The COVID-19 vaccines and undocumented migrants in Germany

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 March 2021 with Christoph Krieger of Medibüro Kiel to discuss the situation in Germany. It is not meant to offer an exhaustive picture of the legal and practical context in Germany. 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.

Does Germany include undocumented migrants in its vaccination campaign?

There is little information at this stage, but no federal plan currently explicitly mentions undocumented migrants as a target group of the German vaccination campaign. Some local authorities, including in Kiel, have shown a certain openness – in principle – to vaccinating undocumented migrants as long as they meet age or health-related eligibility requirements.

At the same time, federal regulations on the vaccination strategy state that you have to either provide a registered address or at least prove that you live in Germany “under normal circumstances”, which is meant to exclude those coming to Germany specifically to get their vaccine. Undocumented migrants in many cases can’t provide a registered address, but they might be able to provide a self-certification to prove that they live in Germany.

So undocumented migrants can get the vaccine through this self-certification?

This is where it gets tricky. In Germany, undocumented migrants risk immigration consequences if they try to get non-emergency health care because our federal residence law requires the governmental body they have to go through to report undocumented patients to immigration authorities. This means that they could risk detention and deportation if they register for their vaccine.

Let’s go step by step. How would it work in practice for an undocumented person who tries to access a vaccine?

First, they would get an appointment by internet or by phone. If they meet the eligibility requirements, they would be invited to the local vaccination centre.

Once there, they would need to show an identity card or passport, not necessarily German. So it would be possible to register with a Brazilian passport, for instance.

However, they would need to show a health insurance card too. If they don’t have a health insurance card, which is the case for undocumented migrants, they would need to go to the local social welfare office and get a paper confirming that the office will pay for the vaccination. This is how it works for homeless people, for instance. Some states don’t require a health insurance card – but need proof of residence in that state, which itself is a barrier for many.

But not for undocumented migrants?

No. If undocumented people go to the social welfare office, they risk being reported to immigration authorities because of art. 87 of the Residence Act.

Germany also has a large refugee population. Are there any differences in access to the vaccines for them?

Refugees can access health care almost on the same basis as German citizens. Those who live in refugee centres are actually prioritised in the vaccination campaign. The same goes for those asylum-seekers who’ve seen their asylum request rejected. In Germany, these people get a “tolerated status”, Duldung, whereby they can access certain health care for a period of time. This includes access to the COVID-19 vaccines.

Updates from April 2021:

Following a written request introduced by German MP Klein-Schmeink (Greens), the Ministry of Health clarified in a letter that undocumented people too are entitled to the COVID-19 vaccines, as long as they are habitually living in Germany. However, Doctors of the World note that concerns and practical issues remain, most notably around providing proof of habitual residence and around data sharing with immigration enforcement.

Since April 2021, people in Germany can get vaccinated at a doctor’s office. Here, one has to show proof of cost coverage for the 20€ that the doctor gets for administering the vaccination (health insurance or other source). Undocumented migrants cannot get a proof of cost coverage from the welfare office without being reported. In theory, they could pay the 20€ themselves/out-of-pocket. In this case, doctors are not obliged to report the undocumented patient to immigration authorities. Most cities’ administrations have stated that lack of proof of cost coverage (e.g. a health insurance card or the confirmation from the welfare office) should not keep anyone from getting vaccinated. In practice, however, doctors’ offices will be hesitant to vaccinate someone without proof of identity due to administrative difficulties.

Cover: Federico Orlandi – Paxels