The COVID-19 vaccines and undocumented migrants in France

As part of our efforts to monitor access to the COVID-19 vaccines for undocumented migrants in Europe, we’re speaking with national-level advocates about the situation in their countries. This interview was conducted in September 2021 with Houda Merimi of Médecins du Monde France to discuss the situation in France. It is not meant to offer an exhaustive picture of the legal and practical context in France. Please get in touch at if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates.

What does the French vaccination strategy say about undocumented migrants?

The French vaccination strategy doesn’t mention undocumented migrants explicitly, but it does mention people in precarious situations as a target group. This group wasn’t given a high priority for the vaccination, as the vaccination campaign was only opened to them almost at the same time as the general population, that is people younger than 50, rather than with priority groups vaccinated earlier based on age and other factors.

On the other hand, some notes from the Ministry of Health do mention migrants explicitly, following regular meetings with civil society.

So can undocumented people get a COVID-19 vaccine?

In terms of administrative access, it’s always been possible for undocumented people to get the vaccine, in principle, as no residence papers or ID documents or public health insurance are required to get the vaccine. Also, the vaccines have always been free for everyone.

Do people need to book their vaccine? And how can undocumented people do this in practice?

At the start of the vaccination campaign, people needed to go through a booking process to get their vaccine indeed. Now, in some cities it’s possible to get vaccinated without an appointment, but this varies from region to region as it’s a decision of the local health authority.

Booking one’s vaccine can be done either online or by phone. Undocumented patients only need to provide their full name, and the operator should give them an ad-hoc health number and a date for the appointment. The process has been smooth whenever we’ve been able to accompany undocumented people through it, but we’ve heard of cases where the operators have refused to book their appointment because they didn’t have a health insurance number. This is why local health authorities need to better communicate with all actors involved in the vaccination process.

Where can undocumented people go to get their shot?

There are several avenues. The first one to be set up was the vaccination centres. Then vaccination was made possible in pharmacies, at GP’s offices, in local health centres and then crucially in the so-called PASS (permanences d’accès aux soins de santé), which provide health care to uninsured people and are usually found in the hospitals. In practice, undocumented people would go more easily to the vaccination centres, if they could get an appointment, or to the PASS to get vaccinated.

In addition, some local health authorities have provided dedicated funding to the PASS centres to operate mobile medical teams, which would go where people in precarious situations live, including informal encampments, slums, squats, and on the street. Some NGO are also operating their own mobile teams to help reach out to these groups, such as the French Red Cross or Médecins Sans Frontières. Concerning Médecins du Monde, even if we have contributed to immunisation activities in some locations, our systematic intervention is rather about providing information and raising awareness around COVID-19, including the vaccination.

What about immigration risks as a result of people getting their vaccine?

In general, the French data protection regime is strong, especially for medical data. All data linked to the COVID-19  tests and vaccines is stored in the SIDEP platform, which was reviewed and approved by the French data protection authority (Commission Nationale Informatique et Libertés, CNIL). That said, certain actors are worried about the involvement of the Ministry of Interiors in the vaccination campaign, as the Ministry often co-signs the legal texts designed since the declaration of the national health emergency was developed with the Ministry of Health. One could wonder if the prefectures take any data from the regional health authorities.

And regardless of whether these are actual risks, many undocumented people do fear immigration consequences should they come forward to get vaccinated. This is obviously a major barrier to their vaccination in and of itself.

Are there other practical barriers?

There are several. The first one is the language barrier: many vaccination points don’t have professional interpreters, which is problematic. Think about the questions you’re asked when you go to get vaccinated, about your own health and medical history, information about the side effects and their monitoring: without an interpreter, we doubt that those questions are correctly posed, understood, and answered.

The second barrier has to do with the lack of adaptation of the vaccination campaign to the specific living and working conditions of many undocumented people. For many, for instance, time is a real constraint, as they may be working informally, with long or unsocial hours, with few or no breaks, which are incompatible with the opening hours of the vaccination points.

The third barrier concerns the lack of awareness of the vaccination options, and then the amount of fake news about the vaccines themselves. At Médecins du Monde, we’ve been working with the public health agency (Santé Publique France) to design and deliver tailored communications campaigns, including through online videos, leaflets and billboards, translated into several languages.

Where do unaccompanied minors fit in the vaccination campaign?

The vaccination campaign is particularly problematic for unaccompanied minors. Since the start of summer, the vaccination was authorised for people aged 12 to 18, which would in principle cover lots of unaccompanied teenagers. But a lot depends on their age, as procedures are different for children over and children younger than 16. The law is unclear as to unaccompanied minors, so what’s being done is the fruit of the interpretation of regional health authorities.

In short, those who are over 16 don’t need the parent’s or guardian’s consent to their vaccination. For those who are younger than 16, it depends. Those who were recognised as unaccompanied minors and are therefore taken in charge by child care services (aide sociale à l’enfance) need the authorisation of the director of such service. Those who are not currently recognised as unaccompanied minors should need the authorisation of a juvenile judge, but regional health authorities have interpreted this differently, accepting to vaccinate those children only with their consent and if they are accompanied by an adult of their choice.

Given all this, it’s clear that determining the age of the child becomes ever more crucial. The problem is that the age assessment procedures are often biased and inaccurate, which prevents many unaccompanied teenagers from getting vaccinated, and from accessing their COVID-19 certificate.

Let’s talk about COVID-19 certificates. The French pass sanitaire is now required to access many places and services. What does this mean for undocumented people?

In principle, undocumented people too can either download their COVID-19 certificate from an app on their phone, or get a paper version at the vaccination point upon request. But if people accidentally lose their paper after being vaccinated, it can be very difficult to get another copy because of bureaucratic shortcomings linked to the ad-hoc health number.

The biggest issue is that because of all the barriers we spoke about, many undocumented people are still not vaccinated, don’t have a COVID-19 certificate and therefore now don’t have access to lots of places and services. This even includes a more restricted access to hospitals! Hospitals have often set up different entries for people who have a certificate and those who don’t: this is where it gets tricky. These different entries are often not adequately signalled, and personnel hired to check the certificates isn’t always able – or willing – to help people without a certificate to the right entry, starting from the fact that they may not speak their language. Plus, the sheer sight of people checking documents at the entry of the hospital can scare undocumented people and ultimately keep them out.

Cover image: Phil_Good – Adobe Stock