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Query by the Catalan Ombudsman concerning the issuing of EU Digital COVID Certificates for those who are unable to take COVID-19 vaccines for medical reasons


Head of Unit - C2

Ethics, Good Administration &

Relations with the European Ombudsman

European Commission


Dear Mr X,

The European Ombudsman has received a query, which is attached to this letter, from the Catalan Ombudsman concerning Regulation (EU) 2021/953 on the EU Digital COVID certificate[1].

The Catalan Ombudsman raises concerns regarding access to the EU Digital COVID Certificate for persons who, for medical reasons, are exempt from COVID-19 vaccines. People in this situation can get an EU Digital COVID Certificate only on the basis of a certificate of recovery following a SARS-CoV-2 infection or, for a short duration, on the basis of a negative SARS-CoV-2 test result. The Catalan Ombudsman notes that some EU Member States, such as Austria, Denmark and France, provide access to their national COVID certificate system for those who are unable to get vaccinated for medical reasons, as do other non-EU countries, such as Canada, the United Kingdom and the United States. 

Based on this query, we would like to ask the Commission to reply to the following questions:

(i) In the context of the drafting of Regulation 2021/953 on the EU Digital COVID Certificate, did the Commission take into account the situation of those who have a medical exemption from COVID-19 vaccines in terms of accessing the EU digital COVID Certificate?

(ii) Has the Commission provided any guidance to the Member States on how to deal with persons who currently cannot obtain an EU Digital COVID certificate because they are unable to take COVID-19 vaccines for medical reasons?

(iii) Does the Commission foresee this situation being addressed in subsequent updates of the Regulation?

We would appreciate it if the Commission could respond to this query and the questions above by 14 April 2022, if possible, so that we can forward the information to the Catalan Ombudsman. A copy of this letter, and of the Commission’s reply, will be made available on the Ombudsman’s website.

Yours sincerely,


Rosita Hickey
Director of Inquiries

Strasbourg, 11/03/2022


[1] Regulation (EU) 2021/953 of the European Parliament and of the Council of 14 June 2021 on a

framework for the issuance, verification and acceptance of interoperable COVID-19 vaccination, test and

recovery certificates (EU Digital COVID Certificate) to facilitate free movement during the COVID-19

pandemic, available at: