Companies must arrange for foreign employees to be vaccinated against measles by 31 December 2019

On 6 March 2019 Russia’s Chief State Medical Officer adopted Resolution No. 2 “On conducting a clean-up immunisation against measles in the territory of Russia”[1], whereby employers must ensure immunisation against measles for foreign employees who have not previously suffered this disease and have not been vaccinated against it or have no evidence of such vaccination. Employers must perform this obligation by 31 December 2019.

Yet, no clarifications have been issued so far on how companies should comply with this new requirement of the state authority’s ruling.

Please note that, under current legislation, vaccination is a voluntary procedure in Russia[2]. Nevertheless, the employer’s failure to take epidemic prevention measures may give rise to administrative liability in the form of a fine of RUB 10,000 - 20,000 or of an administrative suspension of activity for up to 90 days (article 6.3 of the Code of Administrative Offences).

What to think about and what to do

We suggest that employers hiring foreign nationals take action to perform the above obligation. Specifically, we recommend companies to:

• issue an order regarding immunisation against measles and make sure that foreign employees sign to acknowledge having read it;
• request that foreign employees provide documents confirming whether or not they have been vaccinated against measles, as well as statements as to whether they have already suffered the disease (if the employee has suffered measles, we believe that an internal memo from him or her to this effect may serve as sufficient evidence);
• obtain employees’ consents to or refusals to undergo vaccination;
• if necessary, enter into an agreement with a medical organisation for vaccination services. 

Help from your advisers

Pepeliaev Group’s lawyers have extensive experience of advising on all issues of labour law and migration legislation and are ready to provide necessary legal assistance on issues relating to this new development.