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 August 2021 with Neil Falzon from aditus foundation to discuss the situation in Malta. It is not meant to offer an exhaustive picture of the legal and practical context in Malta. 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 Maltese vaccination strategy say about undocumented migrants?

The Maltese vaccination strategy doesn’t mention undocumented migrants, but prioritises groups based on age and medical conditions. Undocumented migrants are also a very small group of migrants in Malta, as most persons coming to the islands gets some sort of a document confirming their presence on the territory.

But the question of the vaccination of migrants quickly became evident for us. When the vaccination campaign reached people in their fifties and forties, we started to get calls from migrants and refugees to inquire about the vaccination.

Was it possible for them to book their vaccination?

It was for migrants residing here regularly, such as those holding work permits, and beneficiaries of protection, meaning refugees and holders of subsidiary protection. To book your vaccine online, at the start of the campaign, you had to have either an ID or a residence permit number, which basically left asylum-seekers and undocumented people out.

How did you go about addressing this?

With other civil society organisations, we got in touch with the government and called for inclusive access to the vaccines, based on both human rights and public health arguments. Our first calls fell flat: the government responded that the vaccination was only for regularly residing people, and that in any case it would have been nearly impossible to reach undocumented people as they weren’t registered anywhere.

So, what changed?

Well, things changed as younger age groups got to book their vaccine. At that time, the government opened the vaccinations to all people in open reception centres and to detained migrants, regardless of their residence status. And then, out of the blue, when all Maltese citizens could have received their shot based on their age and medical eligibility, they opened up access to the public vaccination centres too. So anyone can now turn up at a vaccination centre and get their shot. In fact, thousands of migrants have been queuing to get their shot, also because we saw that many employers expected staff to be vaccinated in order to ensure a Covid-safe workplace.

Are there any other avenues for undocumented people to get their shot?

Yes, the central vaccination hub remains open. For some time, there were mobile teams administering the vaccine at various locations. These were staffed by medical students, civil servants, and civil society volunteers and were hugely successful particularly amongst the migrant communities.

Are there any practical barriers to access the vaccines for undocumented people?

Well, there’s lots of public information out there, on billboards, buses, and on civil society online ads, which is good. The biggest issue is the reluctance of some migrants to get the vaccine. From the beginning of the outbreak, we were engaged in information campaigns targeting migrants as we were aware of misconceptions and information gaps within particular communities. We face the same challenge in relation to the vaccines.

Are there any risks of immigration checks if an undocumented person tries to get their vaccine?

The government made it clear that there would be no data sharing with immigration authorities. But we don’t have a formal separation between public services and immigration enforcement.

What about people in immigration detention?

Undocumented people in immigration detention were actually the first to benefit from the government opening up the vaccination campaign to migrants. This was largely due to the fact that it was easier for the authorities to manage the vaccinations in reception and pre-removal detention places as opposed to public vaccination points: anyone residing in a centre is obviously registered and therefore traceable, which is key to administer the vaccine doses.

COVID-19 certificates are now required in Malta to access lots of services and places. Are those certificates available to undocumented migrants too?

Yes. When an undocumented person gets their vaccine, they also receive a health number which they can use to download their COVID-19 certificate from the website of the Health Ministry.

Cover: Aliaksandr – Adobe Stock

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 August 2021 with Sergio Ferreira from the Association de Soutien aux Travailleurs Immigrés (ASTI) to discuss the situation in Luxembourg. It is not meant to offer an exhaustive picture of the legal and practical context in Luxembourg. 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 Luxembourgish vaccination strategy say about undocumented migrants?

The Luxembourg vaccination strategy doesn’t mention undocumented migrants explicitly, but they are now being reached by the vaccination campaign.

Was this from the beginning?

No, we actually didn’t have a great response from the government at the start of the campaign. We were only able to advance things from mid-July, thanks to internal changes in the Health Ministry.

What was agreed?

The government agreed to open the vaccination centres for undocumented people on selected days in August and in September.

The way it worked was that civil society organisations like ours gathered the contacts of undocumented people who wanted to get vaccinated. We then sent this list to the health ministry, which in turn communicated the contacts to the vaccination centres. This way, the centres could trace the administration of the doses.

How’s that going?

It’s very promising. In the first days, they were able to vaccinate some 2150 people without any particular issue. The health ministry even arranged for the security guards at the vaccination centre to wear civilian clothes, so undocumented people would more readily trust that there wouldn’t be any immigration consequences. At ASTI, we were there the first day to facilitate the process but we realised that our presence wasn’t needed after all.

Are there any other avenues for undocumented people to get vaccinated?

There will be. The government is arranging for the administration of the vaccines through GPs for free, including for undocumented people, from end of September or start of October. We’re still discussing with the health ministry how to implement this in practice for undocumented people.

Access to the GPs is already possible for undocumented people, in principle, but they would need to pay a so-called “voluntary social insurance”, which costs about 110€ per month. Through this, they can get a social security number, which they can use to access primary care, including COVID-19 vaccines at GPs. Obviously not everyone can afford to pay 110€ a month, and that’s why we’re working with other allies to call for universal health coverage. So what’s being proposed now is to open up access to the GPs for the COVID-19 vaccination, without paying this voluntary social insurance.

Are there any risks of immigration consequences for people who access the COVID-19 vaccines?

No, we even got a written guarantee from the health ministry that no data sharing would happen with other authorities. We also got a similar guarantee from the government IT centre (Centre de traitement informatique de l’Etat) which stores personal data for the purpose of delivering the COVID-19 certificates. These certificates are indeed handed to undocumented people too, on paper, at the vaccination point.

Are there any outstanding issues?

The biggest problem now is outreach. We were able to reach out to the Brazilian community, which is really engaged on access to the vaccines, and the Chinese and Balkans communities, but less so to people from originating from Africa, the Middle East and Maghreb. The government doesn’t seem particularly invested in publicising efforts to vaccinate undocumented migrants, probably because they fear that the issue would quickly become politicised.

Cover: Llibert Losada – Unsplash

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 July 2021 with Pablo Iglesias Rionda from Medicos del Mundo to discuss the situation in Spain. It is not meant to offer an exhaustive picture of the legal and practical context in Spain. 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 Spanish vaccination strategy say about undocumented migrants?

The Spanish federal vaccination strategy explicitly mentions undocumented migrants and other marginalised populations as groups to be vaccinated. They’re not identified as a priority group, and the strategy doesn’t detail how to reach them. Several regional strategies, which implement the federal framework, equally mention undocumented migrants.

Let’s look at how the booking system works.

The mainstream booking systems are managed by the regions. In some regions, the local health centres call people who are registered in the regional health care database. In others, like in Madrid, the booking can be done via an app, but it still needs a valid health insurance number.

That’s where it gets tricky for some undocumented people.

Why some?

Since 2018, a law allows for access to health care to undocumented people who can prove that they’ve lived in Spain for at least 3 months, and that their country of origin doesn’t cover their medical expenses. If you’re undocumented and you can prove these two points, then you can get a health insurance number that grants you access to some health care, including the COVID-19 vaccines.

How easy is this?

It’s not. Many undocumented migrants aren’t able to prove these points. Proving that you’ve lived in Spain for at least 3 months is already quite challenging. The means of proof are regulated by the regions, and some ask for documentation which isn’t readily available to undocumented migrants. For instance, some regions ask for registration with a local municipality, which can be difficult to get if you don’t have a lease contract or other proof of residence. It’s really a chain of subsequent barriers, and you always need something to unlock the next one. And this is just the first point.

The second point, proving that your country of origin won’t cover your medical expenses, can be even more challenging. To prove this, you need to get a certificate from your country of origin, and for certain countries, this document is not provided by the embassy. So it means that you have to go back to your country of origin to get it, and then try to enter Spain again, with no more regular ways to get here than there were at the first attempt.

And then it’s not just undocumented migrants who face challenges in accessing health care, and the COVID-19 vaccines.

Do you have other groups in mind?

Yes, for instance those who arrive to Spain as part of family reunification. These are people who in principle would have a residence permit in Spain. Partners and children who come to Spain via family reunification are covered by public health insurance, but parents are not. As parents, they’re often older than the average, and at higher risk of developing strong COVID-19 symptoms. But they face greater hurdles to access the vaccination, since they wouldn’t be registered in the public health databases.

Are regions trying to reach out to undocumented people, beyond the mainstream booking system?

There are some good practices at the regional level. Most regions are proposing that NGOs like Medicos del Mundo act as a bridge between undocumented people and the health care system. At Medicos del Mundo, for instance, we have contacts of undocumented people we work with, so we provide their telephone number to regional health care authorities, who will call them and administer the one-dose Jansen vaccine in mainstream vaccination points. But we don’t have access to all undocumented people of course. So while this cooperation with NGOs is useful, it has to be complemented by broader outreach campaigns.

Are there any particular groups that would be harder to reach?

Well, for instance, undocumented people working in secluded areas like the fields in southern Spain. The regions should deploy medical teams to those areas. Then there are undocumented sex workers, and homeless people too. We’re asking the authorities to develop a protocol to reach these and other marginalised groups.

Are there any risks of immigration checks as a result of people accessing the COVID-19 vaccines?

No, our data protection framework has an absolute prohibition for immigration authorities to get and use personal data from health care providers. That said, media have recently reported that in Ceuta some hospitals have been calling the police when an undocumented person couldn’t provide proof of coverage for their health care.

Cover: Harrison Fitts – Unsplash

“No one is safe until everyone is safe”

On 10 July, Commission President Ursula von der Leyen announced in a statement that the EU had received enough vaccine doses to vaccinate 70% of its adult population. She also acknowledged that the virus “is not yet defeated” and that now “member states must do everything to increase vaccinations”, adding “nly then will we be safe.”

This echoes the mantra of the World Health Organisation (WHO) and other international bodies over the last several months that “none of us will be safe until everyone is safe” – a simple statement of the need for solidarity and equity to be at the heart of our collective response to the pandemic, at both the global and national levels.

What about people with irregular residence status?

International and regional public health and human rights bodies have, since the end of 2020, been vocal about the need for inclusive and equitable vaccination schemes, as a matter of public health, fairness and human rights; and have published guidelines about how to achieve this for people with irregular migration status, who have long faced major barriers to accessing health care. Click here for a more detailed picture of existing recommendations.

In Europe, vaccine strategies vary considerably, with wide variation in governments’ approaches to inclusion of undocumented people. Despite important gaps, promising practices have emerged in several countries to promote access by undocumented people and others facing various forms of systemic exclusion to COVID-19 vaccines. Below is an overview of some of those promising practices.

1. Proactive measures to address legal, practical barriers to access. The United Kingdom announced in February that all UK residents could access the vaccine for free, regardless of their migration status, with only a requirement (for those without a national health number) to register with a general practitioner. This was reflected in official national guidelines. Access has, however, been hampered by fears linked to the “hostile environment” and the fact that most GPs refuse to register undocumented patients because they cannot provide documentation, such as a valid residence permit, even if this is not required by law.
2. NGOs, community-based organisations actively involved by governments in the definition of strategies. In Belgium, the federal government was receptive to the concerns of non-governmental and community-based organisations and collaborated with them from early on in the development of its strategy and approach; and the Brussels region has worked proactively with local organisations to craft practical solutions for ensuring that undocumented people and others facing exclusion can get the vaccinated, including through mobilisation of mobile clinics.
3. Clear instructions from governments and health authorities about entitlements and how to ensure undocumented people get COVID-related care. In Spain, the federal vaccination strategy explicitly mentions undocumented migrants and other marginalised populations as groups to be vaccinated. It doesn’t, however, detail how to reach them. While there are examples of inclusive approaches in some regions, non-governmental organisations have been pushing for clear guidelines from the Ministry of Health to the regions to address inconsistencies in practices that lead to exclusion.
4. Clear commitment and communications that personal data will not be shared with immigration authorities or otherwise used for purposes not related to public health. In Ireland, the Minister of Health stated clearly that there would be no immigration consequences for people coming forward to be vaccinated, and encouraged undocumented people to do so. During the lockdowns in 2020, Ireland had already announced that undocumented people could access COVID19-related care without risk of data sharing with immigration authorities – and that they would be included in the country’s Pandemic Protection Program for workers who lost their jobs. In Germany, the Munich municipality confirmed in writing that there would be no immigration checks on undocumented people who would try to access the vaccines.
5. Straightforward and flexible procedures, with limited documentation requirements. Portugal published a COVID-19 vaccination registration website where undocumented people can book their vaccinations, and which is adapted to be less burdensome in terms of the information that must be provided (address, birth date, phone number and nationality). According to official figures from June, more than 19000 undocumented migrants had registered via the website, often with assistance from local NGOs.
6. Communications campaigns tailored to the needs of diverse groups. Because undocumented people generally do not have access to mainstream health systems, they often also do not have ready access to health-related information. They may also have limited access to online sources of information. So it’s essential that information about the pandemic and about the COVID-19 vaccine – its safety and efficacy, who is eligible to receive it and how – is tailored to address these barriers, and made available and accessible in multiple languages to promote awareness and understanding, address vaccine hesitancy.

The COVID-19 vaccination strategies are spotlighting pre-existing gaps and inequities in national health systems across countries in Europe, and at least in some cases tensions between immigration control and public health and equity imperatives. Some countries have been proactive in trying to fill gaps in the context of the pandemic and vaccination programs, in particular. This is a key moment to think not only about a more equitable pandemic response, but sustained and systematic efforts to repair the cracks in our health systems, and to prioritise need over status in defining and implementing rights to care.

Cover: Adobe Stock – bernardbodo

International and regional public health and human rights bodies have, since the end of 2020, been vocal about the need for inclusive and equitable vaccination schemes, as a matter of public health, fairness and human rights; and have published guidelines about how to achieve this for people with irregular migration status, who have long faced major barriers in accessing health care.

For instance:

According to World Health Organisation (WHO) guidance from June 2021, “Striving for equity in vaccine access should be a guiding principle for all countries to adequately protect groups experiencing greater burden from COVID-19 disease irrespective of legal status including refugees, asylum seekers, internally displaced persons (IDPs), migrants, stateless persons, as well as people living in areas under the control of any non-state armed group.”

International human rights experts have highlighted that: “In the context of establishing criteria for vaccines prioritization, attention must be given to those migrants who are most exposed and vulnerable to the SARS-COV-2 due social determinants of health, such as migrants in irregular situations, low-income migrants, migrants living in camps or unsafe conditions, in immigration detention, migrants in transit.”

The International Organisation for Migration (IOM) has documented seven main barriers to migrants’ access to COVID-19 vaccines including administrative or policy barriers, informational barriers and mistrust, and fear of arrest or deportation. In December 2020, the IOM had called for full inclusion of migrants, regardless of status, in national vaccination strategies.

The European Centres for Disease Control and Prevention (ECDC) devoted a report to increasing uptake of the COVID-19 vaccines among migrants, noting that “onsideration needs to be given to ensuring equitable access to and uptake of testing for COVID-19, and for COVID-19 vaccines, particularly in migrants excluded from, or facing barriers to accessing health systems”, noting the “urgent need to share models of good practice and lessons learned from across the Region.” Moreover, “or migrants who face barriers and exclusion from mainstream health systems – including undocumented migrants, asylum seekers/refugees, and those residing in camps and detention facilities – mechanisms will be required to ensure they are meaningfully included in national response plans to reduce transmission.”

For an overview of international and regional guidelines on inclusive responses to the COVID-19 pandemic, click here.

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 July 2021 with Lefteris Papagiannakis of Solidarity Now to discuss the situation in Greece. It is not meant to offer an exhaustive picture of the legal and practical context in Greece. 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 Greek vaccination strategy say about undocumented migrants?

The Greek vaccination strategy says nothing about undocumented migrants. This is something we, and other NGOs, try to raise every time we meet with public health officials, but the political environment is very hostile. There’s like an allergy to talking about undocumented migrants.

How does the mainstream booking system work? Is that accessible to undocumented migrants?

To register for your COVID-19 vaccine, you need a social security number. This is needed whether you book it online, at citizens’ services centres or pharmacies. EU citizens and refugees can access a temporary social security number, but many may not have it in practice for bureaucratic reasons. For undocumented migrants, such a number is not available.

Greece has a large migrant population who live in so-called refugee camps. Is anything being done to reach those people?

Vaccinations against COVID-19 have started in main camps in mainland, but they don’t reach everyone. For instance, people who get a second rejection of their asylum claim are not given the vaccine.

A lot depends on the person’s residence status, which is a complex matter in Greece, and especially inside the camps it can change from one day to the other.

Are there any risks of immigration enforcement as a result of people trying to access the vaccines?

We don’t have a formalised ban against public services sharing personal data with immigration authorities. So it can happen that undocumented patients get reported. But this is almost a non-issue in the case of the COVID-19 vaccines, as undocumented people aren’t even able to book their shot.

Update from September 2021:

Since July, the Greek government has established and convened meetings of working groups to discuss access to the COVID-19 vaccines for undocumented migrants in the country. Despite this positive step, no practical measures have been implemented to address persisting challenges.

Registration still requires having a social security number, and so remains problematic. Under a circular issued in May, undocumented people with documents from their country of origin can use them to register for a social security number to book and get their vaccination. But some do not have even these documents – and for many who do, they are fearful of registering because of possible immigration consequences.

Furthermore, specific groups of undocumented migrants face different challenges, depending on if they live in the “camps” on the islands or mainland; in the city, where many work in the hospitality sector, or as domestic workers, or vendors; or in more remote regions on farms doing seasonal work.

Humanitarian organisation INTERSOS has launched the campaign “Vaccines for All” to open up access to COVID-19 vaccines for undocumented people in Greece. The campaign calls for the removal of existing barriers to vaccinations, including simplified registration, and a clear statement from the government that everyone in Greece can be vaccinated, without fear of immigration consequences. It also aims to raise awareness and build trust among migrant communities around the vaccination. The campaign is joined by the Greek Forum of Migrants and the Greek Forum of Refugees as implementing partners.

Update from November 2021:

On 2 October 2021, the Greek government published Law 4839/2021, which includes a provision making it possible for undocumented people and stateless persons in Greece to obtain a provisional social security number (PAMKA) so that they can register for COVID-19 vaccination.

The law (Article 32) law indicates that undocumented migrants will not be deported if they seek access to the vaccination process. Undocumented migrants will be issued a PAMKA exclusively for the COVID-19 vaccination, the receipt of the relevant certificate and for receiving COVID-19 self-tests.

The law (Article 31) foresees that NGOs and municipalities will have a role in the delivery of the COVID-19 vaccines. But the practical implementation has to be detailed in a future joint ministerial decision from the Ministers of Health, Digital Governance, Labour and Social Affairs, and Migration and Asylum.

The measure has been welcomed by advocates as a positive step towards addressing systemic barriers faced by undocumented people in getting the COVID -19 vaccines in Greece, although there is frustration that the inter-ministerial decision needed to implement the law has yet to be agreed. In the meantime, migrants’ rights organisations are rolling out community-based initiatives to inform migrants in Greece of their rights, to address their questions about the vaccine and to encourage strong uptake when it becomes available.

Humanitarian organisation INTERSOS continues the campaign “Vaccines for All” for the COVID-19 vaccines for undocumented people in Greece, including updating the website Vaccines for All daily with information and latest news on vaccination against COVID-19, translated into different languages. The campaign is joined by the Greek Forum of Migrants and the Greek Forum of Refugees as implementing partners.

Cover: Christophe Meneboeuf – http://www.pixinn.net

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 Magda Faltová of Migrace to discuss the situation in the Czech Republic. It is not meant to offer an exhaustive picture of the legal and practical context in the Czech Republic. 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 Czech vaccination strategy say about undocumented people?

The Czech vaccination strategy  doesn’t say anything about undocumented migrants unfortunately. As the vaccination campaign stands now, only people with public health insurance, and – as of 11 June – regularly residing migrants with private health insurance, are able to access the COVID-19 vaccines.

So the mainstream booking system isn’t accessible for undocumented people?

The mainstream booking system provides two main avenues to register: neither is accessible for this population because of the data they require.

The first one is an online portal, which requires a national ID number or a passport number that is already registered in the national database, and then a public health insurance number.

The second avenue is through GPs, who can administer the vaccines themselves. However, to get the vaccine, you would still need to provide a national ID and public health insurance number at the doctor’s office.

Even if you somehow managed to book your vaccine, staff at the vaccination centre would still check your ID and public health insurance card.

Is anything being done for undocumented people?

On 30 June, the Ministry of Health sent a letter to regional authorities stating that they can also vaccinate migrants without health insurance. But nothing was said as to how to practically organise this or how to reach this group.

What’s more, the regions don’t want to pay for the administration of the vaccines to this population. So now authorities at different levels are discussing how to cover these costs.

The Prague Municipality is currently piloting a scheme where local social services administer the vaccines to people without health insurance.

If vaccines at some point become practically available for undocumented migrants too, would they risk facing immigration checks?

In theory, the mainstream booking system doesn’t transfer data to the immigration authorities. But it’s unclear what happens with the vaccination certificates, which are needed for people to access a whole range of services and places in the Czech Republic, and which is administered by the Ministry of Health. And it’s unclear what impact the new EU Green Pass will have on the processing of data of vaccinated people.

Our concern is that the Ministry of Interiors won’t hesitate to use such data, should it be stored somewhere.

Cover: Adobe Stock – JackF

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. In this blog, we’re looking at the situation in Brussels, Belgium, with the help of various national level actors. It is not meant to offer an exhaustive picture of the legal and practical context in Belgium. 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 Belgian vaccination strategy say about undocumented migrants?

In March 2021, the Belgian Federal Health Minister confirmed in Parliament that the COVID-19 vaccine would be available to all undocumented migrants. Then, in April, the Secretary of State of Asylum and Migration, Sammy Mahdi, confirmed again that undocumented migrants in Belgium would be able to get vaccinated. Secretary Mahdi also stated that police would not be involved in the vaccination process. Since these declarations, the Brussels-Capital region has come up with various strategies to implement its vaccination campaign to include undocumented migrants and other groups facing social exclusion.

What is the approach in Brussels?

One aspect of the vaccination strategy in Brussels is to use mobile teams, or “Mobivax”, to administer the Johnson & Johnson vaccine – which can be given in a single dose – to undocumented migrants and others facing barriers to vaccination in the region. Mobile vaccination teams began vaccinating homeless and undocumented people on 19 May.

Why mobile teams?

The use of mobile teams facilitates the vaccination of people who may be unable to reach vaccination centres by themselves. This can be because of  different reasons, such as physical or mental illness, or reluctance to venture to centres for fear of encountering the police and, for undocumented people, the risk of immigration enforcement. In this way, the use of mobile teams can alleviate vaccine hesitancy amongst undocumented migrants and increase their uptake of the vaccine. Among the sites the mobile teams will prioritise will be accommodation centres for homeless people and informal centres or “squats”.

The mobile teams are being coordinated by a consortium of organisations including Médecins du Monde, Médecins Sans Frontières, the Red Cross, and the Samusocial (which runs shelters and provides related medical care), all of which have been collaborating closely with the government since the beginning of the pandemic to devise strategies to reach people who face barriers to getting vaccinated. Each Mobivax team includes two cultural mediators to facilitate dialogue with the target group.

Why use a single-dose vaccine?

Using the Johnson & Johnson single-dose vaccine is more conducive to reaching people who do not have a fixed address, which otherwise greatly complicates the administering of a second dose. Factoring in those without permanent housing is especially important given the relatively large numbers of people living in precarious residence in Belgium: in 2015, it was estimated that there were between 85,000 and 160,000 people in precarious housing, and estimates show that around 50% of people experiencing homelessness in Brussels are undocumented.

While the merits of using mobile teams are clear, they should be paired with other measures, such as making vaccination centres better equipped and more accessible.

How can undocumented migrants register?

To register for a COVID-19 vaccine in Belgium, a person must provide their national number (numéro bis).  While this number is visible on one’s official national registration card, it is also possible to get the bis number without having a national card, and without any immigration consequences. You only need to provide basic information, and it is usually used for people who do not have citizenship but can access health care and social security. The bis number is also easy for GPs and local authorities to create.

That being said, there is a need for greater awareness about the existence of the bis number and the avenue to vaccination it creates. And in practice the bis number is not always straightforward for undocumented people to obtain, especially, for example if they are homeless. For those who cannot register online, registration can be carried out either through the GP, or anonymously by phone for those without a doctor. After receiving the jab, a document will be issued showing proof of vaccination.

What still needs to be done?

There is an agreement between the federal government and the regions that data obtained by the health care services will not be shared with the immigration authorities for the purpose of immigration control or otherwise used for reasons not related to public health. However, some NGOs have called for clear and binding policy frameworks formalising this and for better communication and awareness-raising around this issue by NGOs and government.

Cover: Adobe Stock – MEDIAIMAG

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 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 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

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 Zuzana Stevulova of Human Rights League to discuss the situation in Slovakia. It is not meant to offer an exhaustive picture of the legal and practical context in Slovakia. 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 Slovak vaccination strategy say about undocumented migrants?

The Slovak vaccination strategy doesn’t say anything about undocumented migrants. And there haven’t been any official statements from public authorities on the vaccination of this group. Indeed, since having public health insurance is a condition for getting the vaccine, even some documented migrants are excluded, if they are covered by private (rather than public) health insurance.

So nothing is being done for the vaccination of undocumented migrants?

In early April, an amendment clarified that the Ministry of Health can expand access to the vaccines for groups of foreigners just by publishing a note. They haven’t done so yet, and it’s unlikely that they would include undocumented migrants.

Bratislava and other regions are currently operating special mobile teams to vaccinate people who are homeless and people living in socially excluded settlements (mostly inhabited by Roma people). These teams use the single-dose vaccine, Johnson & Johnson. In principle, undocumented people could benefit from this – but they don’t tend to be in touch with organisations working with the homeless (or Roma people). Most undocumented people living in Slovakia are not homeless, but rather seasonal workers who live in often low-cost accommodation provided by their employers.

How does the booking system work? Could undocumented people access it?

The mainstream booking system happens through a specific website, which is only available in Slovak. To register, you need a social security number (birth registration number) and a registered address. You also need to select your health insurance, which can be either public, or EU health insurance (for EU residents registered for residence in Slovakia).

This information is generally not available for undocumented migrants. Those who used to reside regularly and therefore had a social security number might be able to register with the old number, since the online portal doesn’t control the validity of the data provided. But this is highly hypothetical.

Let’s assume an undocumented person is able to register through their old social security number. What will happen at the vaccination point?

At the vaccination centre, you need to show your health insurance card and ID card, which is yet another barrier for undocumented people. Whether staff will actually verify its validity, that depends on the centre.

Are there any concerns regarding possible immigration checks if an undocumented person tries to book their COVID-19 vaccine?

Well, the starting point is that access to the mainstream booking system is not an option for undocumented migrants in Slovakia, because of the information that is required. The online portal isn’t connected to other public databases, and it’s unlikely that a vaccination centre would call immigration authorities in case an undocumented person tries to get their vaccine, but we don’t have a clear and formalised firewall that would prevent public services from sharing personal data with immigration authorities.

Cover: Martin Katler – Unsplash

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 April 2021 with Janine Wildschut of Dokters van de Wereld to discuss the situation in the Netherlands. It is not meant to offer an exhaustive picture of the legal and practical context in the Netherlands. 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 Dutch vaccination strategy say about undocumented migrants?

The strategy explicitly mentions undocumented migrants as one target group for the vaccination campaign. In terms of priority, they come after age, medical and professional categories, and are included in the group of homeless people.

What do you make of this?

It’s good that the strategy mentions undocumented migrants explicitly, and this was the result of advocacy early-on carried out by civil society organisations. But we also pointed out that undocumented migrants should also be prioritised based on their age and medical conditions, and not come after age and medical categories, as if those didn’t apply to them. In addition, not all undocumented people are homeless, and so they wouldn’t be reached through outreach in the shelters for homeless people.

So how can undocumented migrants get their COVID-19 vaccine in the Netherlands practically?

There are three main avenues. The first one is the one outlined in the vaccination strategy, that is in the shelters for homeless people. The Ministry of Health, in cooperation with civil society, has organised vans with medical teams who administer the jabs in the shelters, or other facilities managed by civil society. This process started at the beginning of June.

At Doctors of the World, we’ve been able to administer the vaccines to some undocumented migrants before this process started. But this only happened because we were able to convince local doctors, on a case-by-case basis, that these people were old enough or sick enough to be vaccinated according to the age and medical priority groups. And then only because spare doses were available.

What about the other two avenues for undocumented migrants to get vaccinated?

The second avenue is by phone. Anyone can call a public number to book their vaccination, when they are part of the priority group whose turn it is. If you don’t have a national registration number, the operator will just insert a string of 9s. Not all operators are aware of this policy, but this is what’s in the regulations.

The third avenue is through the GPs, who can help patients with a medical condition to book their vaccination. To register with a GP, you’d normally need health insurance, which includes your national registration number: this is not available to undocumented migrants, but the GP can still accept them as patients and later be reimbursed through the national health service. Because this process is quite bureaucratic, though, it really depends on the individual GP and whether or not they’ll accept an undocumented person.

Are there any risks of immigration checks when undocumented migrants try to get the vaccine?

In the Netherlands, there’s a clear duty of confidentiality for all medical staff, and privacy regulations would apply too. We haven’t heard of any case of data sharing, but fears over immigration enforcement are obviously still present among the undocumented community.

Cover: Michal Soukup – Unsplash

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 Maria Lapa of Amnesty International Portugal to discuss the situation in Portugal. It is not meant to offer an exhaustive picture of the legal and practical context in the Portugal. 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 Portuguese vaccination strategy say about undocumented migrants?

The Portuguese vaccination strategy doesn’t really mention undocumented migrants, but it does say that access to the vaccines is “universal”, meaning that it will be available to anyone who lives in Portugal. Access to health care is anyways possible for undocumented migrants under national law.

Public officials also announced that they’re working on a specific plan to identify and vaccinate undocumented migrants. In addition, the Ministry of Health created a dedicated registration platform to let undocumented people book their vaccine.

Can you tell us more about this platform?

Sure. Essentially, it’s a website where undocumented people can book their vaccination against COVID-19. The website, in Portuguese and in English, is adapted to them in terms of the data that they’re required to provide. On this website, people only need to provide their address, birth date, phone number and nationality. Civil society organizations seem to be playing an important role in helping migrants sign up to the platform.

According to official figures from June 2021, more than 19000 undocumented migrants have signed up.

Who manages the data provided in the platform?

The data is managed by the National Health Authority, which oversees the vaccination process. In the platform, they state that the data will be shared with the relevant entities and only for the purpose of the vaccination.

Where are undocumented migrants vaccinated? And are they required any specific documents at the vaccination point?

Undocumented migrants can go to the same vaccination centres as everyone else. It’s unclear what documents they’d need to provide, but since all vaccinations are pre-scheduled, my guess is that there would be a list for this population.

Are there any practical barriers for undocumented people to get the vaccine?

Yes, the coordinator of the vaccination task force has admitted that it’s been hard to identify migrants for the vaccination process. He also said that as long as the person is identified “they have every right to be vaccinated” because “the pandemic doesn’t choose nationality, race or age”. So it’s good to see these kind of positive statements from the coordinator, but I think that the success of this initiative will depend a lot on the ability of civil society organisations to reach out to migrant communities and convince them to trust the process enough to agree to sign up for vaccination

Cover: Unsplash – André Lergier