Based on the clarifications provided by Moscow Operation Headquarters and Rozpotrebnadzor, we provide an overview of compulsory immunization of workers in a number of industries (Moscow Chief Public Health Officer Order N 1 dated June 15, 2021 (as amended on June 23, 2021) for Preventive Vaccinations of Certain Groups of Individuals Based on Epidemic Evidence), an overview of how to calculate the percentage of vaccinated employees, whether it is possible to remove unvaccinated employees from work, and whether it is necessary to submit certificates of medical exemption.

Some employers operating in Moscow and the Moscow region must coordinate the vaccination of at least 60% of their employees:

  • Up to July 15 — first dose or single-dose vaccine;
  • Up to August 15 — second dose of the vaccine.

This applies to organizations and individual entrepreneurs engaged in trade, catering, education, healthcare, public transport, taxis, multifunctional public services centers, housing and utilities sector, delivery of goods and food (courier services), trade on sites where goods are sold to consumers, not only retail trade but also wholesale and distance trade.

Determining the percentage of vaccinated employees

At least 60% of the total number of employees must be vaccinated. The remaining 40% consist of employees with medical exemption, employees who have had coronavirus, and other employees at the discretion of employers.

If a company has regional subdivisions, the percentage of vaccinated employees must be calculated only for the employees working in Moscow, including those working remotely.

All employees working under employment contracts and contractors working under civil law contracts are included in the aforementioned 60%, including those who have already been vaccinated.

Suspension from work

Employees are entitled to decline vaccination even with no valid reason. The Ministry of Labor considers that employees must be suspended from work in such case. Moscow Operation Headquarters and Rospatrebnadzor consider that employees suspended from work should not be paid but they cannot be dismissed on this ground (i.e. for having declined vaccination).

Employers must not allow employees who refused immunization without medical exemption and are not required to pay salaries while employees are suspended from work.

Employers are entitled to offer employees to switch to remote work.

Inspections

From July 1 to July 15, employers must report vaccinated employees. Employees who have received only the first dose of the vaccine may be included in the report.

Employers operating in Moscow must submit information through their account on the website mos.ru, and those operating in the region should do so using the regional portal.

All employers will be subject to continuous inspections to check whether the information provided matches the data in the system of the Ministry of Health.

Employees’ medical exemption, past illness, and other reasons for refusing to be vaccinated will not be checked.

If companies fail to comply with the mandatory vaccination requirement for 60% of employees, their activity could be suspended for up to 90 days.

Information from Moscow Health Department of June 24, 2021 (in Russian)

How to submit information about employee vaccination

To report on staff vaccination, some employers operating in Moscow must from July 1 to July 15 complete this table and upload it to their online account at mos.ru (https://www.mos.ru/pgu/ru/app/dit/087001/).

Representatives of legal entities must use an enhanced electronic signature to forward such information while individual entrepreneurs need only to link their mos.ru account to the government services website.

When the submitted information is verified, i.e. within 3 days, a special section will appear in employers’ online account.

Organizations and individual entrepreneurs who must vaccinate at least 60% of their staff are to submit reports on vaccinated employees.

Information from Moscow Mayor website of July 01, 2021 (in Russian)

Information from Moscow Mayor website (in Russian)

COVID-19 vaccination of migrant workers has begun

Since June 27, foreign employees have been vaccinated with single-dose Sputnik  Light vaccine. Only organizations and individual entrepreneurs who must get at least 60% of their staff vaccinated can apply for the time being.

Such employees may be vaccinated in the migration center located in Sakharovo, and from June 29 this will also be done in Sadovod shopping center located at the following address: ul. Verkhnie Polya 54, Building 15.

Our specialists look forward to helping you drawing up documents for mandatory employee vaccination as well as providing advice on vaccination.

Update as of 02.08.2021:

Ministry of Labor and Rospotrebnadzor have issued recommendations for vaccinating workers against COVID-19

Government agencies have explained how to organize staff immunization against coronavirus and how to take into account the percentage of vaccinated individuals.

Informing staff Employers are recommended to explain vaccination issues in labor collectives jointly with trade unions (if available). In particular, official data on the current epidemiological situation in the region and the effectiveness of immunization can be disseminated among employees. Workers should be informed about Russian preparations against COVID-19 and vaccination centers.

Weekends can be provided for vaccination

Achieving a level of collective immunity To stabilize the epidemiological situation, the following indicators must be achieved: at least 80% of the staff list should be immune to the new infection. This includes employees who have recovered from COVID-19 and those vaccinated no more than 6 months ago. The remaining percentage may consist of those who have contraindications to vaccination and long-absent employees (such as those on maternity leave).

Organization of vaccination

If the chief state sanitary doctor of the Russian Federation subject has ordered the vaccination of personnel, the employer must first determine the list of employees subject to vaccination. Then an order should be issued for its implementation. The order should include, in particular:

  • information on the need for vaccination;
  • terms and procedure for vaccination;
  • information about the person responsible for organizing the vaccination and collecting information on its conduct.

The document should also record that an employee who refuses vaccination may be suspended from work. The order must be signed by the personnel.

Suspension from work

Vaccination becomes mandatory for citizens or certain groups of persons if the chief state sanitary doctor of the region of the Russian Federation so decides. In this case, an employee who refused vaccination without valid reasons cannot be allowed to work. An order must be issued for his suspension if he does not provide a vaccination certificate or a medical conclusion on contraindications within the specified timeframe. The basis is the Labor Code of the Russian Federation and the Law on Immunoprophylaxis of Infectious Diseases. Salary does not need to be maintained during this time.

The employer may suggest that an unvaccinated employee switch to remote work. However, this right should be primarily exercised with regard to persons with contraindications to vaccination.

Earlier, Rosturud indicated that unvaccinated remote workers may also be suspended from work.

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