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Covid Pass for England – a simple guide for hospitality premises

The Government has now activated additional control measures referred to as Plan B, including Covid Pass for certain venues and this came into force on the 15th December 2021.

This guide has been developed to help assist businesses understand if the Covid Pass applies to your business, and if so, what the law says you need to do.


If you operate as a nightclub or similar venue where the expectation is people will go there to dance rather than just to drink or eat, then it will apply to you regardless of how many customers you have.

If you do not consider your business is a nightclub, then do all the following apply to you?

  • You remain open after 1am
  • You serve alcohol after 1am
  • You have a dance floor area or have a space where people dance
  • You provide any kind of music for dancing

If all 4 of the above points apply to your venue, then the Covid Pass applies.

Yes, if you decide to change the way you operate so you no longer fall into the categories above, then you would no longer have to apply the Covid Pass requirement.

For instance: –

  • If you are a nightclub and close your dance floor or stop providing music.
  • For other venues, you may choose to close the dance floor, close the business before 1am, stop serving alcohol after 1am or stop providing music for dancing.
  • For larger events, you can limit the number of people to below the limits set.

For venues where the Covid Pass applies, you will be required to check every customer entering your venue after 1am. However, venues do need to implement a safe system of work to check covid passes for everyone inside the venue prior to this time.

All attendees will have to provide either evidence of double vaccination or a negative Covid test completed within 48 hours. At this time, customers do not have to show they have received the booster vaccination.

It is anticipated most people will use the NHS Covid App to demonstrate they have a valid Covid Pass.

The recommended way to verify a Covid Pass is to the use the NHS Covid Pass verifier App. This will verify if the Covid Pass shown to you on a SMART phone is in date and valid.

If you do not use the NHS verifier App you can make a visual check, but you will need to make sure this isn’t a screen shot, or a copy and is in date.

You should visit the NHS Covid pass web pages for further information on how to verify a Covid Pass.

You can accept evidence of a negative Covid test instead of the NHS Covid Pass but you need to ensure the following:-

  • The evidence of the test must be through the NHS Test and Trace service. You cannot accept any other evidence. The customer will have received an e-mail from the Test and Trace service so ask them for this.
  • Check that this shows the test was negative and done within the last 48 hours.

You must prepare a statement that explains what you will do to ensure you meet your obligations under the Covid Pass requirements. You must also keep this up to date to reflect any changes you might make as you get used to the new procedures. You should also include how you will let your customers know what you are doing.

For each night you operate, you must record the number of people that attended. You should also record if there were any problems that forced you to change the way you carry out your usual Covid Pass checks, why this was and what you did instead.

Records must be kept for 3 months from the day the records refer to and keep your general policy statement for as long as the Covid Pass requirement is in force and for 3 months after the requirement ceases.

Your records for each day/event must not record personal information of your customers.

In addition to ensuring you apply the Covid Pass requirements whenever they apply to your business you must also: –

  • Keep your Covid Pass policy/statement up to date so that it reflects how you are operating and how you are making the required checks.
  • Update your risk assessments to ensure you are taking necessary steps protect the health, safety, and welfare of your staff.

If you require any additional information, please contact

Staying Covid Secure

The Covid 19 pandemic is not over, cases are rising, and hospitalisations are likely to put increased demand on the NHS. Omicron has been detected in Lancashire, so we need to take precautions to keep staff and customers safe. Certain premises will now be required to implement the Covid Pass Scheme so please ensure you check to see if this applies.

There are 6 main actions you can take to protect yourself, your staff, and your customers.

Complete a risk assessment, guidance can be found at Also consider reasonable adjustments needed for staff and customers with disabilities. Share it with all your staff. Keep it updated.

Make sure there is an adequate supply of fresh air to indoor spaces where there are people present. This can be natural ventilation through opening windows, doors and vents, mechanical ventilation using fans and ducts, or a combination of both. Identify poorly ventilated spaces in your premises that are usually occupied and take steps to improve fresh air flow. Adequate ventilation reduces how much virus is in the air and reduces aerosol transmission.

It’s essential to clean surfaces that people touch a lot. Surfaces are contaminated with COVID-19 when people who are infected cough or sneeze near them or if they touch them. Encourage staff and customers to use hand sanitiser frequently.

Staff members or customers should self-isolate immediately if they show any symptoms of COVID-19 and book a PCR test as soon as possible. If positive, staff must complete their full self-isolation period. They must also self-isolate if they have been informed by NHS Test and Trace that they are a close contact – unless they are exempt. If you know that a worker is self-isolating, you must not allow them to come to work. It’s an offence to do this.

Whilst not legally required, collect customer contact details so as to support NHS Test and Trace. You can enable people to check in to your venue by displaying an NHS QR code poster. If you choose to display a QR code, you should also have a system in place to record contact details for people who want to check in but do not have the app.

Keep all workers, contractors and customers up-to-date on updated safety measures which can be found at

With restaurants, pubs and bars now entering the festive season, some businesses have erected a temporary structure. Should you be considering or have implemented this idea, Lancashire Fire and Rescue Service would advise that the responsible person for the premises considers the following advice:

  • Ensure your fire risk assessment is reviewed, including the temporary structure or marquee.
  • Manage the occupancy figures for the whole premises including the structure/marquee so they do not exceed the maximum capacity for the premises.
  • Have clear escape routes. Travel distances should not be excessive in an emergency. This includes the distance in the existing main building where the structure is attached to.
  • Ensure that the temporary structure/marquee does not impede or prevent other fire exit doors from opening correctly.
  • Where heaters or cooking facilities are present (both gas and electric), details of how their use will be the managed must be reflected in the fire risk assessment.
  • Consideration should also be given to the proximity of any decorations or other combustible material in relation to a source of prolonged heat impingement.
  • Storage and use of liquid petroleum gas (LPG) cylinders must be included in the fire risk assessment and codes of practice applicable must be followed. If you are in any doubt about how to store and use LPG safely, seek expert advice.
  • Staff fire safety training should incorporate the new area of the premises and staff should be made aware of their responsibilities in the event of a fire.
  • Ensure all fire-fighting equipment is in good working condition and serviced in accordance with the British Standards.
  • All fire alarm systems and emergency lighting for the premises must be serviced correctly and are tested in accordance with their respective British Standards.

Not only during the festive season but throughout the year, please remind all staff, management, and security to take a positive action to prevent crime and disorder both within and in the immediate vicinity of your premise. This should involve the supervising or monitoring all customers and queues, there behaviour and taking early action to prevent incidents, being mindful not just to eject troublesome groups onto the street together.

If you require help or advice, please contact us at

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