The COVID-19 vaccines and undocumented migrants: what are European countries doing?

Last updated: July 2021

Are COVID-19 vaccines available for undocumented migrants in Europe? International and EU bodies have recommended addressing marginalised communities, including migrants in situations of vulnerability, in national vaccination strategies. In Europe, however, national approaches vary a lot.

For undocumented people, who are excluded from the health systems of most European countries, the pandemic and the lockdown measures have exacerbated pre-existing conditions of social exclusion and destitution. Several European countries, regions and cities adopted measures to support this population during the pandemic, including through targeted regularisation programmes. But what is being done with regards to the vaccination campaign, one of the most important tools we have to protect people against COVID-19?

We have been monitoring the news and exchanging with our members and followers, and we have compiled a map that looks at two critical factors affecting access to the COVID-19 vaccines in Europe for undocumented migrants: the absence of administrative barriers and protection from immigration control consequences of getting the vaccines.

As for administrative access, we consider in particular whether it is possible for undocumented migrants to register for or otherwise get their vaccination without the need to give proof of residence or identity or other documents that many undocumented people simply cannot provide (for instance, a social security number).

As for protection from immigration control, we consider whether there are clear safeguards (“firewalls”) against exposure to immigration control, through data protection and freedom from checks or arrest at vaccination centres.

This map focuses on delivery of the COVID-19 vaccines and doesn’t provide information about the accessibility of other health care more generally in a country, which in most parts of the EU remains very restricted for undocumented people. This map is a living document, which we’re updating as national policies and practices evolve, and as more information becomes available.This map is based on information we’ve been able to gather so far, and we’ll keep updating it as we know more. Here’s a quick rundown of what we’ve learned:


In early January, Brussels health minister Alain Maron said that “It’s out of question to exclude undocumented people from the vaccination process”. After this very welcome statement from a regional (Brussels) leader, the federal health minister confirmed before the Parliament that the vaccines would be available to undocumented migrants too. The Minister discussed the possibility of vaccinating this group via mobile medical teams, who would also ensure the vaccination for homeless people.


At the start of March, the Finnish Ministry of Social Affairs and Health recommended municipalities to grant access to the COVID-19 vaccines to undocumented migrants, free of charge. Questions remain as to the practical implementation of this recommendation.


The French health ministry has declared that the vaccines will be available to all people living in France, regardless of residence status. In practice, the vaccines will be free for all and no health insurance card will be required.


Although some German states have shown a willingness in principle to include undocumented migrants in their vaccination plans, no federal plan has stated explicitly that this group would be included. Moreover, federal regulations exist which require proof of residence in Germany in order to receive the vaccine.

See our blog post for more information on access to the vaccines for undocumented migrants in Germany.


The Hungarian vaccination strategy does not mention undocumented migrants. The vaccination booking system requires both a valid social security number, which is not available for undocumented people, and a registered home address, which can be very difficult for them to prove. Furthermore, civil society has warned of indications that the registration data will be checked against data held by the immigration authorities.

See our blog on the situation in Hungary for more detailed information.


The Italian vaccination strategy doesn’t mention undocumented migrants explicitly. But the Italian Immigration Act (Testo Unico sull’Immigrazione) explicitly guarantees access to the vaccines as part of preventive public health care campaigns to all people living in Italy, including irregular migrants, besides any other urgent or essential health care. And the Italian Medicines Agency (Agenzia Italiana del Farmaco, AIFA) released guidelines which make clear that undocumented people are entitled to the COVID-19 vaccines.

However, challenges remain with practical access to the online booking systems, which are managed by Italy’s 20 regions.

See our blog on the situation in Italy for more detailed information.


The Dutch strategy explicitly mentions undocumented migrants as a group to be vaccinated, but only after priority groups based on age and health conditions. Today, undocumented migrants can book a COVID-19 vaccine via the mainstream booking system, homeless shelters and, in some cases, GPs.

See our blog on the situation in the Netherlands for more detailed information.


Undocumented migrants are not mentioned explicitly in the Norwegian vaccination strategy. However, under the law on communicable diseases, all people regardless of residence status are entitled to vaccinations. In addition, in spring 2021, the Norwegian Directorate of Health addressed a letter to all local and regional health authorities calling on them to make the vaccines available for everyone. However, the letter does not detail how to organise access to the vaccines for undocumented migrants in practice. In fact, booking an appointment for the vaccine requires a valid personal identification number, and being registered with a GP. Both are broadly unavailable to undocumented migrants. In large part, the chance of undocumented migrants being vaccinated is determined by the local municipalities and their motivation to find ways around bureaucratic barriers. The risk of immigration consequences when accessing the vaccines is virtually non-existent, since it’s illegal for medical staff to report undocumented patients.

See our blog on the situation in Norway for more detailed information.


According to FAQs on the vaccines published on the Polish government’s website, “Foreigners with the right to stay are vaccinated on the same terms as Polish citizens”, which implies that people with irregular status wouldn’t be included. Polish officials have further confirmed this on TV interviews. However, the Ministry of Health later stated that access to the vaccines does not depend on health insurance, which would allow undocumented migrants to get their shot.

Read our blog on Poland to understand legal and practical barriers to the vaccines.


The Portuguese government launched an online platform which undocumented people living in the country can use to register for their COVID-19 vaccination, without need of a social security number. Although a welcome development, grassroots organisations have denounced the delay in establishing such a platform and fear that the lack of trust towards public authorities will prevent many from registering.

See our blog on the situation in Portugal for more detailed information.


According to the Spanish strategy, undocumented people are guaranteed equal access to the vaccines. But questions remain as to how public authorities will be able to reach this population.

United Kingdom

Government guidance states that the vaccines will be available for free for undocumented migrants, and no immigration check will be carried out in the context of the vaccination. But migrants rights groups say that practical barriers remain, including fears over fees and data sharing with immigration enforcement, because of the UK’s longstanding “hostile environment” policy that has sown distrust and insecurity, as well as the refusal of some GPs to register patients because they can’t provide certain information like proof of address, which isn’t legally required.

See our blog on the situation in the UK for more detailed information.Including undocumented people in national vaccination campaigns is essential to ensuring their success, and ultimately getting the pandemic under control. But measures limited to opening up access to the vaccine are not enough. The underlying factors that exclude undocumented people from accessing primary health care must be addressed – like burdensome administrative procedures, ineligibility for free or covered care, and exposure to immigration consequences for trying to access services.

Undocumented people are members of our communities, they are our neighbours, our friends. The pandemic has shown more clearly than ever that many work in situations of high risk that are too often undervalued – in care work, cleaning, agriculture. They have an equal right to be protected from this devastating pandemic. Ensuring access to health care for all is not only public health common sense, it is also and foremost the right thing to do.

Cover image: Adobe Stock – daniilvolkov