European Blind Union
EBU
The European Blind Union advocates for the rights and inclusion of visually impaired people.
Lobbying Activity
Response to A strategic vision for sport in Europe: reinforcing the European sport model
26 Nov 2025
Despite growing attention to inclusion in EU sport policy, blind and partially sighted people continue to face structural barriers to accessing mainstream sport. These include inaccessible venues, a lack of adapted sport materials, and the digital inaccessibility of club websites, registration systems, and sport finders. Coaches and volunteers are often not trained to support athletes with specific needs, and young people with disabilities remain underrepresented in grassroots and competitive sport pathways. There are also safety issues attached to these concerns. The European Commissions announced public consultation should examine to what extent national and local sport ecosystems apply principles of universal design and accessibility, including physical access, adapted materials, affordability, and mobility to and from venues. It should also explore how digital websites and tools enable or exclude participation, and whether personal data and privacy are safeguarded. In addition, the consultation should address the training and awareness of coaches, as well as the safety aspects related to the accessibility and clarity of information. To ensure lasting change, the roles and responsibilities of federations and municipalities should be examined across all these dimensions. With reference to the EU Council Resolution of 2019 on access to sport for persons with disabilities (2019/C 192/06), EBU expects a communication on inclusive sport to address the barriers mentioned above and what is needed to create socially inclusive and safe sport environments for persons with disabilities, including visually impaired people. Particular attention should be paid in the communication, at root level, to ensuring that information about sport opportunities, registration procedures and safety guidelines are available in accessible digital and alternative formats (such as audio, large print or easy language), along the principles of the European Accessibility Act and the Digital Services framework. Also crucial is the monitoring of progress, which should measure not only participation rates but also the accessibility of communication, facilities, and training offers at local club level. This monitoring should be carried out regularly and with enough detail to track meaningful progress over time. Data collected through federations and municipalities could feed into an EU-wide Sport Inclusion Index, helping to measure progress on accessibility and participation for persons with disabilities in a consistent and transparent way. In line with Article 31 of the UN Convention on the Rights of Persons with Disabilities, data collection and monitoring should include disability-disaggregated information to ensure evidence-based policymaking across Member States. Embedding accessibility as a transversal value in the European Sport Model will help ensure that inclusion is not treated as a separate pillar, but as a defining characteristic of sport governance, funding and participation at every level. EBU remains ready to support the European Commission in this work, for instance within the future EU Sport Forum process.
Read full responseResponse to Revision of the Standardisation Regulation
2 Jul 2025
The European Blind Union (EBU) welcomes the revision of the Standardisation Regulation as an opportunity to remedy the current lack of meaningful participation of civil society in the standardisation system, including of persons representing persons with disabilities (PWD). The independence and equal opportunities for all stakeholders is not guaranteed by European Standardization Organisations (ESOs) and National Standard Organisations (NSOs). Concretely, the shortcomings are: high participatory fees; inaccessible procedures, documents and meetings; lack of reasonable accommodation for experts with disabilities to participate; and unequal decision-making powers and influence in terms of balance of representation and voting rights for civil society organisations compared to business representatives, to the detriment of the general interest. Moreover, it is abnormal that non- profit organisations or citizens with legitimate interest in European Harmonised Standards have to purchase them (at an expensive price) once they are adopted, even though are funded by European taxpayers money. This situation is of particular concern to us where standards are requested for EU policy reasons or, more importantly, to demonstrate compliance with EU harmonised legislation, namely in the area of accessibility for PWD. For all these reasons, we support the European Disability Forumour umbrella groupcall for such harmonised Standards to be dealt, not by NSOs and ESOs, but by a truly independent entity (e.g. a European agency) that ensures independence and equal opportunities for all stakeholders, along the example of the US Access Board.
Read full responseMeeting with Hadja Lahbib (Commissioner) and
6 Jun 2025 · Presentation of the organisation and their priorities as well as the actions that the Commission should focus on concerning persons with disabilities
Response to Multiannual rolling planning for the period 2029-2036
28 May 2025
EBU has welcome the improvement to Eurostat in recent years as regards providing statistics on disability detached from the health/medical approach. The persistent limitations are: The data come mainly from population or household sample surveys that usually cover the adult population only and exclude people living in collective households and institutions, such as nursing or retirement homes, where usually many persons with disabilities live, especially the elderly. The periodicity of some surveys and statistics could be improved. The data should be further disaggregated by type of disability, to reflect the specific situation of visually impaired people. To-date, the available data distinguishing by type of functional limitation is essentially just to quantify the respective types of limitations and their seriousness, whereas disability is generally treated as a whole when considering the different aspects of life. See: https://www.euroblind.org/sites/default/files/documents/EBU%20Statement%20on%20Eurostat%20developments%20(January%202024).pdf
Read full responseMeeting with Maria Ohisalo (Member of the European Parliament)
19 Feb 2025 · The Rights of Persons with Disabilities
Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)
18 Feb 2025 · Inclusive EU policies for Visually Impaired People
Response to European Disability Card and European Parking Card for third country nationals
16 Nov 2023
EBU welcomes and fully supports this initiative. It well responds to our call (see attached file) in reaction to the proposed Directive on the European Disability Card and the European Parking Card for persons with disabilities, to extend the scope of the proposed new rules, beyond family members of EU citizens, to third country nationals that have a recognised disability status in a Member State and are lawfully travelling to another Member State. That this is achieved, not within the same directive but through a separate and parallel directive that refers in substance to the first, is just as well.
Read full responseResponse to European Disability Card
2 Nov 2023
STRONG POINTS OF THE PROPOSAL: The proposed legal instrument is a directive, i.e., a legally binding instrument, which is necessary given that the 1998 EU Council recommendation on the parking card and the pilot project on the disability card have had limited scope and results. The proposal takes a very pragmatic approach in that: - it addresses the disability card and the parking card, but treats these as two physically separate documents, each with their own purposes and eligibility criteria; - it builds on the mutual-recognition approach, which respects the national competence for disability assessment and granting of the cards while at the same time ensuring equal treatment for persons with disabilities on the move; - for the disability card, it does not give a list of services, activities and facilities covered but simply says that if in the host EU country these come with special conditions or preferential treatment for persons with disabilitiesbe that from public or private entitiesthen equal treatment is to be ensured for card holders from other EU countries. Other strong points include: - for both cards the applicant can choose the format: physical, digital or both; - either format will have to be fully accessible to the holder and respect their privacy about the type or level of disability; - measures are foreseen to avoid forgery and fraud, important to ensure effective mutual recognition. FINE-TUNING NEEDED: - It should remain fully voluntary to be a disability or parking card holder and it should never be an obligation to show the disability card as proof of disability for services already granted under other EU legislationsuch as passenger rights for persons with reduced mobility. It would also be useful to indicate that the cards must be delivered at no extra cost to the bearer, compared with national cards. - An EU-level, centralised register is necessary for the two cards. This would serve to inform the public, in all EU languages and through accessible information, about the available advantages in each country, thereby allowing persons with disabilities to plan ahead when travelling within the EU. Such a register would also facilitate co-operation between competent national authorities, where needed. LOOPHOLES: - Without questioning that the EU country of residence remains competent to deliver the cards according to its national legislation, why only aim to facilitate short stays of persons with disabilities in a Member State other than that of which they are a resident, to the detriment of those who move their residence to another EU country or simply are on longer stays? The proposal should also address, as an indirect barrier to the free movement of persons with disabilities in the EU, that when they move to reside in another EU country, the process of reassessing their disability status there can take a long timeoften many months and sometimes more than a yearleaving them in limbo between two national competencies. At the very least, European card holders should be entitled to equal treatment for special conditions or preferential treatment in the host country, also in the context of a change of residence, while their disability status is being reassessed and they wait to receive a new card. Ideally, the disability card could even facilitate continued access to state-funded social security and social benefits, be it from the issuing country or the host country, during the transition between two countries, based on a concertation mechanism between competent bodiesanother reason an EU-level register is necessary. - The proposal only concerns EU citizens and family members, which does not seem compatible with a human-rights-based approach. Third-country nationals with disabilities who are family members of an EU citizen and who are legally resident in an EU country, with recognised disability status there, should be covered when lawfully moving within the EU under EU law.
Read full responseResponse to Evaluation of Standardisation Regulation (EU) No 1025/2012
18 Sept 2023
The European and national standardisation bodies operate in a global environment. This is not a bad thing in itself as long the influence of a more international perspective does not undermine the expression of European values. In particular, we feel that the efforts, at EU level, to ensure accessibility of services, products, and the built environment are watered down, when it comes to the definition of technical standards, by the over-representation of business interests of multinational companies that do not have their headquarters in Europe but are nevertheless very influent through their participation in the standardisation bodies of EU Member States. A revision of Regulation (EU) 1025/2012 should address this problem. Moreover, in parallel the European standardisation bodies should modernise their governance and address uneven and untransparent representation of industrial interests, to ensure and increase the involvement inter alia of civil society organisations representing stakeholders and users. In particular, when it comes to accessibility standards, organisations representing persons with disabilities should be enabled to bring their contribution and they should also have free access to existing standards and other deliverables.
Read full responseResponse to Interim evaluation anf final evaluation of Creative Europe Programmes
1 Jun 2023
We refer to our position paper of September 2021, "MEDIA funding to European film industry: Promote Equal Access to Culture for Persons with Visual Impairments in the EU" (https://www.euroblind.org/sites/default/files/documents/ebu_position_paper_on_media_funding_sept2020_final.pdf) and attach our statement of July 2022, "Creative Europe 2021-2027: where are the incentives for audio description and subtitling in MEDIA funding to the film industry?". In substance, in these documents: We call on Creative Europe to use the leverage of funding to promote good practices for guaranteeing access to culture for visually impaired people. We recall the EU's obligation as a provider of funding under Article 30 of the UN Convention on the Rights of Persons with Disabilities. Looking at the MEDIA strand of Creative Europe, specifically the funding of the film industry, we deplore that EU funding goes to films without a conditionality of providing audio description and audio subtitling, as is the case in some Member States. Before the adoption of Creative Europe Regulation 2021-2027, we asked that, at the very least and for a start, a target be set of at least 25% of films that receive MEDIA production or distribution funding have an audio description and audio subtitling in the languages of the production. Unfortunately, we were eventually disappointed to observe that, despite the commitment to pursue the programmes objectives in a way that encourages inclusion, equality, diversity and participation and, where appropriate, through specific incentives that ensure access to culture and creative sectors for groups at risk of social exclusion and marginalisation, namely people with disabilities, and encourage their active participation in those sectors, there is no sign in practice that MEDIA, through its funding, is in effect promoting audio description and audio subtitling. Certainly, there is no visible emphasis on making films accessible for visually impaired people, other than a generic statement in all relevant MEDIA calls requesting applications, among other selection criteria, to present "adequate strategies to ensure (...) inclusion. We argue that this state of play is due to the absence in the Creative Europe regulation of a legal obligation for the programmes executive agency to have measurable goals as far as promoting inclusion is concerned. We ask the Commission to use the opportunity of the mid-term review of the Creative Europe regulation 2021-2027, to consider introducing some benchmarking in the regulation on how MEDIA funding is used to promote inclusion, and in particular accessible films for people with visual impairment.
Read full responseResponse to Evaluation of “Marrakesh” Directive and Regulation
11 May 2023
Please see the attached EBU position paper produced specifically for this consultation in which, among other considerations, we generally welcome the positive impact of the EU's Marrakesh Treaty legal framework, but regret: - the negative impact of the Directive's allowing EU Member States to opt for putting in place a compensation scheme for right holders when authorised entities make use of the Marrakesh Treaty rights; and - that some Member States require authorised entities, in order to benefit from the Marrakesh Treaty provisions, to be on an approved list, contrary to the Agreed Statement on Article 9 of the Treaty.
Read full responseEuropean Blind Union urges noise alerts for electric motorcycles
27 Apr 2023
Topic — This consultation updates EU law to reflect international noise emission standards for motorcycles.
Message — The EBU argues the EU legislator should make acoustic alert systems mandatory for electric motorcycles. This would ensure the safety of pedestrians, specifically visually impaired pedestrians.12
Why — Mandatory alerts would improve safety for the visually impaired people the EBU represents.3
Impact — Manufacturers would face higher costs to comply with new acoustic alert requirements.4
Response to Triannual evaluation of the six Executive Agencies
7 Apr 2023
When a political agreement was reached on the new Creative Europe programme in December 2020, we welcomed the commitment to pursue the programmes objectives in a way that encourages inclusion, equality, diversity and participation and, where appropriate, through specific incentives that ensure access to culture and creative sectors for groups at risk of social exclusion and marginalisation, namely people with disabilities, and encourage their active participation in those sectors. From where we stand, we have no possibility to see whether in practice Creative Europe/MEDIA, through the funding managed by EACA, is in effect promoting audio description and audio subtitling. We would be happy to get some feedback on this from the competent service at the European Commission. What we can say, judging by the MEDIA institutional communication and calls for proposals, is that there is no visible emphasis on making films accessible for visually impaired people. This is probably because the Creative Europe regulation does not include a legal obligation for the programmes executive agency to have measurable goals as far as promoting inclusion is concerned. We are aware that Creative Europe also funds cooperation projects to promote the development of audiences with disabilities and the involvement of artists with disabilities in the culture sector. However, we believe that promoting the inclusion of persons with disabilities should be mainstreamed in all of the programmes funding. The European Union acceded to the United Nations Convention on the Rights of Persons with Disabilities (CRPD) and it is responsible for its implementation to the extent of its competences. This of course includes EU funding. Article 30, paragraph 1 of the CRPD defines the right of persons with disabilities to take part on an equal basis with others in cultural life. Among other, it obliges State Parties to take all appropriate measures to ensure that persons with disabilities (...) enjoy access to (...) films (...) in accessible formats. We ask the Commission to use the opportunity of the mid-term review of the Creative Europe regulation 2021-2027, to consider introducing some benchmarking in the regulation on how MEDIA funding is used to promote inclusion, and in particular accessible films for people with visual impairment. For further details, we refer to our statement attached.
Read full responseMeeting with Tomasz Frankowski (Member of the European Parliament, Rapporteur) and European Disability Forum and
21 Mar 2023 · The future of the European book sector-consultation meeting with stakeholders
Response to European Disability Card
19 Dec 2022
The European Blind Union (EBU) strongly supports the European Commissions initiative of a legislative proposal for EU-wide Disability Card (hereafter the Card) in 2023 to ensure the free movement of people with disabilities in the EU. We welcome the announced aim of the Card to facilitate the mutual recognition of disability status for card holders within the EU and to address cases of indirect discrimination on the basis of nationality that may result from non-recognition. Precisely because it is a matter of ensuring equal treatment for persons with disabilities in the exercise of EU free movement rights, we believe that the Card should result from binding legislation, preferably a regulation to avoid differences in implementation at national level. We believe that, to bring meaningful progress by comparison with the current pilot-project, the material scope of the future Card should include all areas of services and support already provided for national citizens with disabilities, beyond culture, leisure and sport such as commercial benefits, education, training or employment. Indeed, if the EU single market is to be a reality for consumers with disabilities, non-nationals/non-residents should have, across EU-internal borders, the same access as nationals/residents to discounts on assistive devices or affordable communications plans, for example. We understand that the Card will not affect the mechanisms in place at national level to grant the disability status based on national assessments, nor replace nationality disability cards, and that its scope will not cover social security/social protection benefits under national rules, including as coordinated by EU law in a cross-border context). Nevertheless, we argue that the Card should concern, beyond travellers and consumers, also workers, trainees or students who move to another EU country, where their disability status needs to be recognised in that context for equal treatment. In particular, the Card should facilitate the transition while undergoing a re-assessment process in the host EU country. We also encourage the Commission to improve the legal framework for the EU Disability Parking Card, namely to harmonise at EU level its format, characteristics and issuing procedure. However, we think that the Card, even if combined in a single legal initiative with the EU Disability Parking Card, should remain physically separate, because not all persons with disabilities who are potential holders of the Card are concerned by the Disability Parking Card, and if they are, they may need it to stay in the car while they would need to carry the disability card around for other needs. Moreover, the Card contains personal information (name, date of birth, degree of disability etc.) which should not be visible for the public in a parking place. The Card preferably in the shape of a credit card should be in a standardised and fully accessible format (i.e., identifiable in Braille) and with digital capabilities. It should be forgery-proof and there should be a central EU register kept up-to-date by the issuing countries. Further, to make the Card a success, we believe that the following is necessary: An EU-level website available in all EU languages that reunites all practical details for every country (where to get the Card, format, database of benefits and places that accept it). Dedicated funding to set up the Card, the website and to guarantee continuing operational needs (printing, staff, administration) A wide, accessible awareness-raising campaign in all EU countries to inform about the Card. The campaign must reach users (so they can get the Card), service providers (so they can know about it and accept it), and the general public. Close collaboration with persons with disabilities and their representative organisations at all levels and in all their diversity.
Read full responseEuropean Blind Union urges automated vehicles to recognize white canes
4 May 2022
Topic — The consultation establishes technical specifications for the safe approval of automated vehicles.
Message — Automated vehicles should be required to recognize white canes as traffic signs. This requirement must be explicitly included in technical regulations for autonomous cars. All visible signs of visual impairment must be detectable by the vehicle systems.123
Impact — Car manufacturers face higher technical burdens to ensure sensors detect partially obscured objects.6
Response to Recommendation on minimum income
9 Mar 2022
We fully support the Commisson's stated aim of “enhancing coverage, take up and adequacy of minimum income schemes to ensure a decent standard of living for individuals lacking sufficient resources and effective access to social activation and labour market integration measures combined with effective provision of quality enabling services.” And we particularly welcome an attention to personalised support to tailor-made active labour market measures.
Indeed, persons with disabilities and in particular with visual impairment are over-represented in poverty and unemployment and have specific needs.
However, we call on the EU to be mindful that minimum income and disability allowance should be addressed separately, when it comes to using means-testing to open access to the scheme or to exclude from it persons who work.
Some EU countries, in violation of UNCRPD obligations, use similar approaches for disability allowances. This is in violation of the UN Convention on the Rights of Persons with Disabilities because (a) it fails to treat disability allowances as compensation for the additional costs related to the disability, including those related to work and finding work; and (b) it associates disability with “inability to work” and disincentivises persons with disabilities to work or seek autonomy.
Read full responseResponse to European Statistical System – making it fit for the future
1 Mar 2022
To make the European statistical system “fit for the future” from the point of view of EBU, it is necessary to ensure that it enable the EU and Member States to deliver on their obligations under the UN Convention on the Rights of Persons with Disabilities (CRPD).
Article 31 of the CRPD (Statistics and data collection) says that “States Parties undertake to collect appropriate information, including statistical and research data, to enable them to formulate and implement policies to give effect to the present Convention” and that “The information collected in accordance with this article shall be disaggregated, as appropriate, and used to help assess the implementation of States Parties' obligations under the present Convention and to identify and address the barriers faced by persons with disabilities in exercising their rights.”
It is a welcome development that, to deliver on its Disability Rights Strategy, the EU intends to have a disability breakdown in all existing data collections, and in particular in the EU Labour Force Survey from 2023.
However, we deplore that no progress has been made yet toward a harmonised definition of disability—if only depending on the type of survey—for statistical purposes, to generate meaningful, reliable, and comparable data across the EU.
We also find unacceptable that the approach to disability taken in the Eurostat database is from the health perspective, instead of a rights-based approach in line with the CRPD.
Moreover, we call on the EU to at last address the issue that, admittedly, in the current setting, Eurostat is unable to generate data disaggregated by type of disability, other than from the health approach, and even so, only every three years.
The concerned civil society organisations, policy makers, and other stakeholders need to have visual impairment-specific data to inform their action to promote more effective inclusion of around 30 million people with visual impairment in Europe.
Read full responseResponse to Improving access to emergency services through the single European emergency number ‘112’
28 Oct 2021
EBU supports the response of its umbrella group, the European Disability Forum, to this consultation and the emphasis therein on ensuring total conversation and real time text communication by PSAPs.
We would like to add or highlight some elements of particular interest to visually impaired persons, especially given that the European Accessibility Act will require the above result on from 2027 at latest:
• There should be quick access to the emergency number, without having to go through extra steps (e.g. press 1 for ambulance, 2 for police, 3 for firefighters, etc.), especially since such features are difficult to manage for visually impaired people using a smartphone.
• Transmission of the user’s location is crucial, as visually impaired people might not be able to describe their surroundings or their location with enough accuracy. This should happen automatically (subject to consent in line with the GDPR) and with the highest accuracy possible.
• It should be possible to initiate a video call between the user and the emergency services, to allow the operator to gather additional information through the user’s phone camera.
• Subject to consent in line with the GDPR, the user should be allowed to automatically share an ‘emergency profile’ of their medical record, indicating critical medical conditions, including disability.
• Subject to consent in line with the GDPR, a user’s personal health monitoring device should be able to automatically communicate to emergency services crucial information on their health.
• The emergency profile should also include relatives or friends to be alerted. Ideally it should also provide the option to allow these persons to be the ones to call the emergency number about their old, ill or disabled relative and, with the help of digital identification, still be able to share that person’s medical information.
• All or as many as possible of the above features should be available across the EU, both in the user’s home country and when roaming.
• Apps or websites have a special role to play in respect of the above possibilities—whether to collect prior consent, to organise the information and to share it with the operator in an emergency call—but also, more generally, for easy-to-find emergency information. They should be accessible in line with the European Accessibility Act and the Web Accessibility Directive, and they should be pan-European, with EU-wide technical specifications. Moreover, it would be useful if calling the emergency number would automatically open the relevant app, to help users with disabilities face situations of stress.
• How country-specific emergency numbers connect to 112 should also be carefully considered, as some national numbers automatically switch to 112 when roaming in other EU countries. Indeed, EU Member States still tend to prioritise national numbers in the information to the public.
See our position paper attached, including presentation of EBU.
Read full responseResponse to Union of Equality: European Disability Rights Strategy
30 Oct 2020
EBU welcomes the EC roadmap for the post-2020 European Disability Strategy.
The Agenda should aim to implement and enforce the rights of persons with disabilities in the following areas:
1) Decent standard of living, with access to inclusive education, social inclusion and living in the community, employment and social protection (article 9 and 151 of the Treaty on the Functioning of the European Union - TFEU).
2) Equality for persons with disabilities in all fields, with guaranteed equal opportunities, protection against discrimination “based on gender, racial or ethnic origin, migrant status, religion or belief, age or sexual orientation” (article 10 and 19 TFEU and General Comment 6 of the UN Committee on the Rights of Persons with Disabilities), violence and abuse.
3) Freedom of movement, to live, work, travel and study in the EU, and to vote and stand for EU elections, as all other EU citizens (article 21 TFEU).
For it to meaningfully deliver to citizens with disabilities in the next 10 years, a Disability Rights Agenda -- as we would prefer it to be named -- should:
- Pave the way for the implementation of the UN Convention on the Rights of Persons with Disabilities (CRPD) and align with the EU treaties and the 2030 Agenda for Sustainable Development.
- Be comprehensive and include clear objectives, timelines, resource allocation, a governance and accountability mechanism, and full participation of persons with disabilities, including women and children, through their representative organisations.
- Use the CRPD as the basis of understanding disability policies and progammes, referring to the Convention itself, its Article 3 ‘General Principles’, and the CRPD Committee’s General Comments and recommendations.
- Draw on the current political priorities of the European Commission and the possibilities for EU and its Member States to take national harmonised actions.
- Ensure disability is included in all policies and programmes in the Recovery plan for Europe.
Further, the Agenda should:
- Ensure full participation of persons with disabilities, through their representative organisations;
- Ensure that the 2015 Concluding Observations of the CRPD Committee are taken into account in all aspects of the EU’s policies and programmes;
- Improve the data collected by Eurostat, especially disaggregating by impairments, socio-economic characteristics such as age and gender, and about persons with disabilities living in institutions;
- Take an intersectional approach recognising the multiple and intersectional discrimination on the basis of sex, age, ethnicity, religion or belief, sexual orientation and gender which, combined with disability, create specific barriers for these groups among the wider population with disabilities;
- Raise awareness about the CRPD;
- Establish coordination mechanisms to ensure a swift implementation of the Strategy (see attached paper for further details);
- Give the EU CRPD monitoring framework an independent budget and secretariat, as well as independence from EU institutions, in line with the UN Paris principles;
- Include monitoring and evaluation processes (see attached paper for further details); and
- Include a clear commitment to funding with an indication of amounts to be allocated (see attached paper for further details about funding).
Read full responseResponse to Evaluation of the European statistical programme 2013-2020
10 Jul 2020
Statistics are still sadly lacking at EU level to allow to monitor the situation on the ground for persons with disabilities. They are badly needed to ensure that the EU and its Member States deliver on their commitment and obligation to include disabled persons in society and in particular in the jobs market. Appropriate statistic tools are necessary for the Commission to address the situation of persons with disabilities in both the European Semester and the Joint Employment Report. The approach taken so far is essentially surveys-based, but there needs to be a more systematic approach, with data disaggregated per type of disability, in order to bench-mark progress, identify problem areas and, where appropriate, devise fully inclusive policies.
Read full responseResponse to Digital Education Action Plan
10 Jul 2020
As clearly shown during the recent lockdown period related to the COVID-19 crisis, online education offers both potential for alternative forms of teaching and learning but also a number of challenges. The European Blind Union (EBU), representing over 30 million blind and partially sighted persons in Europe, would like to stress the importance that all virtual platforms in use – let alone the learning resources, be it exercises, books, tests, webpages providing background reading etc. – be fully accessible to all users. In order to achieve this, the principle of universal design must be applied from the outset, meaning from the first stages of developing online tools. Otherwise, people who are blind or partially sighted, amongst many other groups of the population, are at risk of being excluded from the benefits of online education, thereby further widening the digital divide. In addition to universal design and accessibility of tools, it is also vital to invest in the strengthening of digital skills of both learners and teachers so that all users can truly benefit from the technical platforms available. In such skills training efforts, particular attention should be paid to people who may require extra support or assistance. Last but certainly not least, we would also underscore that online education, if run in a fully inclusive manner, is an innovative tool that constitutes a useful addition to face-to-face education. At the same time, it should always be considered as a complementary form of education and not to replace onsite learning. The European Union, through its Digital Education Action Plan and its wider initiatives in the area of digitalisation, can play a critical role in addressing some of the above mentioned challenges and in promoting inclusive education.
Read full responseResponse to Report on the Application and Evaluation of the Postal Services Directive
30 Mar 2020
Situation:
The first indent of Article 12 of the Directive states that “Member States may maintain or introduce the provision of a free postal service for the use of blind and partially sighted persons”. So, currently, the provision for free Cecogrammes in the Postal Services Directive is voluntary (“may”). This creates insecurities, as service providers under profit pressure could retract their free service.
Recommendations:
It is very important to keep the section on free postal service for the use of blind and partially sighted persons. Moreover, it would be a welcome improvement to make the gratuity of such services a requirement (“shall”), at least for ‘cecograms’, i.e. mail or parcels containing documents or literature from or for the blind.
Related considerations:
- Continuous free provision of postal services for the use of blind and partially sighted persons is paramount, as disabled persons’ organizations and specialized organisations such as libraries or schools for the blind could otherwise not sustainably cover the expenses of cecograms.
- Digital alternatives to postal services can only compensate vulnerabilities, assuming that online platforms, authentication methods and contents are accessible. This is currently not consistently the case.
- Regardless of volumes, visually impaired users will continue to rely on cecograms, as braille printing is organised centrally by non-profit entities, while the community of users is spread out across Europe.
- While audio material can increasingly be sent digitally, cecograms can be expected to increase in volume due to the EU’s ratification of the WIPO Marrakesh Treaty to Facilitate Access to Published Works for Persons Who Are Blind, Visually Impaired or Otherwise Print Disabled.
- While the frequency and speed of delivery are relevant and given the costs of braille printing, the most important is the reliability of service, i.e. that no shipments are lost. This also applies to return shipments from individual users to institutions.
- It should always be possible to get consignments shipped to someone’s home since it could be hard to find post offices or to have access to self-service machines.
Read full responseMeeting with Nora Bednarski (Cabinet of Commissioner Helena Dalli)
11 Feb 2020 · EBU's priorities on the EU's policies and their impact on people with visual impairments
European Blind Union urges swifter ban on vehicle silent modes
10 Jan 2019
Topic — The Commission proposes banning the manual pause function for vehicle acoustic alerting systems.
Message — EBU supports the decision to prohibit the AVAS Pause Function to protect vulnerable road users. They argue for shortening transition periods to reflect the urgent need for these safety features.12
Why — Shorter deadlines would ensure blind pedestrians can safely detect electric vehicles sooner.3
Impact — Vehicle manufacturers lose the flexibility of extended transition periods for technical redesigns.4
Response to Commission implementing decision on establishing a model accessibility statement under the WAD
15 Jun 2018
Remark on the draft implementing decision, article 3, paragraph 2: the statement should not just “indicate” the method to evaluate the accessibility, but also describe it.
Remarks on the Annex (Model Accessibility Statement), in particular the “Instructions” at the top of the document:
• Re. 3rd paragraph: it is indeed paramount for users that the accessibility statement be easy to find. In case, despite efforts to make the statement easy to find on a website or app, the user cannot find it, we recommend to follow the suggestion made by the WADex, i.e. to create a standardised, easy to figure out web address linking directly to the statement. For example: www.name.domain/accessibility.
• The accessibility statement should not only be easy to find; it should also be easy to understand, i.e. in a language that a non-technical user can understand.
• Like the accessibility statement itself, the feedback mechanism should also be easy to find, and there should be multiple options of feedback channels (phone, e-mail etc.).
Read full response15 Jun 2018
General remarks:
• The accessibility statements themselves should also be monitored and reported about, because they are essential for feedback from users of websites and apps.
• The proposed methodology for monitoring tends to put too much emphasis on measuring accessibility at a technical level, to the detriment of usability and user experience. For that same reason, we disagree with promoting automated testing (see point 1.3.2).
Re. section 2.2 (Sample for websites):
• Even if the methodology should be technologically neutral, we recommend to monitor especially key government services with certified digital security services (e.g. in the area of taxation) with most commonly used assistance technology, such as screen readers.
• Re. point 2.2.4: we are keen for persons with disabilities to be involved (see our general remarks, second bullet point) and we would like their representative organisations to be consulted for the selection of a higher proportion of websites to be monitored, through extending the scope of the “20% of the sample” to all websites, not only those monitored with the simplified method. Moreover, the same rule should apply to mobile apps.
Read full responseMeeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)
26 May 2016 · Digital Single Market
Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)
17 May 2016 · Marrakesh Treaty ratification
Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)
19 Jan 2016 · web accessibility, Digital Single Market
Meeting with Anna Herold (Digital Economy)
16 Nov 2015 · web accessibility + copyright
Meeting with Eric Mamer (Digital Economy)
16 Nov 2015 · Web access
Meeting with Anna Herold (Digital Economy)
8 Oct 2015 · copyright
Meeting with Andrus Ansip (Vice-President) and
13 Jul 2015 · Digital Single Market, accessibility
Meeting with Anna Herold (Digital Economy)
24 Jun 2015 · copyright