On December 14, 2020, the first doses of the COVID-19 vaccine were administered to individuals in the United States. Accordingly, many employers are considering whether they can—or should—implement policies mandating COVID-19 vaccinations for their employees when the vaccine becomes widely available. On December 16, 2020, the Equal Employment Opportunity Commission (“EEOC”) updated its guidance, What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and other EEO Laws, to include answers to questions that specifically address COVID-19 employee vaccine policies. In short, the guidance states that employers may implement mandatory COVID-19 vaccine policies for employees as a condition to returning to, or remaining in, the workplace subject to certain exceptions. In this memorandum, we discuss the EEOC’s new COVID-19 vaccination guidance as well as certain other legal considerations for employers as they develop their workplace policies in anticipation of widespread distributions of COVID-19 vaccines in 2021.