Washington, DC, USA - Closeup view of December, 23, 2020: COVID-19 Vaccination Record Card by CDC on blurred documents background.

Key Considerations for the Ethical Design of COVID-19 Vaccine Passports

By Chloe Reichel

States, employers, retailers, and other industries are now grappling with how to update mask policies in light of recent CDC guidance, which suggests vaccinated individuals may remove their face coverings indoors. 

But without a system in place to discern who has been vaccinated, the guidance poses a major risk: unvaccinated individuals, who can still contract and spread the virus, may also opt to go maskless. 

COVID-19 digital health passes, often called vaccine passports, may prove useful as a tool to relax mask policies. Vaccine passports can help to verify whether individuals may safely enter a space without a face covering.

Their ethical implementation, however, is contingent upon a number of factors: first and foremost, equitable access to vaccines. Other considerations include minimizing distrust, accessibility, risks of discrimination, and privacy protections.

For policy makers considering the implementation of COVID-19 vaccine credentialing programs, the Petrie-Flom Center for Health Law Policy, Biotechnology, and Bioethics at Harvard Law School and the Edmond J. Safra Center for Ethics at Harvard University have developed a road map highlighting key considerations for their ethical design.

This post provides a summary of key considerations and responsive policy recommendations presented in the paper to guide more equitable implementation of vaccine passports and to minimize distrust.

Community partnership.

  • Consideration: Communities have specific needs that may not be addressed by vaccine credentialing programs at the outset. For example, different communities may have differential access to vaccines or technology, or need different accessibility or language options.
  • Policy recommendation: Community partnerships should be encouraged, funded, and supported throughout the development and implementation of any vaccine credential program. Partnering with community representatives can help to identify community needs, build trust and guide equitable design.

Medical accommodations.

  • Consideration: Some individuals cannot be vaccinated (currently, children under 12, or those with certain documented medical conditions).
  • Policy recommendation: These individuals should receive accommodations to access sites that use digital vaccine credentials; accommodations can include alternative credentials, such as a recent negative PCR test or on-the-spot rapid screening options for active infection.

Non-medical accommodations.

  • Consideration: Not everyone with access and ability to receive the COVID-19 vaccines will want to do so.
  • Policy recommendation: Accommodations for non-medical reasons, such as philosophical objections, should be considered with caution, since they can impede community-level immunity. Designing policies to protect individual autonomy, whenever possible, can help alleviate some of these concerns, for example by including alternative credentials like recent negative PCR testing.

Monitoring and discrimination.

  • Consideration: Policing of vaccine status could put the safety and wellbeing of already overpoliced, racialized communities at even greater risk.
  • Policy recommendation: Governments should set clear guidelines for how vaccine status can be monitored. Safeguards should be in place to reduce discrimination. Personal identification credentials should be anonymized whenever possible and apps should be designed to block location services.


  • Consideration: In the United States, at least 17 organizations are developing vaccine passport apps. A decentralized model for vaccine passport programs creates a possibility that individuals will need to download multiple apps to go about daily living activities.
  • Policy recommendation: To promote interoperability, credentialing platforms could be modeled after credit card systems, which all use the same readers, despite being affiliated with different networks.

The digital divide.

  • Consideration: The digital divide means smartphone access is less common among the elderly, low-income individuals, and communities of color.
  • Policy recommendation: Providing alternative modes of displaying certification, such as via SMS or emailed QR codes, can avoid the need for smartphones, and for those without cell phones, paper alternatives can be used to validate COVID-19 health status.


  • Consideration: COVID-19 vaccine credentialing programs are likely to normalize use of novel digital health platforms, some of which will not fall under HIPAA protections.
  • Policy recommendation: Digital vaccine credentialing programs must be designed to protect data privacy and security. Organizations should be given the least amount of personal health information needed to grant individuals access. Individuals should be able to selectively disclose certain elements of their personal health information, such as the need for a medical accommodation, only when necessary. Consumers should be made aware of how their data is being used and protected by digital COVID-19 credential systems in clear and accessible terms.


  • Consideration: Asking the question of how to implement vaccine passports should not replace the questioning of where and when they should be implemented.
  • Policy recommendation: Ethical implementation of COVID-19 vaccine credentialing is contingent upon equitable access to vaccines, a precondition far from realized in the U.S. As such, the risks and benefits of vaccine passports should be weighed against other policy alternatives. These alternatives include, but are not limited to, site-specific vaccine mandates in high-risk settings, continued implementation of masking and physical distancing requirements, community-based vaccine education initiatives, and doubling down on vaccine distribution domestically and internationally.

Read the full road map here.

Chloe Reichel

Chloe Reichel is the Petrie-Flom Center’s Communications Manager. She serves as Editor-in-Chief of the Bill of Health blog and leads the Center's broader communications efforts.

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