People attend a Covid-19 vaccination campaign
© Adrià Salido / Europa Press

Vaccinating Europe’s Undocumented

Policy scorecard ranks European countries efforts to respond to Covid 19

The majority of undocumented migrants in Europe are excluded from the health systems and find themselves among the most vulnerable groups in the pandemic. While countries have rallied behind national vaccine campaigns, urging everyone to do their part to protect public health in times of crisis, undocumented people have largely been absent.

The pandemic has demonstrated the need to separate access to healthcare (and vaccines) from political positions on immigration. But how can we assess whether governments are taking this onboard?

Our policy scorecard attempts to count those who governments have decided not to count, by reading between the lines of vaccination strategies, implementation plans, policies and statements to determine, at least on paper, how easy or difficult it is for undocumented migrants to be vaccinated against COVID-19.


The scorecard is Lighthouse’s first collaborative data journalism project and the absence of meaningful data on almost all aspects of the undocumented, from population estimates to countries of origin, ruled out a direct approach like counting vaccination numbers. There has been no meaningful Europe-wide effort to count the undocumented since 2009 as we explained in a previous investigation into the Shadow Population.

The most effective avenue open to us was to construct a survey which would provide ground for a useful comparison between the performance of different European countries. To design this we consulted with PICUM, the leading European association of groups working for undocumented rights, to design a survey to capture the policy reality of European countries’ strategies to vaccinate undocumented people.

We reached out to expert researchers, community groups and journalism students to help us track down publicly available documents related to those vaccination strategies and implementation plans for every country. Lighthouse’s data team then converted the responses into numbers, and those numbers into a scorecard.

The final results cover 18 European countries, spanning 14 languages. The data collected offers a snapshot of policies regarding undocumented access to vaccination against COVID-19, across five categories: Policy Transparency, Access for the Undocumented, Identification and Residency Requirements, Access for the Marginalised and Privacy Guarantees.

Find a more detailed description of the methodology here.


To complement the scorecard, which illuminates some of the big questions and trends across Europe, we are working with media partners on a series of feature stories that provide ground reporting to bring the topic alive. The first in this series comes from Greece where a mixed ranking on the scorecard reflects a genuine effort to vaccinate the more visible undocumented communities — such as asylum seekers in publicly-managed reception facilities — but neglect of undocumented workers who are doing some of the hardest jobs in some of the country’s biggest companies.

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The Impact

Our investigations don’t end when we publish a story with media partners. Reaching big public audiences is an important step but these investigations have an after life which we both track and take part in. Our work can lead to swift results from court cases to resignations, it can also have a slow-burn impact from public campaigns to political debates or community actions. Where appropriate we want to be part of the conversations that investigative journalism contributes to and to make a difference on the topics we cover. Check back here in the coming months for an update on how this work is having an impact.