Blog: MPCAG welcome UK Covid-19 Inquiry findings on migrant barriers to vaccine access

Friday 24 April 2026

Blog post by Maha Sardar and Maria Moodie of Garden Court Chambers, who represented the Migrant Primary Care Access Group (MPCAG) in Module 4 of the Inquiry.

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Migrant Primary Care Access Group (MPCAG)

Our clients welcome the publication of the UK Covid-19 Inquiry Module 4 Report on Vaccines and Therapeutics, which recognises the serious barriers faced by migrant communities in accessing Covid-19 vaccination during the pandemic.

MPCAG are a collective of organisations seeking to raise the voice and experience of refugees and migrants and their experiences during the pandemic. MPAG are comprised of organisations Doctors of the World UK, Joint Council for the Welfare of Immigrants, Medact, and Kanlungan.

MPCAG’s evidence to the Inquiry exposed how migrants were unable to access the vaccination programme due to structural barriers: poor access to GP registration, fears of NHS/Home Office data-sharing, and the detrimental effect of the NHS charging regime.

UK Covid-19 Inquiry Module 4 Report

The Inquiry has now acknowledged those concerns. It recognised that vaccine systems relied on GP records to identify eligible people and send invitations, meaning that people who were not registered with a GP were less likely to be reached (§6.70). This was a significant problem for migrant communities, where levels of GP registration were low (§6.71).

The Inquiry recorded MPCAG’s evidence that one fifth of a sample of applications by vulnerable migrants were rejected, predominantly because of insufficient paperwork, despite the requirement that GP practices register people within their catchment area even where they lack documentation (§6.72). The Report also recognises that migrants were deterred from registering with GPs because of concerns about immigration status, as well as language barriers, lack of understanding of the UK health system and digital exclusion (§6.76). These barriers kept migrants outside the very systems used to identify, invite and inform the public about vaccination.

Crucially, the Inquiry acknowledged the damaging impact of the NHS charging regime and fears of Home Office data-sharing. It found that the charging regime in England, and its application to other non-Covid-19 conditions, appears to have deterred some migrants from seeking Covid-19 vaccination. Some migrants feared that approaching healthcare providers for vaccination would lead to their details being shared with the Home Office or to immigration checks (§6.84). The Inquiry further found that confusion about charging, lack of trust in government and concern about Home Office data-sharing contributed to vaccine hesitancy among migrants (§6.85).

These findings are important. They confirm that barriers to vaccination for migrants were structural, predictable and avoidable.

The Inquiry recommends clearer and earlier communication in any future pandemic, including reassurance that vaccination is free, that there are no immigration status requirements, and that patient details will not be shared with the Home Office when people attend for vaccination (§6.87). It also recommends targeted vaccination strategies and local community engagement to improve uptake and reduce inequalities.

Our clients welcome those recommendations, but feels that they do not go far enough.

The Inquiry recognised the problem but stopped short of the solution. Despite the evidence presented by MPCAG, the Report does not engage with the need for a permanent firewall between the NHS and the Home Office to put a stop the harmful and punitive practice of sharing clinical patient data for the purposes of immigration enforcement.

That is a missed opportunity. Communications alone cannot undo the fear created by NHS charging and immigration data-sharing. So long as data-sharing practices remain operational, fear and mistrust experienced by migrants will deter them from accessing vital healthcare services in peacetime and, critically, when the next global health emergency strikes. Migrants need a clear, permanent and legally enforceable guarantee that accessing healthcare will not expose them or their families to immigration enforcement. Public health must be prioritised over immigration enforcement for the benefit of all.

Without that firewall, the same barriers will remain, and trust will continue to be undermined. The deterrent factors are by now well known to the Government, and have been reinforced by the Inquiry’s findings, and it must act now to remove them before the next public health crisis.

The full report can be accessed here.

Migrant Primary Care Access Group (MPCAG) were Core Participants in Module 4 of the Inquiry. Their counsel team was Sonali Naik KC, Maria Moodie and Maha Sardar instructed by Ellen Fotheringham, Helen Mowatt and Alisha McSporran of the Public Interest Law Centre.

Further relevant findings include:

  • Language barriers made access to vaccination more difficult for ethnic minority communities and recent migrants: §6.64.
  • Lack of GP registration meant eligible people did not receive vaccine invitations or information: §6.70.
  • There was significant lack of GP registration in migrant groups: §6.71.
  • GP practices rejected applications where people lacked proof of address or identification; MPCAG’s evidence showed one fifth of a sample of vulnerable migrant applications were rejected, predominantly because of insufficient paperwork: §6.72.
  • Migrants were deterred from registering with a GP because of concerns about immigration status: §6.76.
  • The NHS charging regime in England and fears of Home Office data-sharing deterred some migrants from seeking Covid-19 vaccination: §6.84.
  • Confusion about charging, lack of trust in government and concern about Home Office data-sharing led to vaccine hesitancy among migrants: §6.85.
  • Similar fears may have affected migrants in Wales, Scotland and Northern Ireland: §6.86.
  • The Inquiry found that communication should have been more carefully targeted to reach migrants early, including reassurance that vaccines were free, there were no immigration status requirements and patient details would not be shared with the Home Office when attending for vaccination: §6.87.

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