Are we entering the age of COVID-19 passports in the sport industry?

Chief Scientific Adviser Sir Patrick Vallance has stated that nightclubs and other such venues could result in "potential super-spreading events" because of crowds of people in close contact. The UK Government has indicated that fans attending sports venues where “large crowds may gather” might be required to show proof of full vaccination from the end of September. No clarification has yet been given as to what may constitute a “large crowd” but the BBC has reported a number of “about 20,000 or more”.

These plans have been met with criticism from the Labour Party, with Shadow Sports Secretary Jo Stevens arguing that testing would be much more efficient. She said: “to insist on vaccine passports less than a month before the start of the season will cause major disruptions, especially for clubs at the lower end of the pyramid.”

In this article, we consider where we are on the government’s roadmap out of lockdown and set out considerations for sports event organisers to take into account, in light of the most recent government guidance.

UK Government roadmap – where are we?

The government's roadmap for the easing of lockdown restrictions comprises four steps. We are now in the fourth phase which means:

  • There are no restrictions on how many people can take part in sport and physical activity, indoors and outdoors.
  • All forms of activities can take place without restrictions. The national governing bodies (NGBs) should issue guidance where relevant.
  • All sports facilities can now open. There are no capacity limits at indoor venues but businesses may choose to put in place some restrictions and guidance.
  • Organised mass participation events can take place outdoors with no restriction on capacity for participants or spectators. 
  • Government will issue guidance for those participating in sport and physical activity on how to reduce transmission whilst exercising.

‘Freedom Day’ was a double edged sword for sports organisations and venues which will now be seeking urgent clarification on the proposal for COVID-19 passports. A decision is likely to be fluid whilst ministers and scientists review the data during the coming weeks.

Restrictions were lifted in the Netherlands on 26 June 2021, with the public given access to major events, for those who could provide proof of vaccination or a negative COVID-19 test. However, the infection rate then rose from a few hundred to 9,000 in two weeks, causing a number of measures to be reintroduced. The UK infection rate declined for six consecutive days after the lifting of restrictions but rose again on day seven. Businesses should bear in mind that government guidance could change quickly to reflect any increase in infection rates.

Likely considerations for sports event organisers will include:

  • Logistics around the verification process of spectator COVID-19 passports.
  • Issues around the processing and retention of data.
  • Additional staffing requirements.
  • Effect on revenue of reduced capacity versus additional administration costs.
  • Potential for conflict between staff and customers who have paid for tickets but are refused entry. According to Gov UK, as of 25 July 2021, around two-in-five people aged 18-29 in England have still not had their first jab since the programme was opened up to all over-18s on 18 June 2021.
  • Monitoring and policing staggered entry of spectators to venues.
  • Whether smaller venues simply restrict attendance to the prescribed COVID-19 passport limit to avoid administering the passport scheme.

The government allowed crowd capacity at Wembley to be raised to more than 60,000 for the semi-finals and final of Euro 2020. A capacity crowd of 140,000 attended the British Grand Prix at Silverstone on 18 July 2021 which was the largest crowd for a sporting event in the UK since the start of the coronavirus pandemic.

Fans attending Wembley were required to follow a number of entry requirements, including having a negative COVID-19 test or proof of full vaccination but significant concerns have since been raised about the adequacy of the system due to:

  • Visual checks only
  • No scanning/QR code check
  • No identify check to match ticket holder and vaccination.

The government will undoubtedly have learned much from these ‘test’ events - Tottenham Football Club are to trial the NHS COVID-19 pass on 8 August 2021 for their matches against Arsenal. Fans aged over 18 will need to use the pass to prove they have been double jabbed or have had a negative test within 48 hours of the game. Again, this will be an opportunity for more data to be gathered about the effectiveness of the passport system.


Spectators have made a welcome return to sports venues with all restrictions lifted. After 17 months, clubs and organisations can at last start to earn revenue. However, sports venues and clubs do not want to be in conflict with spectators and supporters. Indeed, the government and all those connected with events that attract large crowds, will be hoping that technology provides the blueprint for the future management of the associated COVID-19 risks.

The next phase of the roadmap out of lockdown, however, will be particularly challenging for sports organisers and venues that are required to administer the passport scheme. For many, this represents a fundamental shift in the government’s philosophical approach to managing COVID-19 risk. As such, how businesses deal with and respond to this threat, will increasingly be placed under the public spotlight.

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