The Health Protection (Coronavirus) (Requirements) (Scotland) Amendment Regulations 2022 and The Health Protection (Coronavirus) (Requirements) (Scotland) Amendment (No. 2) Regulations 2022: equality impact assessment

This equality impact assessment (EQIA) is to analyse the potential impacts for each protected characteristic under the Equality Act 2010 of amending the definition of fully vaccinated to include the requirement for a booster if a primary course of MHRA vaccine was over 120 days ago and amend the definition of late night venue.

Age: Young people (18-39)


A full Children's Rights and Wellbeing Impact Assessment (CRWIA) on the domestic use of Covid Status Certification has been carried out. The CRWIA considers the impact of the Covid Status Certification on children – all those under 18 – and so this age group will not be considered in the EQIA.

Young people in the age cohort 18-39 have taken up vaccination at lower rates than the rest of the population. As of 18 January 2021, 80.5% of young adults aged 18-29 had received one dose, with 72.2% having received their second and 40.0% having received a third dose or booster; 85.8% of adults aged 30-39 had received one dose, 79.8% had received their second and 52.3% had received a third dose or booster.[69] UK-wide research suggests that, while general willingness to get vaccinated is high, vaccine hesitancy (the "reluctance or refusal to vaccinate despite the availability of vaccines"[70]) is inversely related to age, as 16–24 year olds are 1.48 more likely to be vaccine hesitant than those aged 45–54 years.[71]

Recent UK-wide analysis also shows that vaccine hesitancy has decreased slightly among younger age groups. The latest Opinions and Lifestyle Survey (ONS)[72] conducted in June-July 2021 found vaccine hesitancy was:

  • 11% among those aged 16 to 17 years (14% previously in the ONS survey conducted January-February 2021),
  • 5% among those aged 18 to 21 years (9% previously)
  • 9% among those aged 22 to 25 years (10% previously).

Data from the UCL Social Study (an online UK based study of over 70, 000 people) found, from the week ending 28/11/21 that although attitudes to Covid-19 booster vaccine intentions were mostly favourable, 5% were hesitant about receiving a booster vaccine (scores of 3-4 on a scale from 1 [very unlikely]–6 [very likely]), and 7% said they were unwilling (scores of 1-2). Booster unwillingness (scores of 1-2 on a scale 1-6) was reported amongst 12% of young adults compared to 8% of adults aged 30-59 and 3% of adults aged 60+. Booster hesitancy (scores of 3-4 on a scale 1-6) was more common amongst young adults (10% vs 5% ages 30-59 and 2% ages 60+)[73].

Connected with this lower vaccination uptake among younger cohorts, Public Health Scotland data shows that, in the four weeks up to 30 August 2021, 40.1% of Covid-19 related acute hospital admissions were unvaccinated individuals, of which 56.2% were in the under-40s age group.[74]

Even before the pandemic, young people already reported higher levels of loneliness than the general population. The Scottish Household Survey of 2018 showed that 21% of the general population reported feeling lonely "some, most, almost all or all of the time" in the last week, but this percentage rose to 24% for people aged 16-24.[75]

Evidence collected through the longitudinal Scottish COVID-19 Mental Health Tracker Study run during the pandemic further suggests higher levels of loneliness among young people. The most recent analysis (on data collected in February and March 2021) found those aged 18-29 reported more loneliness than older age groups.[76]

The Tracker Survey has also shown young people have experienced mental health issues disproportionately. [77] [78] [79] In particular:

  • 18-29 year olds were more likely to report depressive symptoms (35.8%) than those aged 30-59 years (25.3%) and 60+ years (11.9%).
  • 18-29 year olds (28.8%) were more likely to report anxiety symptoms than 30-59 year olds (15.5%), and 60+ year olds (8.2%).
  • 18-29 year olds (28.8%) were more likely to report anxiety symptoms than 30- 59 year olds (15.5%), and 60+ year olds (8.2%).

Half of 18-29 year olds (50.2%) reported psychological distress compared to 31.4% of 30-59 year olds and 20.5% of 60+ year olds.

During the pandemic, evidence suggests that young people's mental health has suffered disproportionately from restrictions. In the first wave, 18-29 year-olds reported 1.7 times more depression, 1.6 times more anxiety, and almost twice as many suicidal thoughts than the overall sample.[80] In the second wave, levels of anxiety for that age group increased further.[81]

A meta-study on the mental health of children and young people during the pandemic by the British Medical Journal found that while many children and young people remain resilient to disasters such as the pandemic and may recover over time, the experience of multiple sustained stressors (such as illness, grief, isolation, closed borders, and home confinement) can result in both short and long term effects on their mental health and wellbeing.[82]

Differential impacts

Positive Impacts

For adults (18+), the 18-39 age cohort have the lowest level of vaccination.

All 16 and 17 year olds were invited to come forward for vaccination from 6 August.[83] All 16 and 17 year olds will be offered a second dose from 12 weeks or more after their first dose and those who are at increased risk from COVID-19 due to underlying health conditions, those who live with someone who is immunosuppressed, those who are an unpaid carer, a frontline health or social care worker, or those who are within three months of their 18th birthday, will be offered the second dose eight weeks after their first dose.[84] As of the 18 January 2022 2021, 81.8% of 16-17 year olds have had one dose, 51.7% have had 2 doses of the vaccine and 8.8% have a had a third dose or booster[85].

For those young people who have just turned 18 years old and have not had the opportunity to be doubled vaccinated, plus two weeks—for example if they have recently tested positive for Covid and have had to wait 4 weeks before getting their vaccination—they will be able to show record of a negative test as an alternative to vaccination.

A study comparing six countries has found that Covid Status Certification increased vaccinations 20 days prior to implementation, with a lasting effect up to 40 days after. The uptake was higher for those under 20 and 20-29 year olds when restricted to settings such as nightclubs and events. When expanded to a greater range, a high uptake was also seen in 30-49 age groups. A greater change was seen in countries with lower starting levels of vaccination. It is important to note these schemes were not vaccine only, like the Scottish scheme originally was, and had a different scope.[86] [87]

If vaccine and testing uptake increases among this age group, this would positively impact them as increased vaccination will reduce the direct health harms from Covid-19 and increased testing will enable us to identify the virus and reduce transmission.

There are some young people, such as some care experienced people, who may find it more challenging to access and maintain Covid Status Certification due to their life experiences and circumstances. For example, a care experienced person may change their address frequently, and may not have their current address registered at their GP. Including testing as an alternative to vaccination could have positive impacts for these younger people, as this may avoid difficulties with changing addresses and maintaining paper documents. However, we know that digital exclusion affects care experienced young people, and so they may not have a phone to receive or display SMS and email test results. Socialisation is key in supporting and maintaining relationships, mental health and wellbeing. Evidence shows that the mental health of this age group declined during lockdowns, and then gradually increased as settings re-opened.[88] [89] The settings in scope are often frequented by young people and play an important role in facilitating socialisation. Therefore, if the policy objective is achieved and the risk of transmission is reduced, which in turn allows higher risk settings to continue to operate as an alternative to closure or more restrictive measures, the policy could positively impact young people as it facilitates their ability to socialise.

Negative Impacts

Stakeholders noted that there was a reduction in mass vaccination centres and that some remaining sites could be more difficult, expensive, or time-consuming to access. This, coupled with the later offer of the vaccine to younger people, may make vaccination less accessible for this age group. The introduction of testing as an alternative to vaccination would mean that those who are not yet fully vaccinated would be able to access the regulated spaces.

Feedback from the Children and Young People's Commissioner Scotland (CYPCS) on how the scheme is impacting young people highlighted the narrative in the media - in Scotland and the rest of the UK- that young people have been more reluctant to take up the vaccine than other age groups, despite being the last to be offered the vaccine. This has negative impacts on how young people feel they are perceived by society. The CYPCS also commented on the closure of vaccination centres, which makes vaccination less accessible.

We want visitors coming to Scotland to be able to access events and venues. For domestic Covid Status Certification purposes, only MHRA-authorised vaccines are accepted and this does not include the World Health Organisation (WHO) list vaccines, such as the Chinese vaccines Sinopharm and Sinovac and the Indian vaccine Covaxin.[90] While students can be any age, they are far more likely to be younger and in the 20 and under and 21-24 age group.[91] Many students travel internationally to attend Scottish universities and of these many have received a vaccine which is not authorised by the MHRA. Stakeholders have informed us that an estimated 23,000 international students could have received an alternative vaccine. In 2016/2017 Chinese students made up 16% of the percentage of non-UK students total and Indian students made up 3%.[92] Both of these countries administer vaccines which are not approved by the MHRA. This could impact international students' ability to socialise with other students, such as going to nightclubs or sporting events. For those whose vaccine is not recognised by the MHRA, testing is an alternative option and would mitigate against the negative impacts.

Negative test results are only valid for 24 hours and so for those who are not fully vaccinated do not have a MHRA vaccine, testing could have an impact on their ability to spontaneously attend events in scope if their result has expired, or if they did not anticipate attending an event in scope and so did not test before leaving home. LFD tests can be ordered online, or picked up from a local pharmacy or test site and, dependant on the test used, take approximately 15 minutes to process a result. Registering the results of the LFD test on the GOV.UK website takes a short period of time and the SMS and email confirmation are generally issued very quickly.

We are however encouraging everyone to test before attending social events even if they are not within the scope of certification.

There is a possibility that Covid Status Certification could be used beyond the intended purposes, and that employers could require proof of vaccination as a condition of employment. Employees within the regulated settings are generally younger. Evidence from the Institute for Fiscal Studies showed that young people (under 25s) in the UK were 2.5 times as likely to work in a sector that has been 'shut down' during the pandemic, such as leisure and entertainment.[93] Therefore, if employers use Covid Status Certification beyond the terms of Covid Status Certification, it is more likely to impact on younger people. This age group has been already impacted financially by the pandemic, so if people are not able to maintain or gain employment due to their Covid Status Certification status this may exacerbate pre-existing impacts. Businesses not covered by the Covid Status Certification Scheme and operating certification voluntarily should consider asking for a record of a negative test as an alternative to a record of vaccination. However, as LFD test results are only valid for 24 hours, some may find daily testing inconvenient and burdensome.



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