The COVID-19 Vaccines and Undocumented Migrants: What Are European Countries Doing?

Last updated: March 2021

International and EU bodies have recommended addressing marginalised communities, including migrants in situations of vulnerability, in national vaccination strategies. In Europe, however, national approaches vary a lot.

For undocumented people, who are excluded from the health systems of most European countries, the pandemic and the lockdown measures have exacerbated pre-existing conditions of social exclusion and destitution. Several European countries, regions and cities adopted measures to support this population during the pandemic, including through targeted regularisation programmes. But what is being done with regards to the vaccination campaign, one of the most important tools we have to protect people against COVID-19?

We have been monitoring the news and exchanging with our members and followers, and we have compiled a map that shows which countries are explicitly including undocumented migrants in their vaccination strategies, and which ones are explicitly excluding them. Regardless of whether the strategies mention undocumented migrants or not, it’s crucial to note that practical barriers to the vaccines exist in virtually all countries.

Map showing where undocumented people can access the COVID-19 vaccine

This map is based on information we’ve been able to gather so far, and we’ll keep updating it as we know more. Here’s a quick rundown of what we’ve learned:


In early January, Brussels health minister Alain Maron said that “It’s out of question to exclude undocumented people from the vaccination process”. After this very welcome statement from a regional (Brussels) leader, the federal health minister confirmed before the Parliament that the vaccines would be available to undocumented migrants too. The Minister discussed the possibility of vaccinating this group via mobile medical teams, who would also ensure the vaccination for homeless people.


At the start of March, the Finnish Ministry of Social Affairs and Health recommended municipalities to grant access to the COVID-19 vaccines to undocumented migrants, free of charge. Questions remain as to the practical implementation of this recommendation.


The French health ministry has declared that the vaccines will be available to all people living in France, regardless of residence status. In practice, the vaccines will be free for all and no health insurance card will be required.


Although some German states have shown a willingness in principle to include undocumented migrants in their vaccination plans, no federal plan has stated explicitly that this group would be included. Moreover, federal regulations exist which require proof of residence in Germany in order to receive the vaccine.

See our blog post for more information on access to the vaccines for undocumented migrants in Germany.


News outlet Wired Italy has reported that the Italian vaccination strategy doesn’t address migrants, let alone undocumented migrants, as a target group. During an interview at the beginning of December, the Italian Commissioner on the COVID-19 crisis Domenico Arcuri declared that “It’s important that everybody, unless they’re here [in Italy] irregularly, gets vaccinated”, which seems to imply that undocumented migrants wouldn’t be included in the vaccination campaign. However, it is worth noting that under Italian law undocumented people too are entitled to access primary healthcare, including vaccines.

On 9 February, the Italian Medication Agency published an FAQ where it states that the vaccines will be available for anyone living in Italy, regardless of their residence status.


The Dutch strategy explicitly mentions undocumented migrants as a group to be vaccinated. But local civil society reports that so far very little has been done to practically implement this provision. The Rotterdam Undocumented Support Centre (ROS), for instance, declared “We regularly ask the [Amsterdam] municipality but we haven’t got a response yet”.


According to FAQs on the vaccines published on the Polish government’s website, “Foreigners with the right to stay are vaccinated on the same terms as Polish citizens”, which implies that people with irregular status wouldn’t be included. Polish officials have further confirmed this on TV interviews. However, the Ministry of Health later stated that access to the vaccines does not depend on health insurance, which would allow undocumented migrants to get their shot. Read our blog on Poland to understand legal and practical barriers to the vaccines.


The Portuguese government launched an online platform which undocumented people living in the country can use to register for their COVID-19 vaccination, without need of a social security number. Although a welcome development, grassroots organisations have denounced the delay in establishing such a platform and fear that the lack of trust towards public authorities will prevent many from registering.


According to the Spanish strategy, undocumented people are guaranteed equal access to the vaccines. But questions remain as to how public authorities will be able to reach this population.

United Kingdom

Government guidance states that the vaccines will be available for free for undocumented migrants, and no immigration check will be carried out in the context of the vaccination. But migrants rights groups say that practical barriers remain, including fears over fees and data sharing with immigration enforcement, because of the UK’s longstanding “hostile environment” policy that has sown distrust and insecurity, as well as the refusal of some GPs to register patients because they can’t provide certain information like proof of address, which isn’t legally required.

Including undocumented people in national vaccination campaigns is essential to ensuring their success, and ultimately getting the pandemic under control. But measures limited to opening up access to the vaccine are not enough. The underlying factors that exclude undocumented people from accessing primary health care must be addressed – like burdensome administrative procedures, ineligibility for free or covered care, and exposure to immigration consequences for trying to access services.

Undocumented people are members of our communities, they are our neighbours, our friends. The pandemic has shown more clearly than ever that many work in situations of high risk that are too often undervalued – in care work, cleaning, agriculture. They have an equal right to be protected from this devastating pandemic. Ensuring access to health care for all is not only public health common sense, it is also and foremost the right thing to do.


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Cover image: Adobe Stock – daniilvolkov

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