Aug 22 2019

Clarification of Employers’ Obligations in Monitoring Measles Immunization


At a Glance

  • In response to the rising rate of measles across the region, the Russian government has clarified that employers must follow specific rules to ensure their foreign workers are immunized against measles, including by seeking proof of their employees’ immunizations and maintaining the records until December 31, 2019. 
  • The government has issued a list of roles and occupations which cannot be performed by those who have not been correctly immunized. 
  • Employers who, during an audit, are found to have insufficiently documented a migrant worker’s immunization status may be fined from RUB 10,000 to RUB 20,000 or be subject to an administrative suspension of the company’s operations for up to 90 days. 

The situation

The Russian Federal Service for Supervision of Consumer Rights Protection has clarified the obligations of employers who employ foreign nationals to ensure their migrant workers are immunized against measles, or have previously had or been immunized against measles.

A closer look

  • Immunization records. As a result of the clarified obligations, employers that employed foreign nationals in 2019 should ensure that their foreign workers confirm that one of the below applies by obtaining the employee’s vaccination certificate by December 31, 2019, in case of a government audit:
    • They have previously had measles;
    • They have previously been immunized against measles;
    • They have a medical reason against immunization; or
    • They have signed a written refusal of measles vaccination form (issued by Russian medical organizations).
  • Other requisite documentary evidence. The regulation also lists additional documentary maintenance requirements related to the medical organization which provided the immunization services; and official signature requirements for any medical documents submitted. Documents issued outside Russia must be apostilled and accompanied by a notarized translation.
  • Occupation restrictions. The government has also issued a list of jobs and occupations which cannot be performed by foreign workers who have not been properly immunized. Foreign nationals not in jobs on the list can refuse the immunization requirement by providing a specified written document.
  • Refusal. Foreign nationals have the right to refuse immunization without negative consequences by providing a written form which is issued by Russian medical organizations.


Impact for employers

Employers found to have insufficiently documented a foreign worker’s immunization status during an audit may be fined RUB 10,000-RUB 20,000 or be subject to an administrative suspension of the company’s operations for up to 90 days.

After December 31, 2019, employers that employ foreign migrants should continue to maintain sufficient documentary evidence concerning immunization against measles for each foreign national.


  • Regional vaccine requirements. Vaccinations requirements for measles for foreign workers has been in existence since March 2019 in response to the resurgence of measles in the region over the past few years.
  • Global vaccine requirements. Some countries, such as Singapore, also require measles vaccinations, and others require testing for other conditions, such as the United Kingdom, which requires specific nationals to confirm they are free from infectious tuberculosis before entry.


Looking ahead

If the World Health Organization’s risk assessment of measles in Europe remains at Grade 2 (emergency response), other countries in the region may also consider introducing stricter immunization requirements and imposing financial penalties against employers who fail to provide documentation of measles immunization.

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].