Salud por Derecho

Swedish Red Cross

Incertidumbre legal, salud mental y resiliencia

Statut migratoire précaire, santé mentale et résilience

Insecure residence status, mental health and resilience

COVID-19 certificates and undocumented migrants: for some, the risk is more exclusion

This post was written by Jamie Slater, former Advocacy Trainee, and Alyna Smith, Deputy Director.*

Since the EU Digital COVID Certificate Regulation went into effect on 1 July 2021, several Member States have used vaccine certificates to determine access to services and civic spaces. While many see this as a way to boost uptake of the vaccine among those hesitating, this is not true for everyone. For those already facing barriers to the vaccine, like undocumented migrants, requiring vaccination certificates to access public services and civic spaces compounds pre-existing exclusion. It also raises concerns about the increased policing of these spaces to the detriment of fundamental rights, particularly for groups already facing criminalisation.

In many European countries, registering for the vaccines is itself a challenge for undocumented people who cannot produce a social security number, national identity document or, in some cases, proof of a home address – common requirements to get the Covid-19 vaccine. Even if undocumented migrants can register, countries often have no specific policy safeguarding their personal data from being transmitted to immigration authorities. These barriers occur against a backdrop of extremely limited access to health care in Europe for undocumented people, and the pervasive risk of exposure to deportation, including by accessing services.

Undocumented people who do manage to get vaccinated cannot always get a digital COVID certificate. One barrier is due to limited access to the technology needed to obtain or display a digital certificate by some.  Another is that health databases themselves may not allow undocumented migrants to obtain digital certificates. In Italy, the code issued for “Temporarily Present Foreigners”, used by undocumented migrants to get health care, is not always recognised by the health ministry as valid for obtaining the country’s “Green Pass”, which is needed to access a panoply of public spaces and services, including workplaces and public transit.

On 9 June 2021, France became one of the first countries in Europe to implement its COVID-19 certificate system, requiring people to present a pass sanitaire (“health pass”) to use public transportation, enter restaurants, cafes and indoor public spaces, and for employees who work in these public spaces. While people from the age of 12 are required to present the pass sanitaire, unaccompanied children seeking recognition of their status as minors cannot request vaccinations without a legal representative’s authorisation, leaving children between 12 and 18 without a legal representative effectively excluded from civic and other public spaces. Both the French Ombudsperson and the French national medical association expressed concerns around the risks of further exclusion of marginalised and poorer populations.

Concerns over data protection and immigration checks may also deter undocumented people from registering for the certificate. In the Czech Republic, it is unclear – even more than half a year after the implementation of the policy – if data submitted when applying for the certificate would be transmitted to immigration authorities. Even when there are clear safeguards in place, data security breaches – such as in Germany recently – may nourish existing fears and dissuade people from getting the certificate.

There are also worries about the increased policing of certain spaces and the risk of more exclusion and discrimination. One advocate in Austria noted that virtually every kind of document check can foster fears of immigration consequences, and expressing concerns over increased random certificate checks by police in public spaces, which could equally increase the risk of ID checks and of immigration consequences. Advocates in Hamburg, Germany, have reported high levels of stress and exclusion from public services (including public transportation) among undocumented migrants because of the so-called “3G rule” that requires a person to certify they have been vaccinated, cured of COVID-19, or have tested negatively. These certifications are accompanied by ID checks. Because undocumented people often cannot provide identification and may not be able to provide the needed proof (including because they cannot obtain a vaccine certificate), they are effectively excluded from public services.

While in some countries vaccine updates increased after the imposition of vaccine certificates among certain segments of the population, this is not the case for everyone. Pre-existing inequalities disparately affecting ethnic minorities and people with lower incomes have an impact on vaccine uptake. A recent study conducted in the UK shows that vaccine certificates are predicted to cause certain groups, including black British ethnicities and non-English speakers, to be less likely to get vaccinated. For undocumented people, this is compounded by barriers to vaccine registration, distrust of authorities and risks of immigration enforcement – not to mention, in most countries, longstanding exclusion from national health systems due to their immigration status.

In the case of undocumented people, vaccination certificates are ill-suited to addressing vaccine inequities and restrict fundamental rights in ways that may not be necessary or proportional to achieving our public health goals.

We’ve seen that the way to boost access to and uptake of COVID-19 vaccines for undocumented people is to partner with local organisations to develop and implement programs that reach people where they are, and proactively address the systemic barriers they face. Public health overall would be strengthened by enabling undocumented migrants to receive reliable, clear information about the pandemic, the vaccines and their rights, from sources they trust – and our collective resilience to health emergencies improved by removing the systemic barriers they face to the health system.

* The content of this post was further adapted into an op-ed that was published on Al Jazeera under the title COVID-19 policies need to be inclusive of undocumented people. For the past year, PICUM has been working with national organisations to document COVID-19 vaccination programmes and their inclusiveness of undocumented people – including examples of promising practices. For more information and resources, visit COVID-19 and undocumented migrants in Europe.

Cover image: ROMUL014 – Adobe Stock 

The COVID-19 vaccines and undocumented migrants in Finland

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 November 2021 with Meri Korniloff, Programme Coordinator at Physicians for Social Responsibility in Helsinki, to discuss the situation in Finland. It is not meant to offer an exhaustive picture of the legal and practical context in Finland. Please get in touch at info@picum.org if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates

What does the Finnish vaccination strategy say about undocumented migrants?

The Finnish vaccination strategy does not specifically mention undocumented migrants. But the Ministry of Health addressed a recommendation to the municipalities to grant access to the vaccination to people whose residence is not officially registered in a given municipality, which includes undocumented people. At Physicians for Social Responsibility, we advocated at the local level to ensure meaningful implementation of this recommendation.

Can undocumented people access mainstream vaccination points?

They can, but it depends on the booking system. Booking online requires official identification, which is largely not available for an undocumented person in Finland. As a result, it is extremely difficult for undocumented migrants to access the mainstream online booking system. It is possible to book by phone, but then contact with the operator can be challenging if the patient doesn’t speak Finnish, Swedish or English and doesn’t know the health care system.

Are there other possible avenues?

Yes, there are two alternative avenues for undocumented migrants to access the vaccine.

The first one is drop-in vaccination points, where people can go and get their vaccine without the need to book an appointment. These vaccination points were opened at a later stage of the national vaccination strategy. People who go to these dropin points can provide a temporary health number, which is given to undocumented patients by health care providers themselves at the first point of contact. Someone could also go to a drop-in centre without such a temporary health number and be able to get one on the spot. It’s still unclear if someone without any form of identification could be vaccinated at these drop-in points.

The second vaccination avenue is mobile teams composed of public health care professionals who administer the vaccines at sites operated by NGOs on specific dates. This was the result of significant cooperation between the various bodies involved. In Helsinki, for instance, the city administration organised and deployed mobile units to two specific sites where undocumented migrants are known to live; social workers informed them about this vaccination route and made sure people would come on a certain date and time; NGOs reached out to undocumented migrants too, and accompanied people through the vaccination process, including by allaying fears about the vaccines.

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

In Finland, there is a strict firewall in place, which separates health care and immigration enforcement. Health care professionals are bound by strict confidentiality rules and can be trusted to not share personal data for purposes not related to health care.

Are there practical barriers for undocumented people to access vaccines?

There are three main practical barriers that hinder access to vaccines.

First, lack of information: people living in big cities, and who are in contact with NGOs, are generally informed about the various avenues to get the vaccines and about their rights. But not all undocumented migrants have social networks or access to information. For example, those who live in other parts of Finland, especially in small towns, may not have access to such information.

Second, there continue to be fears around contacts with public authorities, including the health care system, and around the vaccination itself.

Third, administrative barriers where there are no official guidelines for health care professionals about health care entitlements.

In Helsinki, undocumented people have largely good access to the vaccines because the system already includes undocumented patients and because there are many NGOs spreading the information about entitlements to the community.

Let’s talk about COVID-19 certificates. Are they required to access places and services? Are they accessible to undocumented people?

In Finland, several restrictions have been introduced with regards to accessing places without a COVID-19 certificate, especially in response to the spread of the Omicron variant. The situation keeps changing rapidly.

It is impossible for undocumented migrants to obtain an electronic certificate from a dedicated website. But they can get a paper certificate after their vaccination at the vaccination point.

Cover image: MISTERVLAD – Adobe Stock 

Vaccinating Europe’s Undocumented: A Policy Scorecard

This blog post was authored by Francesca Pierigh, project coordinator of Vaccinating Europe’s Undocumented: A Policy Scorecard, at Lighthouse Reports.

Since March 2021, investigative nonprofit newsroom Lighthouse Reports has been working with PICUM to assess European vaccination policies and strategies, in terms of how inclusive they are of undocumented people. We embarked on a joint data journalism project to try and answer one apparently simple question: are undocumented people included in the vaccination efforts of European governments?

The answer is anything but straightforward. Policies are for the most part vague and open to interpretation. This can be a purposeful means of avoiding a charged political debate while still providing for this population, or it can be an exclusionary tactic to deny undocumented people access to the vaccines.

We collected all publicly available documentation related to the vaccination programmes (strategies, implementation plans, policies, but also statements from public health and national authorities) and assessed it through a questionnaire developed collaboratively by PICUM and Lighthouse Reports.

All answers we gathered were then cleaned, checked and validated by the team at Lighthouse Reports, where a data scientist turned them into scores. The results are 18 national Scorecards, one for each country we analysed.

The Scorecard is divided into five sections, each one attempting to assess a different aspect of vaccination policies and access for the undocumented:

  • Policy Transparency evaluates government efforts to make national vaccine policies available to the public;
  • Access for the Undocumented assesses whether language is inclusive or exclusionary and whether some of the practical barriers have been addressed;
  • Identification and Residency Requirements identifies which requirements are needed to access the vaccines;
  • Access for the Marginalised tries to understand how a country is accommodating the needs of other marginalized groups within its borders, which may or may not include undocumented people;
  • Privacy Guarantees evaluates policies related to the collection, processing and sharing of data between health and other authorities.

The overall results, and each country’s results, can be consulted at this link, where more information on the project and its methodology is also available. Across the 18 countries in the sample, the best performers are the United Kingdom and Portugal. They are the only ones which received positive scores in all categories, earning the label “Open and Accessible”. At the other end of the scale are the “Closed Door” countries: Slovakia, Czech Republic and Poland, all of which are explicitly exclusionary.

Map from Lighthouse Reports

An important note here: the Scorecard only assesses written policies, documents and materials gathered online. That means that there may be a gap between policies and practices. We know, and have been documenting, that this is the case in many countries, even in the United Kingdom, which, despite scoring highest, has made trust in authorities very difficult for undocumented people with years of the “hostile environment”.

To provide a balance to the Scorecard results, many PICUM members in the countries analysed have been contacted and asked for their expert, on-the-ground opinions. Their quotes accompany the country results, where they are available, and balance the assessment of written policies. A number of case studies will also be published across European media outlets, and they will be linked from this page.

Some of the challenges undocumented people face in accessing the COVID-19 vaccines also reflect broader barriers they have faced for years in accessing health care. Unclear policies, vague languages, lack of national directives for how to include the undocumented are all too common in the lives of those who live among us, but are uncounted and often left out of our health and social care systems. At the same time, the development of some good practices is a promising sign, and, while they may apply only to vaccine access, there are hopes – and opportunities for civil society to advocate – to expand them to other health care.

Access to health care is a human right and a person’s residence status should not determine whether this right is granted or not. The pandemic has exacerbated existing inequalities across the board, including in health care. It has also shown examples of how governments and civil society can work together to ensure that health care is accessible for everyone. It can be a turning point in recognising that we all benefit from genuinely inclusive, responsive health systems, and in states’ efforts to make this a reality for undocumented people too.

Cover Photo: Kate Trifo – Unsplash 

COVID-19 vaccines and undocumented migrants in Sweden

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 October 2021 with Ida Carlsson of Läkare i Världen (Doctors of the World), to discuss the situation in Sweden. It is not meant to offer an exhaustive picture of the legal and practical context in Sweden. Please get in touch at info@picum.org if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates.

What does the Swedish vaccination strategy say about undocumented migrants?

The Swedish vaccination strategy foresees specific vaccination avenues for people living in vulnerable situations such as homeless people, asylum seekers, refugees with humanitarian permits. Undocumented migrants are also included in this category, at least from April 2021.

Can they access mainstream vaccination points?

No, the booking system wouldn’t allow that. To book your vaccine at a mainstream vaccination point, you need a personal number and a bank ID, which you use in Sweden as a form of digital identification to access online services and for online purchases. These numbers aren’t available to undocumented people. What is available to them is a sort of alternative health care number, which they get the first time they access health care and they can use to continue accessing care, but this is not valid for the mainstream vaccination points.

Where can they go then?

It depends on the regions. In some regions, like in Malmö, undocumented people can call a primary health clinic, provide their health care number and book an appointment. In Stockholm, authorities have set up mobile medical teams which vaccinate uninsured people. Civil society organisations, like Doctors of the World Sweden, accompany them in this process.

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

In Sweden, medical confidentiality applies to everyone, and we’ve never heard of people being reported to immigration enforcement. However, many undocumented people still fear contacts with public authorities, because of perceived risks of deportation.

Are there other practical barriers?

At the start of the vaccination campaign, some people were unable to effectively access the vaccines at primary health clinics, because of lack of adequate information about their rights.

While this is no longer an issue, another obstacle is misinformation around the vaccines themselves. But this is something we observe in the general population as well.

Let’s talk about COVID-19 certificates. Are they required to access places and services? Are they accessible to undocumented people?

In Sweden, you can access any place or service without proof of vaccination. In general, the Swedish public health response to COVID-19 relies on recommendations rather than obligations. That said, COVID-19 certificates can be issued as proof of one’s vaccination, especially for travelling outside Sweden.

To access the electronic certificate from the dedicated website, however, you need either a personal number, which is only available to regular residents, or a “coordination number” which is assigned by the Swedish tax agency, on request, to people who have no registered address, which is the case for several undocumented people. In this instance, undocumented people who want to get their certificate would need to access the dedicated website, and request a coordination number by downloading, printing, filling in an posting a specific form in the mail. All this can be a complicated process for some undocumented people.

Cover photo: Adam Gavlák -Unsplash 

The COVID-19 vaccines and undocumented migrants in Austria

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 a representative of Red Cross Austria to discuss the situation in Austria. It is not meant to offer an exhaustive picture of the legal and practical context in Austria. Please get in touch at info@picum.org if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates.

What does the Austrian vaccination strategy say about undocumented migrants?

The Austrian vaccination strategy doesn’t explicitly mention undocumented migrants. But government communications about the vaccinations, on their website, on social media and flyers, state that vaccinations are free of charge for any person residing in Austria, including people without Austrian social insurance.

How does one access the vaccines?

The procedures vary between regions. In general, though, you would need to book your vaccine either through an online platform or by phone. At the beginning of the vaccination campaign, these were necessary steps to access the vaccine. Now it’s possible to get vaccinated in certain vaccination points also without an appointment. In some regions, though, you’d still need to register on the online platform even if you’re not taking the appointment.

What information does one need to provide, when booking or registering for their vaccine?

Again, it can vary slightly from region to region, but in general you’re required to give your full name, date of birth and email address, sometimes a phone number. The social security number is not required, and indeed is an optional field to fill in in the online platform.

At the vaccination point, however, you’re generally required to show an identification document, which could even be a non-EU ID. If a person would like to get vaccinated and doesn’t have an ID, the alternative is to access civil society and other initiatives that provide vaccinations to undocumented and uninsured people in all regions.

Where can undocumented people go to get their shot?

Undocumented people can in principle access the same venues that are available to the general public, including mainstream vaccination centres, medical clinics and GPs offices. In practice, it is more likely that they would access “pop-up centres” which are temporary and can be set up in buses or shipping containers. There are also initiatives organised by civil society organisations, where the access threshold is very low.

We talked about the need to show an ID card at the vaccination point. Are there other barriers for undocumented people to access the vaccines?

There are a few, yes. First of all, the vaccination points are often set up in places that are outside larger cities and are hard to get to by public transport. And some of them are only temporary, which makes it difficult for undocumented people to locate or keep track of them.

Then there’s a language barrier. The online booking platform, for instance, is only in German. More generally, the government’s communications are often not translated into many languages, beyond Turkish and Balkan languages. As civil society organisations, we try to fill these gaps through our own campaigns.

What about the risk of immigration checks for undocumented people accessing the vaccine?

In Austria, we have a very clear and formal separation between health care services and immigration authorities. However, we can’t assess the real risk of immigration consequences for undocumented migrants, and we don’t know what impact this may have on people’s willingness to access public health care. Regardless of the actual risks, the fear over immigration consequences is definitely there among the undocumented community, and this could very well represent a barrier to their vaccination.

Let’s talk about the COVID-19 certificates. How does this play out for undocumented people?

People without social insurance, which includes undocumented people, wouldn’t be able to request and download an electronic certificate. But they can get a paper version directly at the vaccination point. This obviously has its own limitations, because the paper can be lost and can be easily damaged.

Beyond whatever form the certificate comes in, for instance whether paper or on your device, there’s the whole policing of the COVID-19 certificates that poses issues with regards to undocumented people. Virtually any kind of document check can foster fears of immigration consequences; this is all the more relevant considering that those who control the validity of the certificates can also ask for an ID document.

While we don’t necessarily expect waiters and restaurant owners to carry out ID checks, we are concerned about government plans to increase randomised certificate checks by police in public spaces, which definitely increases the risk of ID checks and ultimately immigration consequences.

Cover image: SASITHORN – Adobe Stock

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 info@picum.org 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

The COVID-19 vaccines and undocumented migrants in Bulgaria

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 Diana Dimova from Mission Wings Foundation to discuss the situation in Bulgaria. It is not meant to offer an exhaustive picture of the legal and practical context in Bulgaria. Please get in touch at info@picum.org if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates.

What does the Bulgarian vaccination strategy say about undocumented migrants?

The Bulgarian vaccination strategy doesn’t mention undocumented migrants. It sets out priority groups in terms of age, medical conditions and work. Thanks to advocacy from civil society organisations, the strategy also includes refugees and asylum-seekers held in Bulgaria’s six reception centres.

Would undocumented migrants still be able to access the vaccines somehow?

Well, the health care system in Bulgaria doesn’t generally recognise people without residence or identity documents. This is also true for the COVID-19 vaccines.

The mainstream booking system is not accessible to them, because they would need to provide a social security number. There may be a possibility to still get the vaccine in so-called “green corridors”, that is vaccination centres (usually part of hospitals or other health establishments) where anyone – not according to the priority groups – could go and get the vaccine. You’d still need some documentation but it’s unclear what type, so it may be possible for someone with a foreign passport to get vaccinated.

Are there any plans to make the vaccines more accessible to undocumented migrants?

Not at this stage. We’ve been trying to discuss access to the vaccines for this group with the Directorate of Migration, in vain. We’re now planning to address letters to various bodies, including the national Ombudsman, to get some clarification on who is responsible to provide the documentation that would allow undocumented migrants to get the vaccine.

Would there be any risks of immigration consequences if an undocumented person tries to access the vaccines?

We can’t exclude it, but it seems quite unlikely given the poor communication between health care services and police authorities.

Cover: Toniflap – Adobe Stock