The COVID-19 vaccines and undocumented migrants in Italy

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 June 2021 with Marco Paggi, lawyer at Associazione Studi Giuridici sull’Immigrazione (ASGI) to discuss the situation in Italy. It is not meant to offer an exhaustive picture of the legal and practical context in Italy. 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 Italian vaccination strategy say about undocumented migrants?

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.

So, all good?

Not really. The online booking platforms, which are managed by Italy’s twenty regions, in most cases still require information and documents which are unavailable to most undocumented migrants. In some regions, for instance, users have to enter their social security number (codice fiscale), which is only available for regularly residing people.

As part of a coalition of NGOs that advocates for access to health care for migrants in Italy (Tavolo Immigrazione e Salute), we have written to the Ministry of Health to ask for clear instructions for the regions to open up their online booking platforms, but we haven’t got any response from the national government yet.

Are there any good examples at the regional level?

Yes, in Apulia, Campania, Sicily and Veneto, for instance, undocumented migrants, both EU  and non-EU nationals, can book their vaccines online. Lombardy has recently opened the registration for undocumented non-EU nationals, while it’s unclear if irregular EU nationals can access the registration too. More regions are opening up their online booking platforms to this population, including most recently Friuli Venezia Giulia and Tuscany.

How do they do this?

Where access to the platforms is possible, undocumented migrants only have to enter their STP (Straniero Temporaneamente Presente, or Temporarily Present Foreigner) card number, which is provided to any undocumented migrant who approaches local health authorities, which also conduct some administrative services. There’s also a specific number, the ENI (Europeo Non Iscritto, or Non-Registered European) number, which is provided to those European citizens who live in Italy but cannot be registered with a local municipality because they lack the administrative requirements to do so. They too can book their vaccine online, but only where the platform allows them to enter their ENI number.

Are these online booking platforms the only way for an undocumented migrant to access the COVID-19 vaccines in Italy?

There are some local initiatives which aim at reaching out to undocumented people to vaccinate them. For instance, the Rome administration, in cooperation with local NGOs, has set up special vaccination facilities. The Veneto region asked local health authorities to agree with local NGOs – as has already happened in some provinces – ways of providing direct access to vaccines for irregular foreigners or those without a health card.

But staff is largely made up of volunteers, and these initiatives depend on the availability of specific vaccines. Most of them rely on the Johnson & Johnson vaccine, because it only requires one dose and is therefore easier to administer logistically. But when the use of this vaccine was suspended because of concerns around its side-effects, these initiatives were stopped too as a result.

The initiatives implemented so far cover only part of the national territory and remain difficult to implement effectively. Yet they’re still crucial to reach some undocumented groups who wouldn’t be able to access the online booking systems.

Do you have a specific group in mind?

Well, for instance the farmworkers who work in the fields all across Italy, who often live in informal settlements. Many of them may have a residence permit and STP card issued in a province far away from where they work, which makes access to local health facilities more challenging.  Others don’t even have an STP number, because they may not be aware of it and never requested one, and so wouldn’t be able to book their vaccine even if the online platform allowed them to. For this group, NGO initiatives may be the only way to effectively access a COVID-19 vaccine.

Are there any concerns around potential immigration checks if an undocumented person tries to access the COVID-19 vaccines?

No. The law is very clear in this sense. Article 35 of the Immigration Act (Testo Unico sull’Immigrazione) forbids any data sharing with police and judicial authorities. Indeed, the STP number is released to any undocumented migrant so they can access public health care safely.

Cover: Christopher Czermak – Unsplash