In July 2021, the Ministry of Labour and the Federal State Agency for Health and Consumer Rights issued a joint letter on the rules of employee vaccination. The authorities aimed at an 80% vaccination rate and outlined that employees who refused vaccination without a medical reason, should be suspended from work without pay. This act was broadly quoted in the media and resulted in a spike in the vaccination rate. Later on, in its letter of August 10, 2021 N 14-2/OOG-7691 the Ministry of Labour clarified that the above rules are only recommendatory by nature and do not create new obligations for employers and employees.

Key Action Points for Human Resources and In-house Counsel

Closely monitor the situation, as it may rapidly change in the opposite direction. As per the current legislative regulation, refusal to vaccinate entails suspension only for a few hazardous professions and the sphere of education.

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