Statement from the Frontline Migrant Health Workers' Group on the Covid-19 Inquiry Module 3 Report

At midday today, Thursday 19 March 2026, the Covid-19 Inquiry released its Report on Module 3 which focused on healthcare workers. The Frontline Migrant Health Workers’ Group (FMHWG), which is composed of the Independent Workers' Union of Great Britain (IWGB), United Voices of the World (UVW) and Kanlungan, represented the experiences of migrant health workers during the pandemic.

Our members — low-paid, precarious migrant workers, primarily from Black, brown, and other ethnic minorities — were severely impacted by the pandemic. In the first months of the pandemic, 83% of the ethnic minority healthcare workers who died from Covid-19 were migrant workers and 53% of the total UK healthcare workers who died were migrants. Despite comprising only 3.8% of the NHS workforce, in the first months of the pandemic, up to May 2020, Filipino nurses accounted for 22% of Covid-19 NHS nurse deaths.

In our evidence, we highlighted the:

• Impact of immigration policy and restrictive work visas on migrant frontline workers
• Disproportionate death rates amongst migrant frontline workers
• Disproportionate impact and exposure of gig-economy and agency staff, many of whom were migrants, with limited access to PPE
• Lack of access to sick pay for gig-economy and agency staff who could not afford to take days off work when experiencing symptoms
• Catastrophic impact of austerity on the healthcare sector, which compounded the impact of the pandemic

Outsourced migrant workers

Outsourced workers faced additional risk due to limited sick pay entitlement payment and being excluded from furlough and other government support. This left many working whilst being sick as they couldn’t afford to not work. This was the case for Emanuel Gomes, a cleaner at the Ministry of Justice with the OCS agency who died of suspected Covid-19 after a shift at the Ministry of Justice in April 2020.

We welcome the Inquiry’s explicit inclusion of the impact of the pandemic on outsourced workers, especially our members’ experiences, with greater exposure to Covid-19 and unequal access to PPE. The Report highlights that migrant outsourced workers’ concerns and complaints were dismissed or ignored.

However, we are concerned that the unequal access to sick pay has not been addressed in the Module 3 Report. Despite the passing of the Employment Rights Act 2025, many limb b and other precarious workers remain without access to sick pay. As long as frontline health workers are unable to afford to take days off when they are unwell, their wellbeing and public health will remain at risk.

Migrant healthcare workers

Our evidence demonstrated the undeniable impact of immigration policy on our members, specifically: No Recourse to Public Funds and restrictive visa sponsorship conditions, which led to dramatic and disproportionate death rates amongst migrant workers.

In the Report, migrant experiences are mostly described in euphemistic terms with mentions of overseas recruitment, internationally educated staff, and Black and minority ethnic worker death rates. What remains unsaid throughout the Report is that the majority of these minoritised workers who died of Covid-19 were migrants.

The link between ethnicity and death rate is a “particular concern” for the Chair, however, the Report fails to recognise that the combination of systemic racism and restrictive immigration policy led to these death rates. It is frustrating the Inquiry did not take into account our evidence.

We feel let down by the Inquiry’s refusal to name systemic racism and immigration policies as key reasons for the disproportionate death rates of minority ethnic workers, despite extensive evidence from FMHWG and other core participants.

The recommendations made by the Inquiry are disappointingly weak and will not make any material changes to the working conditions of our members.

Quotes

Myriam Naoual, Public Interest Law Centre, legal representative for FMHWG said:

“We are concerned that the contributions of frontline migrant healthcare workers were only briefly addressed in this Report. Our clients have put forward clear evidence that their members were essential to the healthcare systems during the Covid-19 pandemic, and yet they were often the least protected, which resulted in disproportionate death rates among migrants. We hope to see future recommendations in the Inquiry that will protect our clients and public health.”

Andrea Martinez, Kanlungan Director:

“We welcome the recognition that Black and minority ethnic healthcare workers bore the brunt of the pandemic, sometimes at the cost of their lives. The report also recognises that most PPE provided in the NHS was not fit for purpose, for Filipino workers and women in particular. However, we are deeply disappointed that the role of immigration policy and the particular discrimination and exploitation that migrant healthcare workers face were not explicitly named. This is a missed opportunity to honour the memories of the migrant healthcare workers we lost to Covid-19. We will continue in our fight to abolish the Hostile Environment and for justice for all migrant workers.”

Alex Marshall, IWGB:

“While the Inquiry has acknowledged the devastating impact of the pandemic on frontline workers and recognised the vital role that migrant and precarious staff played in keeping the country running, it ultimately falls short of delivering the meaningful change that this moment demanded. This was a rare opportunity to confront and dismantle the systemic inequalities that were not created by Covid-19, but brutally exposed and intensified by it.

"We gave clear, detailed evidence of how immigration policy, insecure work, lack of sick pay, and systemic racism combined to produce entirely preventable harm, illness and death. Yet the report stops short of naming these root causes or calling for the sweeping structural reforms needed to ensure this never happens again.

"Recognition without action is not enough. As long as workers are forced to choose between their health and their livelihood, and as long as migrant workers remain subject to hostile policies and exclusion from basic protections, the same conditions that led to such tragic outcomes will persist. We are continuing to see these harsh conditions and forms of treatment produce the same kinds of preventable harm and tragic outcomes today.

"It will once again be left to unions, grassroots organisations and the communities most deeply affected to organise, build power and fight for the changes they need. The Inquiry has listened- but it has not acted with the urgency or ambition required to genuinely address these systemic failures.”

Petros Elia, UVW General Secretary:

"Frontline migrant workers kept this country going during the darkest days of the pandemic, often at enormous personal cost. Many of our members were forced to work without adequate protection, without proper sick pay, and under the constant threat of immigration enforcement — a deadly combination that this report still fails to fully confront.

"While it is welcome that the Inquiry acknowledges the disproportionate impact on outsourced and migrant workers, it falls far short of naming the root causes: systemic racism, hostile immigration policies, and a model of outsourcing that leaves essential workers exposed and disposable.

"These workers were hailed as heroes, yet treated as expendable. Without urgent action to guarantee sick pay for all, end exploitative outsourcing, and dismantle the hostile environment, the same injustices will be repeated in the next crisis. Our members deserve far more than recognition — they deserve justice, dignity, and lasting change.”