“Our investigation did not assess whether the vaccination requirements were an unjustified limitation on individuals’ freedom of mobility guaranteed by the Canadian Charter Of Rights And Freedoms,” wrote Dufresne. The Commissioner also dismissed complaints by federal employees—including RCMP officers and Canadian Armed Forces members—who were required to show proof of vaccination or face suspension without pay. The Commissioner tabled his findings in Parliament without comment to reporters.

The Office of the Commissioner and provincial equivalents had previously written in a May 2021 joint statement that no existing federal law permitted governments to mandate COVID-19 vaccinations, as there must be “clear legal authority for introducing the use of vaccine passports for each intended purpose.”