinema / theatre the outdoor cinema / theatre show provided attendance is
show. below the 4,000 person limit if some people could be
standing during the event. However, it could be considered
as reasonable as part of the reasonable measures
introduced to minimise transmission and spread of the
virus as part of the coronavirus risk assessment for the
event/activity

Annex 2: how customers can demonstrate their


status

NHS COVID Pass status can be demonstrated in a number of ways:

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• digital solution such as the NHS COVID Pass which has evidence of proof of
full vaccination, recovery (this is a positive PCR result within 180 days
(individual must have completed the mandatory 10 day isolation period from
the date of the result))
• the recovery PCR result can also be presented via text or email
• a paper-based certification of full vaccination
• confirmation of a negative test result by text or email

NHS COVID Pass

The NHS COVID Pass is available in England, Wales and the Isle of Man. The
NHS COVID Pass can be accessed via a smartphone, tablet or computer.

The Pass, including a 2D machine readable barcode, can be:

• opened and shown on a smart phone and/or smart device


• downloaded in the Apple or Google wallet
• downloaded as a PDF shown on smartphone or smart device or printed by
the customer
• scanned via a Verifier App for instance the NHS COVID Pass Verifier App

NHS COVID Pass examples

The 2D barcode has an expiry date for security reasons and can be scanned via
a verifier app such as the NHS COVID Pass verifier app.

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Other devolved nations and Crown Dependencies
(Channel Islands)

Scotland and Northern Ireland and the Crown Dependencies (Channel Islands)
have developed similar digital solutions or solutions that contain 2D Barcodes.

NHS COVID Pass Verifier App

The official NHS COVID Pass Verifier app is a secure way to verify an
individual's NHS COVID Pass and check that they have been fully vaccinated

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against COVID-19 and/or had a negative test result. A venue can use the app to
scan and verify the 2D barcode from an individual's NHS COVID Pass as entry
to venues and events.

The NHS COVID Pass Verifier App can be downloaded from the Apply or
Google store onto a smart device.

Proof of vaccination letters

Your customers must have a proof of vaccination via a proof of vaccination


certificate such as the NHS COVID Pass Letter used by Wales, England,
Scotland, Northern Ireland, Isle of Man this will show the full dose of a
vaccination. Venue operators will need to check letters.

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Lateral flow test result

Your customers may also provide proof of negative lateral flow test. We would
encourage this even for people who are vaccinated. The lateral flow test is
reported via the report a COVID-19 rapid lateral flow test result (on GOV.UK).
Confirmation of the negative test result is sent by text and email and are also
available in the NHS COVID Pass.

The results are valid for 48 hours if shown in the NHS COVID Pass, the 2D
barcode will only by valid for 48 hours and if by text or email will show the name,
date of birth and date. However we would encourage lateral flow tests to be
taken within the last 24 hours to help minimise the spread of COVID-19. NB
there's no 2D barcode displayed for these results displayed by text or email.
Venues will need to check the date on the text or email to ensure they are in
date.

This document was downloaded from GOV.WALES and may not be the latest version.
Go to https://gov.wales/covid-pass-guidance-businesses-and-events-html for the latest version.
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What happens with individuals from outside the UK

EU citizens will need to provide an EU COVID certificate or a negative lateral


flow test to enter. A number of non-EU countries have also adopted the EU
COVID certificate such as Turkey.

US citizens will need to provide a Centers for Disease Control and Prevention
vaccination card plus confirmation of identification or a negative lateral flow test
to enter.

Certificates from a number of other countries are valid proof of being fully
vaccinated.

Attendees from a country whose certificate is not recognised must provide proof
of a negative lateral flow test.

To note that when the international travel regulations change, it is likely that
more countries will be able to provide an accepted form of evidence of
vaccination - for example Australia and New Zealand.

Proof of COVID status examples

The EU digital COVID certificate. It is available across the EU member states


and adopted by some neighbouring non-EU states (Turkey).

Also displayed is a USA CDC COVID-19 vaccination record card.

This document was downloaded from GOV.WALES and may not be the latest version.
Go to https://gov.wales/covid-pass-guidance-businesses-and-events-html for the latest version.
Get information on copyright.
This document was downloaded from GOV.WALES and may not be the latest version.
Go to https://gov.wales/covid-pass-guidance-businesses-and-events-html for the latest version.
Get information on copyright.
About this document
This document is a copy of the web page COVID Pass: guidance for
businesses and events downloaded.

Go to https://gov.wales/covid-pass-guidance-businesses-and-events-html
for the latest version.

This document may not be fully accessible, for more information refer to our
accessibility statement.

Get information on copyright.


This document was downloaded from GOV.WALES and may not be the latest version.
Go to https://gov.wales/covid-pass-guidance-businesses-and-events-html for the latest version.
Get information on copyright.

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