European Disability Forum
EDF
The European Disability Forum represents over 100 million persons with disabilities in Europe, advocating for their rights and interests across policy areas.
Lobbying Activity
European Disability Forum urges binding accessibility targets for EU media
18 Dec 2025
Topic — Evaluation of EU rules governing audiovisual media services to enhance accessibility and pluralism.
Message — EDF calls for harmonised accessibility requirements with concrete targets and clear implementation timelines. They demand that video-sharing platforms and social media meet the same standards as broadcasters. Finally, they advocate for mandatory consultation with disability organisations.123
Why — Unified standards would eliminate the current policy fragmentation that limits access to media content.4
Impact — Social media platforms and private broadcasters would lose their current regulatory flexibility and exemptions.5
Response to 2026 EU Justice Scoreboard
9 Dec 2025
The European Disability Forum (EDF), the umbrella organisation representing over 100 million persons with disabilities in the European Union, welcomes the call for evidence on the 2026 EU Justice Scoreboard. The EU Justice Scoreboard plays a vital role in assessing how justice systems across the EU function in terms of efficiency, quality, and independence. It also provides important data to monitor compliance with the United Nations Convention on the Rights of Persons with Disabilities (CRPD), to which the EU and all Member States are parties. Access to justice is a cornerstone of the CRPD (Article 13) and a prerequisite for equal participation in society and the EU internal market. In 2022, the Scoreboard for the first time included indicators on arrangements to support persons with disabilities in accessing justice on an equal basis with others. This was a significant step forward. Unfortunately, subsequent editions did not maintain this focus. EDF recalls that, as a Party to the CRPD, the European Commission has a clear obligation to monitor and report on access to justice for persons with disabilities. EDF therefore renews its call for consistent inclusion of CRPD indicators in all future Scoreboards, similarly to how indicators on childrens rights have been mainstreamed. Annual monitoring is essential to identify gaps, assess progress, and guide reforms to ensure equal access to justice for persons with disabilities across the EU. In 2025, the Scoreboard expanded its scope to include other indicators relevant to the functioning of the single market, looking at independent single market authorities. EDF supports this broader approach and recommends that the Commission also examine the performance of enforcement bodies in terms of efficiency, independence, and accessibility for all users, especially marginalised groups such as persons with disabilities. Beyond courts, many enforcement bodies play a crucial role in guaranteeing rights and compliance with EU law, including for persons with disabilities as reflected in our Guide My Rights in the EU. These include: national equality bodies and human rights institutions; market surveillance authorities (e.g. responsible of enforcing the European Accessibility Act); consumer protection and competition authorities; labour inspectorates; regulatory authorities overseeing transport, digital services, audiovisual services and telecommunications, including their accessibility to persons with disabilities; data protection authorities; and alternative dispute resolution mechanisms. Welcoming the ongoing development of common indicators for equality bodies, EDF recommends that future editions of the Scoreboard include indicators assessing: (1) The independence of these bodies, (2) Their efficiency, including timeliness of procedures and resolution of complaints, (3) Their accessibility, including physical, digital, and communication accessibility and the provision of reasonable accommodation for persons with disabilities, (4) The availability of disaggregated data on complainants and beneficiaries, including by disability, (5) The powers of these bodies, including the nature of their decisions (binding / non-binding), the ability to impose penalties and the level of the penalties, and (6) The existence of cooperation mechanisms with organisations of persons with disabilities. These indicators would offer a more complete picture of how rights are enforced in practice and how accessible justice and redress mechanisms are for all, including persons with disabilities who are often left behind in the exercise of their rights and in seeking redress. They would also strengthen the link between the rule of law, equality, and the proper functioning of the single market.
Read full responseResponse to Indicators on the functioning of equality bodies
20 Nov 2025
The European Disability Forum (EDF), umbrella organisation representing the rights of over 100 million persons with disabilities in Europe, welcomes the proposed adoption of a list of common indicators on the functioning of equality bodies. We particularly welcome the mainstreaming of disability throughout the indicators and the inclusion of accessibility-related indicators, which are well framed and coherent. These are important steps to ensure that equality bodies are well equipped to promote and protect the rights of persons with disabilities in line with the UN Convention on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its Member States. We identified some additional gaps that can be addressed by the indicators to ensure full inclusion and accessibility: 1) Communication accessibility is still too narrowly defined, focusing mainly on ICT and web content. It should also encompass other forms of communication and information provision. 2) The indicators should explicitly require the involvement of persons with disabilities and their representative organisations in the design, monitoring and evaluation of accessibility measures. 3) There is no reference to training of staff on accessibility, reasonable accommodation, and communication with persons with disabilities. To address these gaps, we propose to add the following three new indicators: A1_5: The equality body provides information in accessible formats, such as Braille, plain language and easy-to-read, and accessible means of communication (e.g. in sign language, real-time text or through relay services). (Yes/Partly/No + description); A1_6: Persons with disabilities and/or their representative organisations are involved in the design, monitoring and evaluation of accessibility measures. (Yes/Partly/No + description); A1_7: Staff members are trained on accessibility, reasonable accommodation, and communication with persons with disabilities. Regarding the accessibility of premises, the current yes/no/partially responses do not provide sufficient detail to assess real accessibility levels. Equality bodies could instead report on more specific items, in line with Annex III of the European Accessibility Act (Directive 2019/882), including: approaches to the building and entrances; paths in horizontal and vertical circulation; rooms used by the public; toilets and sanitary facilities; exits, evacuation routes and emergency planning; communication and orientation via more than one sensory channel; equipment and facilities used for service provision. Premises should be considered accessible only when meeting applicable standards, including EN 172010 on accessibility and usability of the built environment. Finally, under the A1_Comments section, equality bodies should be asked to report on data and self-assessment of accessibility. The Regulation could include the following instruction: Provide data or qualitative information on how accessibility is assessed (e.g. audits, feedback from users with disabilities, complaints received, improvements implemented).
Read full responseResponse to Digital package – digital omnibus
13 Oct 2025
1. Accessibility as a Foundation, not a Burden As more aspects of life move online, it is essential that all digital products and services meet minimum accessibility requirements. Without these, persons with disabilities (PwD) are excluded from basic rights such as employment, education, information, and public services. The disability community knows from experience that voluntary measures have proven insufficient; mandatory and coherent legal requirements, underpinned by technical standards are necessary. The EU has rightly adopted a comprehensive legal framework for digital accessibility, mainstreaming accessibility in sectorial legislation such as the Electronic Communications Code, the Audiovisual Media Services Directive, the AI Act, the European Digital Identity Framework, and the European Health Data Space Regulation. In parallel, the EU also adopted in 2019 a horizontal accessibility legislation, the European Accessibility Act with the aim of complementing the sectorial legislation and providing legal certainty on the specific accessibility requirements for the digital domain, also supported by Harmonised European Standards (e.g. the HEN 301 549 on accessibility of ICT products and services) Any attempt to simplify the digital acquis must not weaken accessibility requirements for persons with disabilities. On the contrary, simplification should be used to mainstream and strengthen existing obligations, ensuring that accessibility is regarded not as a burden but as a fundamental right and a driver of inclusion and innovation. 2. The EUs binding duty under the CRPD The European Union is a party to the UN Convention on the Rights of Persons with Disabilities (CRPD), which is binding on EU institutions and Member States under Article 216(2) TFEU. This means that any changes to digital legislation - including the Digital Omnibus and the implementation of the AI Act - must fully respect and implement CRPD rights: equality, non-discrimination, accessibility, independent living, employment, education, health, and privacy. Simplification or streamlining must not dilute these obligations; instead, it should mainstream and strengthen them. 3. The AI Act is a ladder, not a barrier The AI Act is an important step towards protecting fundamental rights in Europe. Although it has shortcomings, deregulating or simplifying its core requirements would increase existing risks and undermine progress. The Act should be viewed as a due diligence framework, not a burden. Article 16 of the AI Act explicitly references the Web Accessibility Directive and the European Accessibility Act, establishing accessibility obligations for high-risk AI systems. Article 95 explicitly mentions accessibility as a topic that codes of conduct may address. Some claim the AI Act will stifle innovation, but its requirements actually help providers and deployers avoid infringing fundamental rights, breaking other laws, or facing costly litigation and reputational damage. Prohibitions (e.g., Article 5) and due diligence requirements guide innovation towards trustworthy, rights-respecting AI, ensuring a level playing field and protecting responsible actors. 4. Inclusion and evidence As highlighted by the UN Special Rapporteur on the Rights of Persons with Disabilities, the rights and core norms of the CRPD are the fundamental standards for assessing the risks and opportunities presented by AI (attached report, points 20-21). The report warns: Persons with disabilities so often the farthest left behind will simply have no chance to catch up unless the technology is properly harnessed. OECD research (attached, page 9) finds that the most cited barrier to the adoption of AI for people with disabilities is a lack of user engagement in developing solutions, resulting in irrelevant and impractical tools. 5. ePrivacy Directive: No weakening of protections EDF firmly stands with the submission of EDRi. The ePrivacy Directive is a cornerstone of trust in cyberspace
Read full responseEuropean Disability Forum Demands Rights Protection for Disabled Asylum Seekers
10 Oct 2025
Message — The organization demands the strategy be grounded in fundamental rights including the UN Convention on the Rights of Persons with Disabilities. They call for binding guidance and minimum standards to ensure accessibility at borders, disability-specific support in reception conditions, and elimination of discriminatory health requirements in visa procedures. They request targeted EU funding for accessibility measures and systematic training of authorities on disability rights.123
Why — This would establish systematic protections for their constituency of over 100 million disabled persons.45
Impact — Member states using disability as visa exclusion criteria would lose administrative discretion over entry.6
European Disability Forum urges stronger employment support in State Aid rules
1 Oct 2025
Topic — Revision of EU regulation exempting certain State Aid categories from prior Commission approval.
Message — The organization requests maintaining provisions allowing State Aid for disability employment support, including wage subsidies, workplace adaptations, and job coaching. They call for increased funding limits and removal of support for sheltered workshops that don't respect workers' rights or support transition to open employment.123
Why — This would help reduce the 24 percentage point disability employment gap by making workplace accessibility more affordable for employers.45
European Disability Forum urges targeted protections for youth with disabilities
29 Sept 2025
Message — The organization calls for a specific focus on young persons with disabilities in the action plan. This must involve equipping them with skills to identify cyberbullying, navigate digital spaces safely, and report abuse effectively. They demand inclusive platform design, stronger enforcement of anti-bullying policies, and coordinated efforts across education, technology, and child protection sectors.123
Why — This would provide stronger protections for their 100 million constituents facing disproportionate cyberbullying risks.456
Response to EU Anti-Poverty Strategy
23 Sept 2025
The European Disability Forum welcomes this initiative. In order to be effective, however, the strategy must be concrete in how it plans to alleviate poverty. It must also acknowledge that certain groups face greater risks of poverty than others and must be prioritised. According to Eurostat, 28.7% of persons with disabilities in the EU are at risk of poverty and social exclusion, compared to 17.9% of persons without disabilities. For women with disabilities the rate is higher, with 29.7% at risk. Furthermore, poverty levels of persons with disabilities have worsened in thirteen EU Member States over the past decade. Income has a key role to play in these statistics. Employment rates for persons with disabilities fall far below those of persons without disabilities, with many persons with disabilities in part-time and low-paid work, or in sheltered workshops (sometimes rebranded as protected employment) with harmful practices such as sub-minimum wages and no pathways to future employment. Women with disabilities are particularly impacted, with only 20% on average working full time. Families raising children with disabilities are also vulnerable to poverty, in part due to lost earnings because of caring responsibilities. Educational attainment is another barrier to employment. In 2022, 22.2% of disabled young people left education and training early compared to 8.4% of their peers. Persons with disabilities with a secondary or tertiary degree have significantly better job opportunities, but too many do not reach this level. The general inadequacy of disability allowance combined with systems in most EU Member States that mean people lose their allowance or see it drastically reduced when they start working, also has a hugely detrimental impact. This affects not only persons with disabilities, but also family carers who receive a carers allowance from the state and risk losing it if they start working. Another issue is that persons with disabilities and their families face additional living costs. Studies from Ireland suggest that the cost of living for households with a member who has a disability is 23.7% higher than for those with no persons with disabilities. More detailed EU-level data on this issue is however still missing. EU data suggests that poverty rates among persons with disabilities have been exacerbated by the rise in living costs, particularly when it comes to housing and groceries. Housing expenses now account for 30.4% of persons with disabilities disposable income, compared to 27.4% in 2018. In 2023 13.8% of persons with disabilities in the EU were unable to afford a meal with meat, chicken, fish (or vegetarian equivalent) every second day, up from 11.9% in 2018. The European Disability Forum therefore calls for the EU anti-poverty strategy to contain the following actions specific to persons with disabilities: Research and data collection on poverty and social exclusion disaggregated by type of disability Further research into the extra cost of living of persons with disabilities across the EU as well as the cost-effectiveness and benefits of Member States moving away from institutions and towards community-based services Recommendations to the Member States on disability assessment processes and adequacy of disability allowance Support for social protection reforms in the Member States that would allow persons with disabilities to retain disability allowance alongside income from work or inheritance Ensuring EU funds are used to support employment, inclusive education, social inclusion and personal budget schemes for persons with disabilities Support social protection reforms in the Member States that will compensate families and informal carers, particularly women, for the support they provide, and to compensate them for the loss in pension contributions.
Read full responseEuropean Disability Forum calls for stronger rail protections amid connections
19 Sept 2025
Topic — Extending passenger rights to journeys using multiple tickets from different rail companies.
Message — The organization requests compensation when missed connections result from lack of accessibility or assistance. They seek elimination of pre-notification requirements, last-minute assistance availability, and simplified booking across multiple rail companies. They emphasize that current rules fail to protect passengers with disabilities during disruptions.1234
European Disability Forum Urges Inclusive and Accessible Energy Policies
11 Sept 2025
Message — The group demands that energy information becomes accessible for all persons with disabilities. They advocate for a rapid phase-out of fossil fuels and strong disconnection protections.123
Why — The organization would secure prioritized financial grants and improved accessibility in housing renovations.45
European Disability Forum calls for binding EU civil dialogue rules
3 Sept 2025
Message — EDF calls for a binding inter-institutional agreement on civil dialogue and more accessible consultation tools. They also demand increased transparency from the Council and improved funding rules for disability organizations.12
Why — These changes would ensure disability organizations can influence legislation on an equal footing while easing financial burdens.3
Impact — EU institutions and Member States lose the ability to exclude civil society from policy-making through opaque or inaccessible procedures.4
Response to Gender Equality Strategy 2026-2030
5 Aug 2025
The European Disability Forum highlights the need for concrete actions targeting women and girls with disabilities, which constitute 29,2% of the female population in the EU, and face exclusion and discrimination in all areas of life. We call to fully integrate the rights of women and girls with disabilities throughout the Gender Equality Strategy 20262030, in line with the UN CRPD, CEDAW, and the Istanbul Convention. Key recommendations include: Systematically incorporate the rights of women and girls with disabilities in all areas of the strategy. Ensure coordination across EU institutions and the meaningful involvement of women with disabilities and their representative organisations in implementation and monitoring. Adopt an EU Directive explicitly criminalising forced sterilisation as gender-based violence, sexual exploitation and torture, aligned with international human rights law (CRPD, CEDAW, and Instanbul Convention). Require Member States to monitor violence in institutional settings. Collect disaggregated data by gender and disability in all in all EU-funded gender-based violence programs and national reporting mechanisms. Guarantee accessible legal procedures through the provision of procedural and age-appropriate accommodations in court, like easy-to-read materials, sign language interpreters, live captioning, and personal assistance. Fund training for law enforcement, judiciary, healthcare, and education professionals on forced sterilisation and gender-based violence. Promote peer-led education and advocacy on bodily autonomy and reproductive rights. Develop EU standards to protect women with disabilities in care institutions. Establish accessible, independent complaint mechanisms. Fund specialised legal aid services and research on violence experienced by women with various disabilities. Support community-based services and vocational training for women with disabilities. Financially recognise caregiving roles and ensure access to adequate pensions. Establish a EU Framework Directive for an adequate minimum income. Support women and girls with disabilities in transitioning from education to employment. Make lifelong learning and vocational training fully accessible. Establish an EU legal framework ensuring free and informed consent for all healthcare interventions, especially sexual and reproductive care. Prohibit substituted decision-making; promote supported decision-making systems. Ensure sexual and reproductive health services are physically and communicatively accessible, including contraception, gynaecological care, and pregnancy support. Train healthcare professionals on disability-inclusive communication and consent. Fund peer-led counselling and inclusive public health campaigns. Establish accessible complaint mechanisms in health systems. Ensure access to rehabilitation services, including for survivors of sexual and gender-based violence. Enforce the Employment Equality Directive, strengthen equality bodies, and introduce mechanisms for employers to implement reasonable accommodations (e.g. by establishing a Disability Employment and Skills Guarantee). Require EU-funded employment and training programmes to report on gender and disability. Invest in research on employment gaps disaggregated by gender, disability type, and sector. Reform the EU Electoral Act of 1976 to align with the UN CRPD and therefore realise the political rights of persons with disabilities, focusing on the participation of women and girls with disabilities. Guarantee within the EU electoral law that women and girls with disabilities have the rights to vote and stand for election, regardless of legal capacity status. Mainstream disability and gender in all EU external action policies and instruments, including NDICI-Global Europe; the EU Action Plan on Human Rights and Democracy; the Gender Action Plan III, and EU Climate policy.
Read full responseEuropean Disability Forum urges new EU disability employment and skills initiatives
28 Jul 2025
Message — The organization requests new actions and flagship initiatives under the EU Disability Strategy for the remaining five years. They call for stronger measures including a Disability Employment and Skills Guarantee, protection of support services when moving between Member States, and investment in accessible housing and transport.123
Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)
28 Jul 2025
Despite the Commission Decision 2012/21/EU on Services of General Economic Interest (SGEI), which allows for investment of state aid in social and affordable housing including that targeted at disadvantaged or socially less advantaged groups, the lack of affordable and accessible housing has only worsened since the SGEI came into force. The issue of housing is particularly prevalent for persons with disabilities. According to Eurostat 11% of persons with disabilities in the EU report being overburdened by the cost of their housing and only 28.9% consider that their dwelling meets their needs. Finding accessible housing is a significant undertaking for persons with disabilities in the EU. Finding housing that is both accessible and affordable is even harder. The extra costs associated with renting of buying accessible accommodation as a person with disabilities exacerbates the already-persistent issue of increased poverty and social exclusion among persons with disabilities. 28.8% of persons with disabilities in the EU are currently at risk of poverty and social exclusion, rising to 29.7% for women with disabilities and 35.6% for people with high support needs. The prevalence of inaccessible and unaffordable dwellings is one of the main reasons people are obliged to leave their homes when they develop a disability or as they become older. It is one of the primary causes of persons with disabilities being placed in institutions against their will. While EU state aid legislation, including the SGEI, cannot take decisions for the Member States on how to invest, the ability to use state aid for funding affordable accessible housing, including social housing, as well as the possibility of adapting dwellings to the needs of persons with disabilities, must be made much clearer and more specific. The SGEI makes references to allowing state aid to be used for housing and social inclusion of vulnerable groups. However, owing to the logistical differences in making housing accessible for persons with disabilities, it should be made very clear from the outset, and within the text of the SGEI, that Member States are encouraged to use state aid to invest in building affordable accessible or easily-adaptable housing in the community that meets the specific needs of persons with disabilities and older people. The SGEI should also encourage Member States to invest in retrofitting or adapting existing properties to improve their accessibility for persons with disabilities. The European Disability Forum strongly believes that there needs to be very specific reference to housing that is accessible to persons with disabilities, as the implications for how this type of housing should be planned and delivered are not sufficiently understood in references to so-called vulnerable or disadvantaged groups alone. The European union counts 100 million persons with disabilities. With an ageing population, the number of persons with disabilities and accessibility needs that cannot be met by the majority of the EUs current housing stock, is constantly on the rise. The use of state aid by EU Member States to improve the accessibility and affordability of housing cannot be overstated. In attachment you will find the European Disability Forums recent resolution on housing.
Read full responseResponse to Revision of the Standardisation Regulation
18 Jul 2025
Please find attatched EDF response to the call for evidence on the EU Standarisation Regulation.
Read full responseMeeting with Cynthia Ní Mhurchú (Member of the European Parliament) and European Network for Accessible Tourism - ENAT asbl
16 Jul 2025 · Roundtable on Inclusive Tourism
European Disability Forum urges DNA to mandate 24/7 relay services
11 Jul 2025
Topic — The Digital Networks Act aims to improve access to secure and fast connectivity across Europe.
Message — Ensure text and video relay services are available 24/7 in every Member State. Emergency services must support advanced location data and native video calls for total conversation. Extend accessibility mandates to national emergency numbers and missing children hotlines.123
Why — Persons with disabilities would achieve equivalent access to essential communication and emergency services.45
Meeting with Tuuli-Maria Mattila (Head of Unit Communications Networks, Content and Technology)
10 Jul 2025 · Discussion on digital accessibility
Response to Anti-racism Strategy
4 Jul 2025
The European Disability Forum (EDF), umbrella organisation representing over 100 million persons with disabilities in Europe calls for the adoption of an ambitious and inclusive new Anti-Racism Strategy. Our organisation stands in solidarity with the European Network Against Racism (ENAR) calling for a strategy based on a human right and decolonial approach, grounded on the EU Charter on Fundamental Rights and in line with International Human Rights Treaties, including the UN Convention on the Rights of Persons with Disabilities ratified by the EU and all its Member States. We call for: 1. Ensuring a strong intersectional approach: Racialised people with disabilities face multiple and intersecting forms of discrimination, marginalisation, and violence. Studies by the EU Fundamental Rights Agency confirm the issue, notably affecting Black people, Roma and Muslims with disabilities in access to education, employment, healthcare, housing, and access to justice. EDFs joint analysis with the ERGO Network on Roma with disabilities highlights how compounded discrimination results in systemic exclusion and poverty (attached). The upcoming Strategy must centre lived experiences through an intersectional approach, with targeted measures for those at the margins, including racialised persons with disabilities. 2. Mainstreaming disability within anti racism and anti-racism within disability policies: Anti-racism must be included in all policy fields, including disability policies. For example, actions to address unemployment among persons with disabilities must account for racial and ethnic discrimination in the labour market. Measures promoting deinstitutionalisation and independent living must also consider the specific challenges faced by racialised persons with disabilities in accessing services or in relation to coercion in health, including mental health. At the same time, anti-racism measures must consider disability as a ground for discrimination. 3. Address racism and disability in migration and law enforcement: The Strategy must take a strong stance on systemic racism in migration policy and border enforcement. It should implement the recommendations to the EU by the UN Committee on the Rights of Persons with Disabilities, including ensuring the New Pact on Migration and Asylum protect the rights of persons with disabilities; preventing pushbacks, detention and denial of access to asylum; and developing accessible reception systems for migrants with disabilities. In addition, the Strategy must tackle racial and disability-based profiling, police violence and the over-surveillance of racialised communities, including those with disabilities. 4. Combat hate speech and hate crime: EDFs findings show that racialised people with disabilities are at heightened risk of hate speech and hate crime, especially when they belong to religious or ethnic minorities. The Strategy must ensure comprehensive measures to combat hate-motivated violence, improve data collection disaggregated by disability, race, gender and other grounds, and adopt harmonised legal protections against hate crime and hate speech across the EU. 5. Governance, monitoring and participation: the Strategy must establish a strong governance structure within the EU institutions. It must guarantee the meaningful participation of racialised people and their representative organisations, including those at the intersections with disability, in its design, implementation, monitoring and evaluation. Core funding and structural support must be ensured for their work.
Read full responseMeeting with Dainius Žalimas (Member of the European Parliament)
2 Jul 2025 · Meeting
Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath)
17 Jun 2025 · Rights and inclusion of persons with disabilities
Response to European Affordable Housing Plan
2 Jun 2025
The European Disability Forum (EDF) recalls the numerous barriers persons with disabilities face when accessing housing. EDF therefore calls on the Commission to make sure that accessibility is central to the European affordable housing plan and to take into consideration the following challenges for persons with disabilities in the EU: Considerable difficulties when looking for housing that is accessible because of an abundance of inaccessible dwellings among Europes housing stock; Extra costs when renting or buying accessible properties in comparison with inaccessible ones, which has a significant impact on the ability to make ends meet. According to Eurostat, 11% of persons with disabilities in the EU report being overburdened by the cost of their housing, and only 28.9% consider that their dwelling meets their needs. 4.4% of persons with disabilities experience severe housing deprivation and 15.1% are unable to keep their homes adequately warm; The extra cost of renting and buying accessible housing exacerbates poverty and social exclusion, with 28.8% of persons with disabilities in the EU currently at risk, rising to 29.7% for women with disabilities and 35.6% for people with high support needs; barriers in buying properties because of difficulties in accessing financial services to acquire a loan or insurance. Inaccessibility of dwellings is one of the main reasons people are obliged to leave their homes when they develop a disability or as they become older. This is a key factor in persons with disabilities ending up in institutions and explains in part why the number of institutionalised people has risen over the past decade in the EU. Having more accessible housing, and the ability to improve the accessibility of existing dwellings, would result in fewer people being forced to leave their homes against their will. People who are institutionalised and/or placed in psychiatric units, lose their homes while placed in such settings because of cuts to incomes and an inability to make rent or mortgage payments. Many people leaving institutions no longer have homes or belongings to return to in order to rebuild their lives. Accessible and affordable housing in the community is not only needed by persons with disabilities, but also their families. EDF therefore calls on the European Union and Member States to: Ensure that the new European Affordable Housing Plan has a specific focus on increasing the stock of housing that is accessible to persons with disabilities and older people. In the next Multiannual Financial Framework, establish a Fund for Accessible Housing within the framework of EU cohesion funding, with the aim of creating new affordable and accessible housing in the community, as well as to retrofit existing properties to make them accessible where possible. Revise the EUs State Aid rules to allow for support on costly accessibility adaptations, particularly on housing. Facilitate access to financial services to reduce additional barriers persons with disabilities face in accessing loans and insurance when purchasing a property. Step up support for persons with disabilities to live independently in the community, facilitate the transition away from a reliance on institutions, and ensure that accommodation in the community meets their needs and ensures dignified living conditions. Make sure that families of persons with disabilities are also supported in finding affordable and appropriate housing or to adapt the family home so that it will allow them to remain as a family unit. Explicitly include accessibility as a requirement when renovating and constructing new buildings in all initiatives in the field of energy efficiency and other policies aimed at making buildings more sustainable.
Read full responseMeeting with Roxana Mînzatu (Executive Vice-President) and
28 May 2025 · Rights of persons with disabilities, pending priorities
Response to European Democracy Shield
26 May 2025
Please find attached the response by the European Disability Forum.
Read full responseResponse to Policy agenda for cities
23 May 2025
Please find attached the feedback from the European Disability Forum (EDF)
Read full responseMeeting with Hadja Lahbib (Commissioner) and
22 May 2025 · EU Disability Rights Strategy
European Disability Forum Urges Inclusive Design in AI Strategy
21 May 2025
Topic — The initiative aims to accelerate industrial AI adoption and improve public service delivery.
Message — Inclusion must be explicitly recognised as a cross-cutting objective for all technologies. The strategy should support AI that serves the public good and accessibility needs. The Commission should provide guidance and testing infrastructures to consult people with disabilities.123
Why — Inclusive design would provide 100 million Europeans with disabilities better access and autonomy.4
Response to LGBTIQ Equality Strategy
21 May 2025
Supporting the call of ILGA-Europe for an ambitious LGBTI Equality Strategy 2025-2030, the European Disability Forum (EDF) calls on the Commission to pay specific attention to the situation and rights of LGBTI people with disabilities. In 2023, ILGA-Europe published a briefing on intersection analysing the results of the FRA LGBTI Survey II from a disability perspective, with the feedback and endorsement from EDF. Many LGBTI people with disabilities are at risk of multiple and intersectional forms of discrimination in all areas of life in the EU. This is particularly true in the areas of education, employment and healthcare. The analysis of the FRA LGBTI Survey II confirmed that LGBTI people with disabilities face unique challenges and experiences compared to all respondents who participated in the survey. Some of the key issues shared in the briefing are the following: 1) Economic hardship: LGBTI people with disabilities, particularly trans women, struggled more to make ends meet, and individuals with intersecting identities, such as trans respondents with disabilities who are also ethnic minorities or intersex, were more likely to experience homelessness. 2) Inadequate access to healthcare: LGBTI persons with disabilities faced significant barriers in accessing healthcare services. Trans women, intersex, and non-binary individuals reported the highest levels of difficulty in accessing healthcare. High rates of inappropriate curiosity or comments from healthcare providers were reported. 3) Discrimination: LGBTI people with disabilities experienced elevated levels of discrimination across various aspects of life, including in workplace, healthcare or social services, and in public establishments. Highest levels of discrimination were reported by trans individuals, ethnic minorities, and trans women with disabilities. 4) Harassment and violence: LGBTI people with disabilities, especially intersex, trans women, and non-binary individuals, reported facing higher rates of harassment, including offensive comments, physical, and sexual attacks, often perpetrated by family, acquaintances, neighbours, and public servants. Some areas not covered by the survey are thus not mentioned above, but are cause of concerns for our organisations. For example, LGBTI people with disabilities who do not receive support to live independently and in the community, may have their sexuality and/or gender identity controlled or denied, facing violence and abuse in their own home. Similarly, LGBTI people with disabilities living in closed settings (such as residential or psychiatric institutions) can face specific issues, from abuse when they express their sexual orientation or gender identity, to lack of access to gender affirming healthcare services and support. In addition, trans and intersex people and persons with some types of disability may rely on healthcare services more heavily, and yet face additional barriers when it comes to access and quality services. Overall, we note a lack of access, space and visibility for and of LGBTI people with disabilities to express their concerns and claim their fundamental rights at national and European level. We call for: 1. Broadening of EU anti-discrimination legislation to explicitly cover sexual orientation, gender identity and sex characteristics, and disability across all areas of life 2. Strengthening of the intersectional approach in development, transposition and monitoring of EU laws 3. Strengthening of the intersectional approach in EU Strategies: in the renewal of the LGBTIQ Equality Strategy (post-2025) and the ongoing Disability Rights Strategy, explicitly address the unique barriers faced by LGBTI persons with disabilities, with concrete actions and measurable objectives. 4. Establishment of clear monitoring mechanisms 5. Increase of disaggregated data collection and intersectional research 6. Development of targeted support programmes
Read full responseMeeting with Isilda Gomes (Member of the European Parliament, Shadow rapporteur)
13 May 2025 · EU Strategy on the Rights of Persons with Disabilities
Meeting with Giusi Princi (Member of the European Parliament, Rapporteur for opinion)
28 Apr 2025 · Disability
Meeting with Jessika Roswall (Commissioner) and
25 Apr 2025 · Consultation of disabled groups in the context of policy and legislative development
Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Helena Robyn (Cabinet of Executive Vice-President Stéphane Séjourné), Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)
22 Apr 2025 · European Single Market, Standardisation, Public Procurement, Intellectual Property
Meeting with Glenn Micallef (Commissioner) and
14 Apr 2025 · Introductory meeting
Meeting with Valérie Devaux (Member of the European Parliament, Shadow rapporteur) and European Association of Service providers for Persons with Disabilities
24 Mar 2025 · handicap
Response to EU rules on medical devices and in vitro diagnostics - targeted evaluation
21 Mar 2025
The right to the highest attainable possible standard of health without discrimination based on disability is a fundamental principle enshrined in international human rights treaties and the EU Charter of Fundamental Rights. Additionally, 22 Member States either prohibit disability discrimination in the field of healthcare, require reasonable accommodation or both. Failure to provide essential and accessible medical devices can constitute an indirect discriminatory denial of healthcare; Failure to provide adapted equipment as a reasonable accommodation can be classified as a form of discrimination under national law where applicable. Yet, inaccessible medical devices remain a key barrier to health and health services for persons with disabilities in the EU. This, among other barriers, contributes to higher unmet medical needs, poorer access to services, lower self-reported health status, late diagnosis and higher mortality compared to persons without disabilities. For example, in Romania, women with physical impairments have reported lack of access to breast and cervical cancer screening because examinations tables cannot be adjusted to the correct height, and mammography machines cannot be adjusted for those who cannot not stand. The EU Medical Devices Regulations do not currently account for the needs of persons with disabilities, with standards and/or requirements for manufacturers on accessibility and adaptability. Therefore, the regulations do not ensure that devices are safe, available nor adequately meeting the needs of the 101 million persons with disabilities in the EU. The U.S. Access Board offers a good practice in establishing recommendations on accessibility standards for diagnostic equipment for adults with disabilities. The Access Board is an independent federal agency dedicated to promoting accessibility by leading efforts in inclusive design and establishing accessibility guidelines and standards. The Board's standards establish design criteria for various medical diagnostic equipment, including tables, chairs, dental and optical exam chairs, weight scales, radiological and mammography equipment, and other diagnostic tools used by healthcare professionals. These standards apply to equipment requiring patient transfer from wheelchairs and other mobility aids, outlining requirements for transfer surfaces, support rails, armrests, lift compatibility, and additional accessibility features. They also cover equipment designed to accommodate mobility devices without the need for transfer. The accessibility standards for diagnostic equipment were developed in partnership with stakeholder representatives including medical device manufacturers, health care providers, organisations of persons with disabilities, among others. While accessibility standards are needed beyond diagnostic equipment, including for treatment, prevention and monitoring devices, the Access Board standards offer good practice in process and outcome. The European Disability Forum urges the Commission to use evidence from the Access Board and other accessibility experts to ensure any revision to the Medical Devices Regulations account for the safety and efficacy of devices for persons with disabilities. Accessibility standards for medical devices must be established to ensure providers have and know how to use the right tools for all patients, to meet their obligations, both to quality of care and to non-discrimination on the basis of disability. Harmonisation at the EU level is necessary to ensure equal access to services for persons with disabilities in cross-border situations, to enable Member States to implement pending EU guidelines on increasing access to healthcare for persons with disabilities, and to meet the EUs and Member States obligations under the United Nations Convention on the Rights of Persons with Disabilities.
Read full responseMeeting with Célia Dejond (Cabinet of Commissioner Wopke Hoekstra), Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)
21 Mar 2025 · Discussion on EU climate policy and international climate diplomacy
European Disability Forum urges inclusive EU public procurement reforms
25 Feb 2025
Message — The organization calls for prioritizing quality and personal choice over cost alone when procuring support services for persons with disabilities. They advocate for mandatory accessibility standards in technical specifications and the exclusion of sheltered workshops with poor working conditions from reserved contracts. Furthermore, they demand the establishment of redress mechanisms and the involvement of disability experts in the tendering process.123
Why — These changes would ensure public spending better supports independent living and high-quality employment for persons with disabilities.45
Impact — Service providers focusing solely on low costs and sheltered workshops paying sub-minimum wages would lose access to contracts.6
Meeting with Kim Van Sparrentak (Member of the European Parliament) and AGE Platform Europe and Equinet - the European Network of Equality Bodies
19 Feb 2025 · Withdrawal horizontal anti-discrimination directive
Meeting with Alice Kuhnke (Member of the European Parliament, Rapporteur) and The European Region of the International Lesbian, Gay, Bisexual, Trans and Intersex Association and
19 Feb 2025 · Anti-discrimination
Response to Evaluation of the EU Lifts Directive
13 Feb 2025
Please find attached the feedback by the European Disability Forum (EDF) on the evaluation of the lift safety directive.
Read full responseMeeting with Hristo Petrov (Member of the European Parliament)
13 Feb 2025 · European Disability Employment and Skills Guarantee
Meeting with Andrey Novakov (Member of the European Parliament, Shadow rapporteur)
10 Feb 2025 · Passenger rights file
Meeting with Lynn Boylan (Member of the European Parliament)
5 Feb 2025 · Persons with Disabilities in Occupied Territories
Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur for opinion)
30 Jan 2025 · Droits des passagers
Meeting with Alex Agius Saliba (Member of the European Parliament)
29 Jan 2025 · Executive committee meeting with Disability Intergroup bureau
Meeting with Alicia Homs Ginel (Member of the European Parliament, Rapporteur)
29 Jan 2025 · Implications of the Traineeships Directive for persons with disabilities
Meeting with Cecilia Strada (Member of the European Parliament)
28 Jan 2025 · discussion on the rights of persons with disabilities, including voting rights, access to quality healthcare and education and removal of barriers
Meeting with Alice Kuhnke (Member of the European Parliament, Shadow rapporteur for opinion) and Bureau Européen des Unions de Consommateurs and
27 Jan 2025 · Passenger rights
Meeting with Vicent Marzà Ibáñez (Member of the European Parliament, Shadow rapporteur)
21 Jan 2025 · Implementation of Passenger Rights
Meeting with Idoia Mendia (Member of the European Parliament)
16 Jan 2025 · Meeting with EDF
Meeting with Jana Toom (Member of the European Parliament, Rapporteur)
14 Jan 2025 · Protection of vulnerable adults
Meeting with Maria Guzenina (Member of the European Parliament)
27 Nov 2024 · Disability Rights
Meeting with Marit Maij (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and
14 Oct 2024 · Roundtable with CSOs for input for ESF Plus
Meeting with Jana Toom (Member of the European Parliament) and EUROPEAN TRADE UNION CONFEDERATION and
3 Oct 2024 · Social and Inclusive Growth
Meeting with Tilly Metz (Member of the European Parliament)
1 Oct 2024 · Disability
Meeting with Pál Szekeres (Member of the European Parliament)
10 Sept 2024 · Exchange on current disability issues
Meeting with Miriam Lexmann (Member of the European Parliament)
11 Jul 2024 · Re-establishment of the Disability Intergroup
Meeting with Alex Agius Saliba (Member of the European Parliament)
11 Jul 2024 · To discuss the Rights of Persons with Disabilities and re-establishment of the Disability Intergroup at the European Parliament
Meeting with Ádám Kósa (Member of the European Parliament) and Equinet - the European Network of Equality Bodies and European Association of Service providers for Persons with Disabilities
16 Apr 2024 · Social inclusion of people with disabilities
Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Community of European Railway and Infrastructure Companies and
2 Apr 2024 · Stakeholder Meetings on Passenger Mobility Package
European Disability Forum demands full liability for broken wheelchairs
7 Mar 2024
Message — EDF requests air rules to eradicate denied boarding and establish full liability for damaged equipment. They also call for stronger powers for national enforcement bodies.12
Why — These changes would protect disabled passengers from discrimination and high costs for replacing damaged equipment.3
Impact — Airlines would face increased costs by paying for companion tickets and providing full equipment liability.4
European Disability Forum demands stronger multimodal travel rights
7 Mar 2024
Message — EDF requests wider coverage of multimodal journeys and shorter assistance pre-notification times. They also want full liability for damaged mobility equipment for the entire journey.123
Why — This proposal would improve travel autonomy and financial protection for passengers with disabilities.45
Meeting with Grace O'Sullivan (Member of the European Parliament)
22 Feb 2024 · The rights of people with disabilities in Ireland and Europe
Meeting with Abir Al-Sahlani (Member of the European Parliament, Rapporteur)
15 Feb 2024 · EU Talent Pool
Response to ESF+ mid-term evaluation
7 Feb 2024
The European Disability Forum views the European Social Fund as one of the most important and impactful forms of EU funding for reducing inequalities throughout the Member States. It has been key to improving the social inclusion of persons with disabilities all over Europe. We therefore strongly believe that the ESF+s budget must be enhanced in the next Multiannual Financial Framework. The inclusion of the Enabling Conditions within the Common Provisions Regulation, governing the use of ESF+ funding, are also to be highly commended. They have been key to clarifying that ESF+ spending must be used to improve the inclusiveness of the open labour market and mainstream education for persons with disabilities, and that funding must not go towards services that further isolate persons with disabilities from their communities. While there is a lot that can be said about the ESF+s positive impact, there are nevertheless a number of shortcomings in the way the funds are distributed. First and foremost, the funds remain very difficult to access for small organisations. The main barriers to accessing and making use of ESF+ funding are the administrative burden involved in applying for and reporting on the use of funds. The high co-financing rates also mean that ESF+ funding is often only viable for large organisations or service providers to make use of. These are issues that must be addressed in the future EU funding regulations. EDF also believes that the ESF+ should focus more clearly on investing in actions with impacts that can be felt directly by citizens. A good example of this is the Youth Guarantee, which has helped numerous young people into employment and training and has given them an appreciation of how the European Union can make a difference in their day-to-day lives. EDF would strongly advocate for similar initiatives focusing specifically on persons with disabilities who are cut off from the labour market, by way of a Disability Employment and Skills Guarantee. This would respond to both the lack of progress Member States have made on reducing the disability employment gap, and simultaneously help Europe respond to its current shortage of workers. We also believe that more of the ESF+ funding in the next Multiannual Financial Framework should be earmarked for initiatives that reduce the segregation of marginalised groups and promote inclusion in the community. For persons with disabilities, in particular, we would like to see more ESF+ funding going towards the training and hiring of personal assistants and community-based services. We would also like to see the same regarding classroom assistants who can offer individualised support to learners with disabilities in mainstream educational settings. Furthermore, we would like there to be a greater emphasis on teaching skills to improve societys ability to meaningfully include persons with disabilities. This should include the teaching of national sign languages, as well as skills for making digital content accessible and usable to all. EDF strongly encourages the EU institutions and the Member States to recognise the importance of the European Social Funds for the EUs disabled community, and to reinforce the budget made available for this fund in the next MFF.
Read full responseMeeting with Cyrus Engerer (Member of the European Parliament)
1 Feb 2024 · TCN disability file
Response to 2024 EU Justice Scoreboard
18 Jan 2024
The European Disability Forum (EDF), umbrella organisation defending the rights of over 100 million of persons with disabilities in the European Union, welcomes the call for evidence on the EU Justice Scoreboard 2024. For the first time in 2022, the EU Justice Scoreboard included data on the arrangements in place to support persons with disabilities in accessing justice on an equal basis with other. This was a very positive step. This information is essential to assess the efficiency and fairness of justice systems in the EU, but also to evaluate the implementation of the United Nations Convention on the Rights of Persons with Disabilities (CRPD), to which the EU and all Member States are parties. Regrettably, the 2023 Justice Scoreboard did not include any information nor mention to persons with disabilities. EDF recalls that the European Commission that it has an obligation to report on access to justice, as Party to the CRPD. It is particularly important as the EU is currently being reviewed by the UN Committee on the Rights of Persons with Disabilities in 2025. The EU and all its Member States have the obligation to ensure equal access to justice of persons with disabilities (article 13 CRPD) through ensuring equality and non-discrimination (article 5 CRPD), accessibility (article 9 CRPD), including of communication and information (article 21 CRPD) and equal recognition before the law (article 12). They also have the obligation to collect data disaggregated by disability (article 31) to identify and address the barriers faced by persons with disabilities in exercising their rights. In its list of issues prior to reporting adopted in 2022, the CRPD Committee explicitly asked about the collection of data on access to justice by persons with disabilities, including on the respective use of the EU Justice Scoreboard. EDF renews its call for CRPD indicators to be included consistently in all Justice Scoreboards, similarly to the Child Rights indicators. Yearly information is essential in order to monitor access to justice by persons with disabilities across the EU. Such CRPD indicators could cover the indicators related to "Specific arrangements for access to justice of persons with disabilities" included in the 2022 Scoreboard, namely: Adjusted ADR procedures Court survey on needs and satisfaction of persons with disabilities Persons with disabilities can be listened to in person and express their will Procedural accommodations Accessible digital solutions at first instance courts Braille/Sign Language/Easy to Read and other specific formats available upon request Information in accessible formats (e.g. digital and paper) In addition, EDF recommends adding indicators on: Laws and procedures that guarantee access of persons with disabilities to the justice system Physical accessibility of the justice system Digital accessibility of services offered by the justice system Procedures for requesting and obtaining reasonable accommodation in court proceedings Training for all legal practitioners on the rights of persons with disabilities based on the CRPD
Read full responseResponse to European Disability Card and European Parking Card for third country nationals
16 Jan 2024
On 6 September 2023, the European Commission published the proposal for a Directive establishing the European Disability Card and European Parking Card . This was followed by a second, much shorter proposal (COM(2023) 698 final) on 31 October 2023 which extends the scope of the initial proposal to third country nationals residing legally in an EU Member State. In the following text we will analyse the second proposal and express our recommendations to the EU decision-makers. In our initial analysis of the first proposal, we already pointed out that the scope of the proposed Directive should be widened to also include third country nationals who are residing legally in the EU Member States. Therefore, it comes to no surprise that we warmly welcome the second proposal and fully support it. The second proposal will ensure coherence with the existing legislation and also the first proposal, because free movement is one of the key points of the Disability Card and should therefore also apply to non-EU citizens when they reside in the EU. Therefore, we also think that even though the legal base (Art. 79 (2) TFEU) allows some Member States to restrict this freedom of movement for third country nationals, notably Denmark and Ireland, we urge those Member States to fully apply this Directive and allow all persons with disabilities to take advantage of the European Disability Card and the Parking Card. As with the first proposal for the two Cards, we would like to point out that that these Cards will not solve all the problems of free movement for persons with disabilities in the EU. Essentially, the Disability Card will provide assurance of mutual recognition of disability for persons with disabilities for all services, facilities and activities for short stays in other EU Member States. A significant barrier to free movement for persons with disabilities is not included: this is with regard to social protection underpinning the permanent moving to another Member States to work or study and this will also remain an obstacle for third country nationals. However, in the context of what an instrument like the Disability Card can achieve, it is very promising in the sense of creating certainty and removing administrative barriers for both persons with disabilities and private and public operators of services, facilities and activities. As with the first proposal, we call on the EU institutions to move quickly to improve the proposal and adopt it as soon as possible and we stand ready to engage with all policy makers who wish to have further information on how these cards impact us.
Read full responseResponse to 9th Report on economic, social and territorial cohesion
18 Dec 2023
Measuring progress in reducing economic, social and regional disparities must take into account whether the EUs efforts to bridge the gaps between different Member States and regions is being felt by all in society. The European Disability Forum would therefore like to draw attention to the fact that while some statistics might signal a closing of disparities across the EU, they ignore the fact that many members of society are being left behind. We would like to stress the need for this to be clearly reflected in the 9th Report on economic, social and territorial cohesion. Persons with disabilities throughout the EU statistically fare far worse than their counterparts without disabilities when it comes to economic and social stability and wellbeing, with little signs of progress over the past decade. When it comes to employment rates, for example, we still see a persistent disability employment gap. On average, throughout the EU, persons with disabilities are 21.4 percentage points less likely to be employed than persons without disabilities, with huge disparities between Member States. Countries faring particularly poorly in this area are Ireland, Belgium, Poland, Hungary, Croatia, Romania and Bulgaria. We also observe that only 29% of men with disabilities and 20% of women with disabilities in the EU are working full-time. Again, the reality varies drastically between Member States. Countries with particularly low full-time employment rates, particularly for women with disabilities, include Ireland, Belgium, Spain, Italy, Malta, Poland, Hungary, Croatia, Romania, Bulgaria and Greece. Salaries are also vastly different for persons with and without disabilities. In every EU Member State, the average mean equivalised net income per year is distinctly lower for persons with disabilities (particularly women) than it is for persons without disabilities. Particularly low annual salaries for persons with disabilities are observed in Bulgaria, Croatia, Greece, Hungary, Latvia and Romania . Persons with disabilities are also disproportionately affected by the risk of poverty and social exclusion. Once again, it is an area where we see significant geographical disparity. The most recent Eurostat data suggests that 29.7% of the EU population with a disability was at risk of poverty or social exclusion compared with 18.8% of those with no disability. Data from 2020 indicated that the percentage of persons with disabilities who were living in households at risk of poverty was highest in Latvia (33.7 %), Estonia (35.9 %) and Bulgaria (37.5 %). Ireland and Belgium, meanwhile, showed the biggest difference in poverty rates between people with and without disabilities . Equally present throughout Europe is the gap in educational attainment between persons with and without disabilities. At EU level about 22.9 % of young persons with disabilities aged 18-24 are early school leavers in comparison with 9.3 % for non-disabled young persons. Countries where the situation is particularly pressing include Germany, Romania and Malta. Persons with disabilities also face difficulty in accessing adequate healthcare. Unmet health needs are particularly common for persons with disabilities in certain Member States. While on average in the EU 4.1 % of persons with disabilities aged 16 and over reported unmet needs for medical care in comparison with 0.9 % for persons without disabilities, the rates were highest in Romania (16.4 %), Greece (19.0 %) and Estonia (20.4 %) . We therefore urge the European Commission, in this report, to acknowledge that measuring cohesion among the Member States and their regions must extend to monitoring how persons with disabilities and other marginalised groups are supported. The report must explore whether the gap between countries is also being bridged when it comes to these groups, or whether social and regional disparities between persons with disabilities are being left to stagnate or even worsen.
Read full responseMeeting with Beatrice Covassi (Member of the European Parliament)
30 Nov 2023 · European Day of Persons with Disabilities 2023
Meeting with Patrizia Toia (Member of the European Parliament)
29 Nov 2023 · Disability Week
European Disability Forum Urges Protection of Disability Reporting Standards
28 Nov 2023
Topic — This initiative aims to reduce EU legislative reporting requirements by twenty-five percent.
Message — Reporting simplification must not come at the expense of disability-related requirements. They urge the preservation of standards on workforce diversity and accessible working environments. Mandatory disclosure on equal treatment and opportunities for disabled employees must remain.12
Why — Maintaining these rules ensures corporate accountability regarding the inclusion of disabled employees.3
Impact — Persons with disabilities lose visibility and protection within corporate sustainability frameworks.4
Response to European Disability Card
2 Nov 2023
First of all, we would like to underline that our initial reception of the proposal is very positive. The proposal will result in binding legislation for both Cards. For many years EDF has campaigned for the European Disability Card, and we, and our extensive membership took part in the policy development process till now; most priorities we highlighted have been included in the proposal. The Card will serve as a basis for raising greater awareness of diversity and promoting the acceptance of people with disabilities in society, while also enhancing social responsibility. It must also be noted that the Cards will not solve all the problems of free movement for persons with disabilities. Essentially the Disability Card will provide assurance of mutual recognition of disability for persons with disabilities for all services, facilities and activities for short stays in other EU Member States. A significant barrier to free movement for persons with disabilities is not included: this is with regard to social protection underpinning the permanent moving to another Member States to work or study. In the context of what an instrument like the Disability Card can achieve, it is very promising in the sense of creating certainty and removing administrative barriers for both persons with disabilities and private and public operators of services, facilities and activities. EDF calls on the EU institutions to move quickly to improve the proposal and adopt it as soon as possible and we stand ready to engage with all policy makers who wish to have further information on how these cards impact us. See the document attached for a more detailed analysis of the strong points of the proposal and where it can be improved.
Read full responseMeeting with Magda Kopczynska (Director-General Mobility and Transport)
31 Oct 2023 · Upcoming review of the passenger rights regulation
Meeting with Nicola Danti (Member of the European Parliament, Shadow rapporteur for opinion)
30 Oct 2023 · European Disability Card
Meeting with João Albuquerque (Member of the European Parliament, Shadow rapporteur)
25 Oct 2023 · Disability Card
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
24 Oct 2023 · Social Taxonomy
Meeting with María Soraya Rodríguez Ramos (Member of the European Parliament, Rapporteur)
19 Oct 2023 · Revision of the Victims Rights Directive
Response to Integrated child protection systems
18 Oct 2023
For children with disabilities the risk of abuse and violence is particularly high. This means that any child protection system must recognise and address the threats posed to children with disabilities. This includes identifying the settings in which children with disabilities are most exposed to risks. One kind of setting that is particularly problematic for children, is that of residential institutions. Institutions segregate children from their community and deny them their right to grow up in a family setting. This is particularly pressing for children with disabilities, especially those with high support needs, who are overrepresented in institutional settings. Being institutionalised has been shown to significantly increase the risk of abuse and severe disciplining, including corporal punishment and restraint, as well as cases of forced sterilisation, which it is still legal to inflict upon minors in three EU Member States. Children and young people in institutions are also shown to be less likely to attend school than their peers, missing out on the crucially formative contribution that education can provide in preparing a person for independence in adulthood. Furthermore, the lack of positive, consistent and individual attention can hinder their emotional, physical, mental, and social development. This initiative from the EU must support the Member States in their transition away from institutions and towards family-based care for all children, and underline that no EU funding go towards segregating care settings for children with disabilities. Far more investment must be made to enable children to find family-based alternatives where they can be given support to develop freely and be educated in inclusive mainstream settings adapted to their needs. The EU and the Member States also need to improve their data collection on all children living in institutions. Improvements in data collection must be twinned with quantitative, time-bound targets for the number of children leaving institutions. Another area in which children with disability are particularly vulnerable is regarding bullying and harassment online. Just is in other settings, we need to see mechanisms put in place to easily report cases of online hate, with a guarantee that these concerns will be followed up and addressed. We also need systems in place to detect people who instigate online bullying, and to hold them accountable for their actions. We must work towards the creation of online culture where people are aware that their actions have real consequences on the lives of others, and where bullying and harassment will be monitored and taken as seriously as it would in any other setting. Finally, family contexts must be monitored. Children with disabilities living in precarious family situations are more exposed to serious human rights violations, as well as to neglect, abuse, maltreatment, and violence. The factors that lead families to precariousness and hardship, namely economic fragility, household composition and other social risks, are factors that can accentuate the disability-related challenges a child faces, and can even result in a worsening of their condition. At the same time, having a child with a disability considerably increases the risk of a family falling into a precarious situation in the first place. It reduces the ability of parents or other family members to take up full-time paid work, and equally results in a considerable number of extra costs. These stress factors can increase the risk of family breakdown, and even of domestic violence. Systems for child protection must therefore pay special attention to the link between disability and the precarity of households. It is thus necessary to collect data on children with disabilities who live in disadvantaged family contexts so that policies and actions to support their quality of life are effective and do not lead to institutionalisation as the only alternative
Read full responseMeeting with Lucia Ďuriš Nicholsonová (Member of the European Parliament, Rapporteur)
11 Oct 2023 · European Disability Card and the European Parking Card
Response to Evaluation of Standardisation Regulation (EU) No 1025/2012
29 Sept 2023
The European Disability Forum (EDF) welcomes the Commissions call for evidence to evaluate Regulation 1025/2012. More specifically, it applauds that the evaluation will aim, among others, at assessing whether the standard-development process in the EU is inclusive, transparent and non-discriminatory. EDF does not believe that the current European standardisation system ensures a truly representative, fair, inclusive and meaningful participation of civil society organisations, including disability organisations. EDF's experience in the development of recent European standards on accessibility, including harmonised standards, has been far from positive, and we have serious concerns about whether the Regulation is fit for its purpose when standards are requested to support EU policies or, more importantly, to demonstrate compliance with EU harmonised legislation. You can find more information in the attached document.
Read full responseResponse to Ex-post evaluation REC and EfC programmes (2014-2020) and interim evaluation CERV programme (2021-2027)
19 Sept 2023
The European Disability Forum is an umbrella organisation of persons with disabilities. We bring together representative organisations of persons with disabilities from across Europe. We defend the interests of more than 100 million persons with disabilities in Europe. We are run by persons with disabilities and their families. EDF is also a member of Civil Society Europe. The Citizens, Rights, and Values Programme (CERV) is very important for EDF as the operating grant helps us to represent 100 million of persons with disabilities in Europe. Several EDF members also benefit from the CERV operating grants. We firmly believe in the need not only to continue the programme, but also to further reinforce it, notably through improving the implementation of some of its provisions, learning from good practice and ensuring further links with other programmes, as well as reinforcing its budget, which would allow to fund further actions, facilitate access by civil society organisations at all levels, and respond to an increasing demand. The programme is built into a solid and meaningful structure with its different strands. All strands are crucial and should remain priorities in the next cycle, as they address important dimensions of rights and values as well as democratic participation. It is especially important of course to keep the specific strand providing operating grants for Disabled Persons Organisations. The temporary change in the co-financing level from 20% to 10% in the current programme period is very positive and helpful for EDF and its member organisations. We recommend keeping the lower co-financing level for future funding programmes as it is already the case for other programmes such as ESF+, for example. Furthermore, the impact of inflation should be considered (as it was for the second year), both for real cost (e.g. salaries) and unit costs. Also travel by plane foresees much higher ceilings than travel by train, which is not consistent with reduction in carbon emission and does not correspond to the reality. Therefore, the impact of inflation in general costs, on salaries, services, etc should be addressed. The alignment of the CERV grants on the Horizon Europe Platform facilitates the reporting and application in certain ways. We appreciate for example, that the application and reporting procedure is now paperless. However, this platform intended initially for the funding of research grants, is not adapted to CERV objectives and to the type of beneficiaries such as Disabled Persons Organisations like ours. This is especially difficult for operating grants such as the one EDF is receiving, because the language and the structure of the reporting is clearly related to research grants based on projects of a limited time, whereas we rather have continuous activities. Another issue related to the implementation is the question of the obligatory EU Survey. Participants to CERV funded activities must fill in a lengthy feedback survey which includes a lot of general questions that are not relevant to the event, including on the state of democracy for example. Apart from the cumbersome procedure, we have the added problem of accessibility for persons with disabilities. The questions are difficult to understand and the survey is very complex, so we fear that this is discouraging participants to reply. Therefore, we suggest having a discussion on the content and the format of the survey and how it can be improved in order ensure full accessibility and as a result also higher engagement rates and make the exercise more useful and fit for purpose for all concerned. Conclusion: the CERV programme is a very important and valuable tool to support Disabled Persons Organisations to engage with the policy-making processes on EU level. It should definitely be continued in the next Multi-Annual Financial Framework under comparable, albeit slightly improved conditions.
Read full responseMeeting with Katrin Langensiepen (Member of the European Parliament, Shadow rapporteur)
18 Sept 2023 · Disability Card
Response to Civil aspects of the cross-border protection of vulnerable adults
17 Aug 2023
The European Disability Forum (EDF) is extremely concerned that the proposed Regulation on protection of adults does not comply with the obligations of the EU and all its Member States under the United Nations Convention on the rights of persons with disabilities (CRPD), and is generally in breach with the fundamental rights of equality and autonomy applicable to every EU citizen. While our organisation emphasised in all stages of the consultation process the obligation for the EU to ensure that proposed laws and policies respect and promote the rights of persons with disabilities, we regret that the input of the disability movement was ignored. Although the recital of the proposed regulation does refer to the CRPD, the core of the proposal falls short by referring to measures that violate the rights of persons with disabilities, such as substituted decision-making mechanisms (such as guardianship and curatorship) (art. 3) and institutionalisation (art. 21). As already stated, our organisation would welcome and support conflict of law legislation which would foster measures that promote the rights of persons with disabilities, such as supported decision-making regimes which are increasingly being adopted by EU Member States and advance directives. Yet, such measures are not covered by the proposal. We also regret that the proposal fails to explicitly mention the CRPD under article 58 relative to relations with other instruments. EDF stresses that substantial issues cannot be ignored while dealing with conflict of laws. The EU, including as party to the CRPD which is a mixed-agreement, has the obligation, along with its member states to respect, protect and promote the rights of persons with disabilities including their right to equality, legal capacity and independent living and as committed under the EU strategy on the rights of persons with disabilities. Finally, we would like to bring to the Commissions attention, the joint submission on the adequacy of the European Commissions proposal for a Regulation and Council Decision governing the Hague Convention on the Protection of Adults made by the UN Special Rapporteur on the rights of persons with disabilities and UN Independent Experts on the enjoyment of all human rights by older persons (joint to this feedback). The experts criticise that the core of the proposed Regulation does not comply with the CRPD. In the joint submission they note that: The notion of representation seems mixed in the draft proposal with the notion of supported decision-making in the CRPD. Article 3.3 of the proposal misunderstands the difference between a power of representation and supported decision-making required by the CRPD. Article 21 of the proposal allows for a protection measure of placement in an institution. This is a clear violation of both Articles 5 (equality) and 19 right to live independently) in the UN CRPD and should have no place in the Regulation. The experts state that both draft Articles 3.3 and 21 of the Regulation therefore require revisiting. In addition, they stress that: as between EU Member States and external parties, we would go further than we did in 2021 and suggest that the Decision authorising Member States to ratify the convention should make clear that they should not only make the general Interpretative Declaration we proposed in 2021, but also should make a Reservation to the Convention excluding (to the effect that it does allow for it) institutionalisation from the scope of protective measures." EDF will call on the negotiators to fundamentally revise the provisions of the proposed Regulation to align with the CRPD. Unless the proposal is amended according to the recommendations issued by the UN experts mentioned above, the regulation must not be adopted.
Read full responseMeeting with Ciarán Cuffe (Member of the European Parliament) and Fédération Européenne d'Associations Nationales Travaillant avec les Sans-Abri
18 Jul 2023 · Exhibition opening event on homelessness
European Disability Forum urges no delays in disability reporting
6 Jul 2023
Topic — New rules for how companies report on environmental, social, and governance sustainability factors.
Message — The group demands that companies immediately report on the percentage of employees with disabilities. They urge the Commission to remove phase-in delays for smaller companies. Finally, they want all disability and accessibility reporting requirements kept in the final law.123
Why — This ensures corporate accountability and forces companies to prioritize inclusive employment practices.4
Impact — Smaller companies lose the proposed exemptions and must face immediate reporting costs.5
Response to Ex-post evaluation of macro-financial assistance to Georgia, Moldova and Ukraine
4 Jul 2023
Ensuring that persons with disabilities participate on an equal basis with other people is not only a basic matter of social justice. It is also a human rights obligation under the UN Convention On The Rights Of Persons With Disabilities (CRPD), to which the EU, Ukraine, Georgia and Moldova are State Parties. Inclusion of persons with disabilities is also embedded in the 2030 Agenda, both through specific references to disability, and through the overall principle that no one will be left behind. Moreover, the European Strategy for the Rights of Persons with Disabilities recommits the EU to uphold the human rights of persons with disabilities and support their social inclusion in all international relations, and as part of all external action, policy planning, funding programmes and activities. For all these reasons, it is essential that in future MFA to these and other third countries, the EU take deliberate steps to ensure that persons with disabilities and their representative organisations in the country can participate in all national reforms affecting persons with disabilities. We request the EU to ensure that all future financial assistance will be fully inclusive of persons with disabilities, and simultaneously that sufficient funding is dedicated to disability-specific reforms which address the specific situation of persons with disabilities. We call for the future MFA to take into consideration the following: It is essential for the MFA to contribute to reforms aiming at the fulfilment of human rights and countrys obligations under the United Nations Convention on the Rights of Persons with Disabilities (CRPD). Other UN global frameworks and conventions include UN CEDAW, UN CRC, UN 2030 Agenda, the Paris Agreement on Climate Change and the Sendai framework. Meaningful involvement of persons with disabilities, through their representative organisations (DPOs/OPDs) in all decision-making processes; from the planning to implementation and monitoring of the reforms carried out with EUs financial assistance. It is fundamental that the consultation strategy led by the EU and national governments will include consultation of key stakeholders and a wide range of organisations representing civil society, including DPOs/OPDs. We urge the EU, not to allow the use of these financial instruments to maintain or reinforce institutionalised care for persons with disabilities, this is the rehabilitation and construction of residential institutions that perpetuate the segregation of persons with disabilities. On the contrary, we wish for the allocation of funds to support reforms which underpin independent living and strengthening the community-based care systems. We call the EU to set the condition for financial assistance not to fund the creation of additional barriers or segregation of persons with disabilities. In line with other EU financial instruments, accessibility and non-discrimination pre-conditions must be put in place. Regarding Ukraine, the process which will lead to the reconstruction of the country needs to be accessible and inclusive for persons with disabilities, and linking this to the countrys EU candidate status, we emphasise that this is an opportunity to rebuild an inclusive and resilient society. Such reconstruction requires prioritisation of accessibility for persons with disabilities, and principles such as Barrier-Free Environment and Universal Design, with investment, at the very beginning of all planning and decision-making processes, of specific budget to ensure that these principles are fundamentally non-negotiable. We call the EU to ensure that financial aid for Ukraine, Moldova and Georgia fully consider and include persons with disabilities. This includes the financing of fully accessible public and relevant disability-specific services aiming at implementing the CRPD.
Read full responseMeeting with Abir Al-Sahlani (Member of the European Parliament)
13 Jun 2023 · Conference Of States Parties To The Convention On The Rights Of Persons With Disabilities
Meeting with Ilana Cicurel (Member of the European Parliament, Shadow rapporteur)
6 Jun 2023 · Implementation of the CERV programme - Meeting with the Senior Policy Coordinator of the European Disability Forum
Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)
2 Jun 2023 · Discussion on the AI Act (meeting held by the Assistant responsible)
Meeting with Helena Dalli (Commissioner) and
28 May 2023 · Commissioner intervenes at the European Disability Forum, in occasion of the General Assembly.
Response to Evaluation of “Marrakesh” Directive and Regulation
11 May 2023
Please find attached the European Disability Forum's Feedback to the Commissions' call for evidence on the implementation of the Marrakesh Directive and Regulation.
Read full responseMeeting with Brando Benifei (Member of the European Parliament, Rapporteur)
8 May 2023 · Call on the AI Act implications for persons with disabilities (meeting taken by the APA responsible))
Response to Boosting European learning mobility for all
3 May 2023
The European Disability Forum (EDF) represents over 100 million of persons with disabilities in 42 European Countries. We are also part of the monitoring Mechanism on the UN Convention on the Rights of Persons with Disabilities that the EU and all its member states have adopted and ratified. Our motto is nothing about us without us and this is also what the EDF Youth Committee wants to experience in mobilities when studying, doing a traineeship, volunteering or working. Young people with disabilities experience often discrimination in mobility due to lack of knowledge by people with disabilities about mobility opportunities, lack of accessibility from information to venues, limited or non existent resources to cover costs linked to disability and stereotypes linked to disabilities, a reduced mobility being understood as not willing to move. To ensure young people with disabilities can meaningfully participate in learning mobility activities we recommend the EU to recommend Member states to: Respect the Convention on the Rights of Persons with Disabilities that all member states have ratified and adopted ensuring reasonable accommodation measures are foreseen in all learning mobility opportunities. We also recommend to be in line with the EU legislation the EU Directive on Accessibility of Websites and Applications and the EU Accessibility Act for example the institutions should have ther websites and applications respecting the Accessibility Standards, using accessible Boards checking in machines at the library etc. Ensure accessibility from the first stage , publishing accessible information, to the end one, on providing accessibility measures during the activities such as accessible housing, accessible learning material and use of accessible learning platforms. All learning mobility opportunities should provide financial and human resources to supporting learners with disabilities, funds that would cover costs related to disability such as Personal Assistant, Sign Language interpreter, renting or buying assistive technologies (voice recognition soft, screen reader, assistive displays etc), mobility sessions or other supporting services, , and knowledgeable staff who can support learners with disabilities that would go on a mobility. Put in place mechanisms to linking the Disability units of the Learning facilities with their mobility service in order to provide an inclusive and accessible service Provide disaggregated data on Disability of participants in Learning Mobility Opportunities to facilitate monitoring the trend in the inclusion of participants with disabilities. Setting up ambitious inclusion objectives for learning mobility activities and to measuring these ones clear and concrete indicators should be established. National Sign Languages should be considered as languages and sign language users participating in learning mobilities should benefit of lesson of the National Sign Language at the same time with the classic language to benefit equally with non sign language users. Persons with disabilities should be included when revision evaluating or proposing of new learning mobility programme via their representative organisations. Young People with Disabilities should never be refused as participants in Learning MobMobilities Activities on the basis of their disability, the costs brought with this or that there are already people with disabilities included at a given period. All persons with disabilities must be able to do their learning mobility at the moment chosen by them and in the learning setting chosen by them as foreseen by Art.24 of the Convention on the Rights of Persons with Disabilities.
Read full responseMeeting with Adina-Ioana Vălean (Commissioner) and
3 May 2023 · Transport and disability
Meeting with Věra Jourová (Vice-President)
2 May 2023 · Political participation of persons with disabilities
Meeting with Karima Delli (Member of the European Parliament, Rapporteur)
2 May 2023 · European Disability Forum
Response to 2022 European Year of Youth – achievements and way forward
13 Apr 2023
The European Disability Forum (EDF) represents over 100 million of persons with disabilities in 42 European Countries. Our motto is nothing about us without us and this is also what the EDF Youth Committee hoped to experience during the European Year of Youth (EYY). From our survey on the topic we found that: Ensure that the information about the European Year of Youth is available in accessible formats The promotional materials are accessible: videos with subtitling, sign language audio-description; The social media campaigns contain accessible information: alt text to images; The events are organised in accessible venues, that sign interpretation and real time captioning are ensured ; Personal assistance is covered for participants who need it Young persons with disabilities are included in the European and National dialogs with steak holders and civil society We were glad to see openness from the European Commission,. During this year our efforts were rewarded, and we are proud to say that we have done the following together with our members: we joined the Stake holder group on the EYY We had discussions with the European Commission and provided feedback on the accessibility of the platform and its materials. For the platform much was done while for the materials published there less. Organised 10 activities on different topicsMental Health and social media,) a photo competition, workshop organising inclusive events collected more than 500 ideas improve the future of Europe a panel on Youth at the European Day of Persons with Disability event we co-organise with the European Commission The Youth Committee was invited to four Youth Dialogues and participated in three of them. The EYY Activity calendar on the platform had tags and fields to include Accessibility and the final meeting of last year had automatic captions. Much was achieved on our side and of course we are proud of it, yet we think that young people with disabilities were not fully included in the EYY.. Accessibility for persons with Disabilities: The Young Voices platform due to accessibility reasons had a separate accessible version for people using assistive technologies, and during the Final Event that was live streamed deaf young people sign language users were not able to follow this as international sign was not foreseen despite the fact that we heared there was budget over .. EDF was invited to 4 out of the 26 Youth Dialogues with Commissioner. The Commissioner on Youth Education and Sport has not invited to the dable for any of her dialogues the disability movement, so did some others and we felt excluded from those discussions. Many of the produced promotional materials were not subtitled nor were they with International Sign available. We acknowledge the effort done and we congratulate the European Commission and all organisers . However, that improvement can be made in the future for the inclusion of young people with Disabilities. For this we recommend: 1. Ensure to include the Disability People organisations and their youth group in at all levels of discussion to ensure not leaving young people with disabilities behind. 2. Include accessibility measures at all stages of the activities and dialogues such as; human live captioning, international sign, accessible venues for persons with reduced mobility, fund at least travel and accommodation of personal assistant, interpreters for deaf blind persons,.. 3. Provide financial and human resources to accommodate the accessibility requirements of participant with disabilities. 4. Ensure that the digital supports used in any type of actions are accessible platforms, surveys, streaming, documents they should respect the Web Accessibility Directive. 5. Ensure you have a dedicated space for accessibility on your web page of the events where you indicate the accessibility measures you put in place and provide a contact point in any form possible.
Read full responseResponse to Common form for reimbursement and compensation requests of rail passengers
6 Apr 2023
Please find attached European Disability Forum's feedback.
Read full responseMeeting with Abir Al-Sahlani (Member of the European Parliament)
31 Mar 2023 · Disability Rights in Europe - the way forward
Response to Recommendation on covert interference from third countries
22 Mar 2023
The recent and ongoing crises we are enduring in Europe have highlighted just how crucial civil society is to our democracy and to the functioning of our societies. Be it in the response to the COVID-19 pandemic or Putins invasion of Ukraine, civil society has often been the central means to support those most at risk. With each crisis Europe has confronted, civil society has shown its ability to adapt and react quickly to pressing issues. Civil society is also essential at the level of policy and decision-making. Civil society bridges the gap between policy-makers and the realities of those they represent. Engaging in dialogue with these stakeholders is thus an effective way for policy-makers to understand the varying needs of people belonging to different social groups. Furthermore, civil society encourage the participation of all in "civic democracy" to impact issues that affect them. The inclusion of civil society in the policy-making process is inseparable from the values of the EU, with Article 1 of the Treaty of the European Union stating that decisions should be "taken as openly as possible and as closely as possible to the citizen". There can be no room for the repression of social and civil society dialogue in the EU. Respect for these values should be a prerequisite for Member States to be eligible for EU funding. The EU should also have zero tolerance when it comes to Member States in which the civic space is shrinking. Ensuring that Member States uphold their EU values is not only about being open to engaging with civil society; it is also about facilitating the existence of civil society even when they are critical of policies or those in power. There must be freedom and independence for all civil society organisations in the EU. Policy-makers should ensure the meaningful participation of civil society, and not only at a superficial level. This means involving them in all parts of the decision-making process. It means hearing the views of civil society during the process of conceiving new legislation, projects or initiatives, and regularly consulting them as they take shape, are adopted and then implemented. Policy-makers at all levels should make their consultation processes easy to find and fully accessible. If the role of civil society in designing and monitoring the implementation of new policies and initiatives is to be taken seriously, then the EU, national and local authorities should support the operational costs of these organisations. This is all the more important given the uncertainties around financing caused by COVID and the invasion of Ukraine, as well as increases in operating costs because if inflation. There are a number of measures, beyond support for operational costs, that the EU and Member States could take to embrace the input of civil society. They could begin with better enforcement of existing obligations to involve civil society organisations in the programming and implementation of EU funds. Currently, the way National Managing Authorities involve organisations representing affected stakeholders is too sporadic and there is a lack of transparency around which organisations are selected and why. As such, some of the best-placed and more representative bodies defending the interests of groups such as persons with disabilities are not given a say about where EU funding should be prioritised and how it should be spent to have the desired impact.
Read full responseMeeting with Ildikó Voller-Szenci (Cabinet of Commissioner Olivér Várhelyi)
22 Mar 2023 · The inclusion of persons with disabilities in the EU neighborhood policies
Meeting with Tomasz Frankowski (Member of the European Parliament, Rapporteur) and International Federation of Library Associations and Institutions and
21 Mar 2023 · The future of the European book sector-consultation meeting with stakeholders
Response to EU Talent Pool
16 Mar 2023
EDF recommends for the EU to develop a fully self-standing and mandatory EU Talent Pool, for all labour migration purposes (as presented under policy option 4 in the call for evidence), and to include the following measures: 1. Ensure that Member States when recruiting via the EU Talent Pool enforce the EU Employment Equality Directive , that obliges employers to treat persons with disabilities equally when applying for a job and to provide reasonable accommodation during recruitment and at work. Equality bodies in the Member States should be empowered to tackle discrimination in access to employment and support victims. 2. Refer to the EU guidelines for employers on the different forms of reasonable accommodation, which the European Commission is developing as part of the EU package on Improving Employment Outcomes for Persons with Disabilities. These guidelines must focus on how to offer person-centred and flexible support to persons with disabilities and how to approach the issue of work adjustments with workers with disabilities. 3. Ensure the recognition of the disability status and eligibility for support of skilled workers with disabilities when being recruited via the EU Talent Pool. These third country workers should be provided with access to support services on an equal basis with other workers with disabilities in the EU Member State where they will live and work. 4. Ensure that third country job seekers with disabilities are not penalized by losing entitlement to support such as disability allowance. Disability allowance is a way of compensating the extra cost of living that comes with having a disability, therefore, it is not a substitution, but it must be compatible with other forms of income. 5. Promote gender equality and diversity when recruiting skilled workers from outside the EU. This means recruiting and employing skilled workers with disabilities that are particularly prone to exclusion from the labour market. This includes women with disabilities, people with disabilities of ethnic minorities, such as Roma, people with high support needs, persons with multiple disabilities, persons with intellectual disabilities and persons with psychosocial disabilities, amongst others. 6. Ensure awareness among skilled workers with disabilities and employers of the legal rights of workers with disabilities. This should focus particularly on the right to work and employment under the CRPDs Article 27 and General Comment no. 8 of the UN CRPD Committee, with particular emphasis on accessibility and reasonable accommodation. 7. The EU online Talent Pool platform should be accessible to persons with disabilities by complying with EU harmonised accessibility requirements laid down in the European Accessibility Act. The Platform should inform workers with disabilities about the services to contact when moving to the EU to receive the support they are entitled to. 8. Refer to the use of the European Social Funds Plus. Member States are encouraged to make use of the European Social Funds Plus to promote employment of groups who are regularly excluded from the labour market. The Regulation on the use of these funds details that 25% of the money should be used by Member States to foster social inclusion, which in part requires assisting groups such as persons with disabilities. 9. Collect disaggregated data by disability, gender and age of workers with disabilities. Data are necessary to adopt targeted actions to ensure full inclusion of skilled workers with disabilities in EUs labour market and societies. 10. Meaningfully involve and consult with persons with disabilities and their representative organisations in designing, implementing and evaluating the EU Talent Pool, including the European employment services (EURES).
Read full responseEuropean Disability Forum urges rights-based EU mental health approach
14 Feb 2023
Topic — The EU initiative explores policy responses to mental health challenges across member states.
Message — The EC should ensure mental health services are accessible and based on informed consent. They must prohibit forced treatment and placement in psychiatry while promoting a person-centred approach.12
Why — This would protect the human rights and physical integrity of people with disabilities.3
Impact — Medical facilities currently using involuntary placement would face strict prohibitions on their practices.4
Response to Vaccine-Preventable Cancers
6 Feb 2023
The European Disability Forum (EDF) welcomes the European Commissions consultation on cancer prevention and initiatives to promote vaccination against cancer-causing viruses. We also welcome the Council Recommendation on cancer screening proposed by the Commission and adopted in December 2022. In 2022, our organisation underlined recent studies which show the higher risk faced by persons with disabilities to develop cancer, to receive a late diagnostic and treatment, and to die from cancer- compared to persons without disabilities (position paper attached). We also highlighted that the EU and all its Member States have the obligation to ensure adequate and equal access to healthcare services by persons with disabilities, under article 25 of the UN Convention on the Rights of Persons with Disabilities (CRPD). In order to combat cancer, the European Union must ensure that all people living in Member States have equal access to prevention measures, including vaccination against cancer-causing viruses, such as the vaccination against Human papillomaviruses (HPV) and Hepatitis B virus (HBV). EDF calls on the EU and Member States to: Introduce accessible vaccination campaigns and programmes, including accessible communication on vaccination against cancer-causing viruses: Vaccination campaigns and programmes must include persons with disabilities in all their diversity as a target group. Information about vaccination must be disseminated in a variety of accessible formats, including sign language, Braille and Easy to Read, and the roll-out of the vaccination campaign must ensure accessibility and reasonable accommodation. Include specific outreach to girls and women with disabilities: Girls and young women with disabilities should be particularly targeted in vaccination campaign against the HPV to eliminate cervical cancer and other cancer caused by those viruses. This is essential, as several studies have proven that women with disabilities are under-screened for cervical cancer and breast cancer, comparing to women without disabilities. Vaccination is an important prevention measure for girls and women with disabilities. Promote and support the training of healthcare professionals and people working with persons with disabilities, including people in institutions, to ensure efficient roll-out of vaccination programmes and respect for the rights of persons with disabilities. Ensure policies and guidelines on vaccination guarantee the free and informed consent of all persons: for example, adults under substituted decision-making regimes such as guardianship, should have access to vaccination but not be forced to accept vaccination, or vaccinated against their will through the consent of their legal guardian. Coercion is a violation of fundamental rights, as protected by the CRPD. Consult representative organisations of persons with disabilities in the development, implementation and monitoring of vaccination campaigns. We call on the European Commission to include those elements in its proposal for a Council Recommendation on vaccine-preventable cancers.
Read full response27 Jan 2023
Please find attached EDF's feedback.
Read full responseResponse to European Disability Card
15 Dec 2022
EDF welcomes the opening of the procedure to establish a European Disability Card. This idea emerged from the disability movement and has been a high priority ever since our Freedom of Movement campaign in 2011. The pilot project showed its feasibility and the opportunities it can bring. We call for a Disability Card that allows for mutual recognition of disability status across EU countries and is accepted by all services offering preferential conditions or adaptations to persons with disabilities, whether provided by public or private entities. This means that the legislation should not set a limited list of sectors, but to apply to all services of the EU single market. When it comes to the exemption of public social policies outlined by the Commission, EDF believes that the EU Disability Card should provide the possibility of granting such services on a temporary basis when the person with a disability has moved to the Member State to study or to work, while the person with a disability gets their disability re-assessed and certified. This will mean that persons with disabilities moving to another EU country because of a job contract or to study (e.g. Erasmus+ programme) will have the possibility to access support for reasonable accommodation, access to adapted housing, personal assistance schemes, etc. All this will facilitate travelling in the EU for persons with disabilities, will create awareness among service providers about (the lack of) accessibility and improve access in the long run, and, at the same time, benefit them by increasing visitors numbers. The Card will strengthen the collaboration between national authorities and government agencies and raise awareness of disability issues nationally. Also, it will give certain persons with (invisible) disabilities a tool to enable access to services and goods without having to explain their disabilities and will provide persons with disabilities from Member States without a national Disability Card a document they can use also at national level. We also encourage the Commission to improve the legal framework for the EU Parking Card. EDF believes the format, characteristics and the issuing procedure should be harmonised, in a form which is binding for Member States and clearly communicated to Card users. Also, the controls on fraudulent use of the Card and illegal use of disabled parking spaces should be strengthen. It seems problematic that the Commission still considers as a possibility to merge the EU Disability Card and the EU Parking Card into a single card. EDF thinks this is not feasible as whereas the Parking Card needs to remain in the car, the person may need to present the Disability Card to enter the venue. Additionally, the Disability Card should be: Based on binding legislation, being a Regulation a more appropriate instrument to avoid differences in implementation at national level. An accessible card with standardised size and digital capabilities. Include an EU-level website, available in all EU languages that provides practical details for every country (where to get the Card, how it works and a database of benefits). It must be ensured that the use of the European Disability Card is voluntary. It has to be codified in the law that each person with a disability can decide themselves if they want to apply for the Card and it should never be an obligation to hold such a Card to prove ones disability. Besides the format and content of the Card, the Commission should consider: The EU should set up dedicated funding to support setting up the Card, the website and to guarantee continuing operational needs. A wide, accessible awareness-raising campaign in all EU countries to inform about the Card, aimed at 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, throughout its development.
Read full responseResponse to 2023 EU Justice Scoreboard
13 Dec 2022
The European Disability Forum (EDF), umbrella organisation defending the rights of over 100 million of persons with disabilities in the European Union, welcomes the call for evidence on the EU Justice Scoreboard 2023. EDF commends the inclusion of data on the arrangements in place to support persons with disabilities in accessing justice on an equal basis with other in the 2022 Justice Scoreboard. This data is essential to assess the efficiency and fairness of justice systems in the EU, but also to evaluate the implementation of the United Nations Convention on the Rights of Persons with Disabilities, to which the EU and all Member States are parties. The EU and all its Member States have the obligation to ensure equal access to justice of persons with disabilities (article 13 CRPD) through ensuring equality and non-discrimination (article 5 CRPD), accessibility (article 9 CRPD), including of communication and information (article 21 CRPD) and equal recognition before the law (article 12). They also have the obligation to collect data disaggregated by disability (article 31) to identify and address the barriers faced by persons with disabilities in exercising their rights. In the past EDF had been calling for CRPD indicators, which to some extend have been covered in the 2022 Scoreboard indicators related to "Specific arrangements for access to justice of persons with disabilities", covering: - Adjusted ADR procedures - Court survey on needs and satisfaction of persons with disabilities - Persons with disabilities can be listened to in person and express their will - Procedural accommodations - Accessible digital solutions at first instance courts - Braille/Sign Language/Easy to Read and other specific formats available upon request - Information in accessible formats (e.g. digital and paper) EDF recommends to include those indicators in the 2023 Justice Scoreboard, and strengthening the assessment by adding indicators on: - Physical accessibility of the justice system - Training for all legal practitioners on the rights of persons with disabilities based on the CRPD
Read full responseMeeting with Jutta Urpilainen (Commissioner) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and
1 Dec 2022 · Speech at the 2nd GAP III Structured Dialogue with CSOs
Meeting with Helena Dalli (Commissioner) and
24 Nov 2022 · Disability rights including the situation of persons with disabilities in Ukraine, independent living and deinstitutionalisation, the upcoming European Disability Card initiative, passengers rights and the Equal Treatment Directive proposal.
Meeting with Laurence Farreng (Member of the European Parliament) and European Youth Forum
9 Nov 2022 · Rémunération des stages en Europe
Meeting with Frances Fitzgerald (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and
27 Oct 2022 · Proposal for a Directive on combatting violence against women and domestic violence
Response to Interim evaluation of EU Youth Strategy 2019-2027
21 Oct 2022
The European Disability Forum (EDF) is the organisation of persons with disabilities. It represents over 1000 million persons with disabilities in Europe. Since its beginning the organisation have a Youth Committee that brings the youth perspective in EDF work.
Young people with disabilities are subject to inter-sectional discrimination; on one hand because of disability and on the other hand because of their age. In 2022 we still do not know how many young people with disabilities are in the European Union.
One of the main objectives of this strategy is to encourage and foster youth participation. Yet in the strategy text disability is mentioned once in the preamble indicating that attention should be paid to this group, however there is no other indication in the text how this is to be fulfilled.
Young people with disabilities were very little involved in the actions the EU took. In the Conference on the Future of Europe 1 third of the places in the panel were dedicated to young people, not one of those were given to a person representing the disability movement. Out of the 9 dialogs held with Commissioners within the European Year of Youth EDF youth Committee was invited to two of them and at the third, the chair of the committee requested to be invited. The dialog held by the Commissioner in charge of youth, there was no representative of EDF Youth and thee EDF Youth Committee is also not in the Youth Dialog. These are just a few example how young people with disabilities are left behind.
EDF did not spare its effort to ensure that the EU decision makers do not forget young people with disability and this year EDF was part of the Stakeholder group on the European Year of Youth, and the Youth programmes thanks to our work became also more inclusive. However this is not enough, the Youth Strategy must become more inclusive as the EU has adopted and ratified the UN Convention on the Rights of Persons with Disabilities.
Young People with disabilities are part of this society. They want to be real participants in building a Europe where everyone is included. The Youth Strategy should reflect this in its measures.
Read full responseMeeting with Petra Kammerevert (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and
12 Oct 2022 · Implementierung AVMD
Response to Developing social economy framework conditions
29 Sept 2022
Social economy is a key sector for the social and labour inclusion of persons with disabilities, assisting in the transition towards the open labour market, as the Social Economy Action Plan identifies. When these enterprises reinvest their profits into social causes, the added value is doubled. Therefore, the structuration of a new legal framework for the sector must reflect this potential through a series of considerations:
- The framework must cover and promote the role and value of Social Economy enterprises, with a particular focus on those that reinvest their revenues into social causes, in generating inclusive employment for persons with disabilities. This promotion is carried out through many relevant policies, such as State Aid and the GBER, public procurement, Structural Funds and Recovery Programmes within Next Generation EU, amongst others.
- The clarification of the concept of social economy through the framework – considering every national definition covering each particular model at Member State level - must recognise this value in providing employment opportunities, addressing the responsibility of social enterprises to focus on training and skilling their employees with disabilities to facilitate career progression and a transition into the open labour market.
- Particular efforts must be made to ensure that training programmes are made accessible for persons with disabilities, and that workers are free from discrimination when it comes to promotions and pay-scale progression.
- It will also be crucial for the framework to address the need for persons with disabilities working for social enterprises to have a guaranteed legal status of “employee”, and to thus be entitled to all the rights attached to this status in their Member State. This means a guarantee of minimum wage in countries where this exists, or a wage equivalent to that generally received in their sector of work in countries without laws on minimum wage, as referred by the recently approved Minimum Wage Directive (recital 15). It also means entitlement to paid annual leave, sick leave, educational leave, unemployment benefits and all other social protection mechanisms, as well as the right to exercise trade union rights, again in line with the national norm. This legal status consideration is a mandatory step towards fulfilling Article 27 of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) at EU and national levels, which is binding law both for the European institutions and Member States, as detailed in the General comment No. 8 (2022) on the right of persons with disabilities to work and employment,
- The Social Economy framework must considerate the importance of persons with disabilities not only as employees in social enterprises, but also as entrepreneurs who want to create their own business or start-up. This involves future regulation and funding opportunities incentivising self-employment and entrepreneurship among persons with disabilities by facilitating access to capital, simplifying procedures to set-up and register a business, and facilitating access to information in accessible formats for business owners.
- The framework should also integrate the legislative acquis, programmes and further actions related to furthering the quality employment of women with disabilities. Statistically, women with disabilities are significantly less likely to be employed and more likely to be in underpaid, low-quality jobs with poor working conditions. It should also seek to combat harassment, including sexual harassment, faced by women with disabilities working in social enterprises, in line with the discussion paper adopted by UN Women in 2020 and the Joint statement by UN Women, the Committee on the Elimination of Discrimination against Women and the Committee on the Rights of Persons with Disabilities on ending sexual harassment against women and girls with disabilities.
Read full responseResponse to EU strategic Framework for Global Health
19 Sept 2022
We welcome the revision of the EU strategy on global health as an important opportunity to ensure that the new strategy and any related actions are aligned with CRPD obligations as well as with global commitment to leave no one behind in the implementation of the 2030 Agenda, the related SDGs, the commitments the EU made at the Global Disability Summit and the World Health Assembly Resolution on the highest attainable standard of health for persons with disabilities. We call on the EU to
• Fully integrate disability inclusion within strategies aimed at the achievement of the health-related SDGs, and in particular UHC
• Strengthen inclusive health systems that provide access to general health care and specialised services and programmes related to disability-specific health requirements, across the spectrum of care and throughout the life course
• Review legal frameworks to promote inclusive health
• Mobilise resources to guarantee the right to enjoy the highest attainable standard of health for persons with disabilities
• Build capacities on disability inclusive health in the health workforce and in service delivery
• Address multiple and intersecting discrimination in the health sector
• Incorporate a mental health approach in line with the principles of the CRPD
• Ensure that it makes health equity and the inclusion of persons with disabilities an integral part of health emergency preparedness and response
• Ensure meaningful participation in Disaster Risk Reduction preparedness and planning, inclusive response to health emergencies, accessible information and capacity-building on the emergent field of One Health, and accessible climate resilient and environmentally sustainable health care facilities
• Create One Health interventions and solutions (both nature-based and technology innovation) which are inclusive and supporting environments for all
• Engage civil society, in particular organisations of persons with disabilities (OPDs), in health-related policy design, planning, implementation, monitoring and evaluation
• Ensure that all EU delegations are inclusive of and accessible to all persons with disabilities and include civil society and in particular OPDs in its dialogues with governments of partner countries.
• Train staff of the EU delegations on disability issues, the CRPD and the needs of persons with disabilities, including women and girls with disabilities, in the areas of international cooperation, emergency response and humanitarian aid.
• Ensure that across all sectors, all EU funded actions, external investments and donor-funded actions uphold the principles of accessibility, dignity, and the inclusion in the community of the most marginalised groups, including persons with disabilities. No funds should be invested externally in creating or exacerbating barriers or segregation of institutionalisation for persons with disabilities
• Optimise the use of data on disability inclusion to inform health policies and investments
• Implement the OECD DAC disability policy marker to track development finance in support of persons with disabilities, including for health finance and investments.
• Champion the rights of persons with disabilities in its multilateral, bilateral and regional cooperation and partnerships, and to ensure better coordination and joint approaches to act on commitments already made at the global and regional levels.
• Actively engage in the Global Action on Disability (GLAD) Network, including its working group on inclusive health, which provides a platform to exchange good practices on how to ensure better disability inclusion in the health sector and in health emergencies. And in addition to encourage its Member States to actively engage in GLAD.
• Through effective international partnerships with GAVI and the WHO for instance, ensure equitable access to testing, treatment and vaccination for persons with disabilities in countries with less robust healthcare systems and economies.
Read full responseResponse to Enabling factors for digital education
14 Sept 2022
During the COVID 19 pandemic, accessible online learning was not available to all learners with disabilities. Accessibility was limited due inaccessible online learning platforms, the inability to provide one-to-one support remotely, and lack of knowledge by teachers of how to make digital learning materials accessible (even if the platform itself is accessible). There was an absence of support for learners and families to help them with the use of platforms.
As digital education looks set to remain a permanent fixture in our societies, we would stress the need for the EU and the Member States to focus on the following things when establishing how to ensure everyone has access to digital education:
-Promote digital accessible learning environments with adapted materials for learners with disabilities and ensure inclusive, accessible and non-(gender) stereotyped learning environment/process for all learners, including learners with disabilities.
-Educational institutions should follow the European Standard EN 17161:2019 ‘Design for All - Accessibility following a Design for All approach in products, goods and services - Extending the range of users’. Schools should also ensure that the digital tools and platforms they use follow the accessibility requirements for ICT products and services of European Standard EN301 549 v. 3.1.1 and Web Content Accessibility Guidelines (WCAG) 2.1.
-Provide alternative and accessible education materials and ensure reasonable accommodations based on individual needs of learners with disabilities. Reasonable accommodation could constitute, for example, setting up the assistive technologies the learner may need at home (e.g. screen magnifiers), providing person-centred support (e.g. personal assistance or sign language interpretation), or adjusted learning and evaluation processes (e.g. extra time for exams or assessment by observation or portfolio of learning);
-Invest in increasing the digital skills of learners with disabilities, including specific actions related to increasing their knowledge of digital accessibility features and how to make use of them;
-Train teachers and teaching assistants in how to create accessible digital content for learners with disabilities;
-Increase the competences of ICT professionals in accessibility for persons with disabilities and invest in training future professionals to become specialised technical support and accessibility for persons with disabilities;
-Gather data on access to digital education for leaners with disabilities. Disaggregate all data by age, gender and type of disability. Collect specific data sets to assess the level of access to digital learning for learners with disabilities and the specific barriers they face;
-Promote inclusive and accessible communication platforms between teachers and parents, to ensure that parents with disabilities have equal access to parent-teacher digital communication in a timely manner.
Read full responseResponse to Improving the provision of digital skills in education and training
14 Sept 2022
Improving Digital skills is not only about ensuring as many people as possible are digitally literate, but also making sure that the digital content people create is accessible to all. What the EU needs to invest in drastically, including within the digital work of the EU institutions themselves, is to facilitate and promote knowledge of how to make digital content accessible to and useable for persons with disabilities. This is to say, there needs to be a focus on training the many workers within the EU creating web content to conform to provisions of the Web Accessibility Directive (Directive (EU) 2016/2102). Likewise, attention must be paid to ensuring the transposition of the Directive (EU) 2019/882 on the accessibility requirements for products and services, by training those in the EU who work on developing products and services covered by the scope of the Directive.
The creation of digital content that is accessible for persons with disabilities (for example but not exclusively, that is compatible with screen readers, that contains alt-text for blind and partially sighted users, that has sufficient visual contrast for partially sighted people, etc.) should not be limited only to specialists. Education on how to make digital content accessible for all, particularly persons with disabilities, should be mainstreamed into the education all learners receive when gaining digital skills. It should be a fundamental part of their education, learning how to make their digital content useable by all.
Of course, as EDF has been advocating for a long time now, this EU initiative should also focus on bridging the digital gap by facilitating education and training on digital skills for groups most likely to be excluded, which includes persons with disabilities, among which women, girls and older people with disabilities are particularly affected. We would like to see outreach schemes and funding going towards building up the confidence of more persons with disabilities in their abilities to use digital technology at work, in education and in their personal lives. In an increasingly digitalised society, digital competencies are essential to avoid social exclusion and isolation.
Read full responseMeeting with Lesia Radelicki (Cabinet of Commissioner Helena Dalli)
13 Sept 2022 · Meeting on Directive Violence Against Women
Response to Improving access to emergency services through the single European emergency number ‘112’
12 Sept 2022
Please find the feedback of the European Disability Forum (EDF) attached.
EDF welcomes the publication of this draft Delegated Regulation and shares the objectives of the Commission as for the provisions concerning equivalent access for end-users with disabilities to the single European emergency number 112. We particularly appreciate provisions related to ensuring emergency communication for end-users with disabilities without pre-registration, free of charge and benefiting from the transmission of caller location. Overall we support the aim of upgrading to packet-switched technologies as these will enable the deployment of real-time text and total conversation services (i.e. voice, real-time text and video simultaneously).
However, we are concerned as for the Commission approach in some of the elements of this delegated act, as well as some wording of its provisions, notably:
1. The draft regulation lacks a clearer link with the European Accessibility Act and even states that there is no common understanding of how to ensure functional equivalence. The EAA does include functional accessibility requirements by which this functional equivalence can be ensured.
2. The Commission is not clear whether mobile apps will be complementary or the way forward for Member States to ensure accessible emergency communication for persons with disabilities when travelling across the EU. EDF believes mobile apps should be an interim solution until the EAA provisions as for 112 emergency communication are implemented. We do not want special apps only for us as final solution.
3. If such mobile apps as interim solution are deployed, they should be legally required to be pre-installed/built-in in the headsets to avoid persons with disabilities having to download and install them (contradicting the non pre-notification provision).
4. The Commission gives discretion to Member States to upgrade to packet-switched technologies either by the core network or by mobile apps, which risks preventing interoperability.
5. The provision on article 4(f) is also unclear and needs further explanation.
6. The required roadmap to be submitted by Member States should include voice, real-time text (not just "text") and (not "or") video. And more importantly it should take into account the deadline established by the EAA (28 June 2027), when the functional accessibility requirements for handling emergency communication will apply to the designated PSAPs.
Further information and explanations on EDF's feedback can be found in the document attached.
Read full responseResponse to Erasmus+ 2021-2027 interim evaluation and Erasmus+ 2014-2020 final evaluation
11 Sept 2022
The European Disability Forum represents more then 100 million persons with disabilities. As organisation we have and currently participate in Erasmus+ Project, but the feedback comes also from our members. We have not conducted any structure research, however, what our members and ourselves experienced when it comes to the programme are the following:
Accessibility: improvements have been done on the Commissions website and an easy to read leaflet has been published, however still not all fims are accessible and many issues arises when it comes to the accessibility of the annexes organisations need to provide, the excell sheets are not inaccessible only but also problematic for persons without disability to use them.
Visibility of inclusion mechanisms for persons with disabilities: There are many measures put in place to support inclusion of persons with fewer opportunities within the Erasmus+ Programme. These measures are still not known by the beneficiaries not doing projects with disadvantaged groups and we receive complaints from young people who were not able to participate in projects because the costs linked to their disabilities were not covered such as: the possibility to take a personal assistant, ann accessibility service, an inaccessible location to name only a few of them. To avoid such discriminatory happenings the possibility to request these costs after a project was submitted and approved could be a solution, or including in the form above the budget a few words indicating that organisations can request for budget to cover costs to support the inclusion of persons with fewer opportunities may decrease the burden upon participants with disabilities or organisations and facilitate the participation with accessibility requirements.
Lack of data on participants with disabilities: The umbrella term to nominate person subject to a discrimination people with fewer opportunities does not meet the requirements of the Convention on the Rights of Persons with Disabilities in providing disagregated data on disability. However the application process requires information about participants and beneficiaries must indicate when persons with disabilities participate. This information does not allow disagregated data on disability type and how inclusion is put in place. More indicators in the evaluation process would be helpful to fill in this lack. Indicators such as: Did you offer accessibility services? Which ones, Did you display on your disemination of your activities that they are open for persons with disabilities? The National agencies should also use the information the gather on participans with disabilities and publish their data also on their channels to give more visibility.
Online activities: Blended mobilities and the pandemic situation brought us to choosing for remote activities and online events. Unfortunately the online activities are not budgeted adequately, the preparation time and organisation of an online or remote activity is not financially more advantageous to diminish the budget for this. Travel costs are nonexistent, but these activities need a more thorough preparation, thus more time, accessibility services such as speach to text sign language interpretation, sometimes personal support are needed to allow an equal and meaningful participation of persons with disabilities. Covering the licenses integrally or partly of conferencing systems is necessary an upgraded version when participants with disabilities are present is necessary as simple accounts may not give access to all features of the programmes that facilitates an accessible participation.
Person with disabilities in the pool of evaluators: National Agencies should include persons with fewer opportunities, thus with disabilities too in their evaluator pools as these ones are best to evaluate whether an application is indeed meeting the inclusion ccriteria set up by the programme, thus becoming inclusive inside and outside.
Read full responseResponse to Income and living conditions domain for the six-yearly variables on Access to services
1 Sept 2022
Persons with disabilities, a group to which approximately 100 million people in the EU belong, are among the biggest users of public services.
Persons with disabilities are also regularly confronted with public services that are inaccessible to them, unaffordable or poorly adapted to their needs. It is therefore essential that disability be clearly and explicitly included in the six-yearly variables on access to services in the income and living conditions domain. In the current proposals, disability is entirely absent. We would therefore urge the following amendments to be considered.
For proposed variable HC190, we would suggest rewording the title to instead read “Presence in the household of people who need support due to disability, because of old age or because of long-term physical or mental ill-health”.
For variable PC30 we would suggest the title “entitlement to disability allowance or benefits for health issues”
For variables PC330, PC340, PC350 and PC360 on discrimination, it is important not only to talk of “feeling discriminated against” but also being “unable to access” the services listed in these four variables.
For variable HC300 we would recommend that the title includes the issue of costs caused by the inaccessibility of public transport for many persons with disabilities, and thus be named “financial burden of public transport or costs incurred due to not being able to access public transport”.
For the variables that refer to “homecare” it would be important to refer to “home care services and personal assistance for independent living” which can therefore refer to services that support people in their activities outside of the place of residence. Many persons with disabilities use such services in their daily lives.
For the EU SILC data to be truly revealing, it will be essential for the respondents to whom these variables apply to be able to be identified on the basis of gender. We also notice an absence of variables that explore people’s ability to access services for family planning and sexual health. This would be a very important topic to have reflected in the EU SILC statistics, being one that particularly affects persons with disabilities, particularly women and girls with disabilities.
In more general terms, we must stress the need for data from EU SILC to take into account the realities of people not only living in households, but also living in residential care settings and confined to institutions. This will be crucial for the EU to understand the number of people living in such settings and the reality of their quality of life.
Read full responseMeeting with Alex Agius Saliba (Member of the European Parliament)
12 Jul 2022 · Towards Equal Rights for Persons with disabilities in the EU
Response to Prevention of harmful practices against women and girls
27 May 2022
The European Disability Forum (EDF) welcomes the initiatives of the European Commission to address harmful practices against women and girls.
The disability movement is very concerned by harmful practices taking place in the EU, including against persons with disabilities. Women and girls with disabilities are particularly at risk and victims of forced sterilisation, forced abortion and forced contraception in EU Member States (MS). According to research conducted by our organisation, 18 MS still legally authorise forced sterilisation of persons with disabilities against their consent. More information is available in the report attached.
Although data are rarely available, statistics and information available show that forced sterilisation, abortion and contraception still happen. For example:
• In Germany, in 2017, 17% of all women with disabilities aged 15 to 65 had been sterilised, comparing to 2% of the women nationwide. In 2016, out of 31 requests for approval of sterilisation filed by a legal guardian, 23 were approved.
• In Italy, a woman with psychosocial disabilities reported having been victims of forced abortion ordered by a court, with the consent of her guardian in 2019 (Yaka case).
• In the Netherlands the Mandatory Mental Health Act introduced in 2020 allows for forced contraception of women with disabilities. By October 2021, Dutch courts forced at least six women with psychosocial disabilities to take contraception.
In some cases, women and girls are sterilised and given contraceptives without their knowledge or consent, while in others, while they and/or their families are pressured to give consent (for example as a requirement to be institutionalised, as they are not supported to live in the community). In all cases, this should be considered as forced and harmful measures. Forced abortion may also be coerced based on real or accurate foetal impairment.
While coercion is often linked to substituted decision-making (e.g. guardianship), it is important to note that women and girls with all types of disability may be victims, based on ableist, patriarchal and eugenics views.
In addition, women and girls with disabilities may be victims to any types of harmful practices including forced marriage and female genital mutilation. Restriction to access to safe abortion and contraception, as well as sterilisation based on the autonomy and choice of the person should also be considered as harmful practices.
EDF calls on the European Commission to ensure the protection of the rights enshrined in the UN Convention on the Rights of Persons with Disabilities ratified by the EU and all MS.
The EU and its MS should:
• Swiftly ratify and implement the Istanbul Convention
• Add gender-based violence to the list of EU crimes
• Criminalise forced sterilisation and abortion at EU level
• Ensuring that harmful practices against women and girls with disabilities is addressed within relevant EU policies and strategies (education, humanitarian aid, etc.).
• Collect data and conducting research on the root causes, prevalence, consequences and costs of harmful practices.
• Finance and promote training and capacity building of professionals in EU Member States, such as support service providers, healthcare and criminal justice professionals (including providers of services for victims’, doctors, midwives, police officers, judges). All professionals should be trained on harmful practices and the rights and needed of women and girls with disabilities, in particular those working them, including those living in institutions.
• Finance and promote emotional and sexuality education in EU Member States, including through project funding. This should be offered to young people with disabilities living in and outside institutions, and include information on respect to others and capacity of saying no, involving organisations of women with disabilities and women’s groups.
Read full responseEDF Urges EU to Criminalise Forced Sterilisation of Disabled Women
6 May 2022
Message — The EDF requests the criminalisation of forced sterilisation and disability-disaggregated data collection. They also demand professional training and protections for women under legal guardianship.12
Why — These measures would provide specific legal safety for women facing heightened risks of abuse.3
Impact — Perpetrators serving as legal guardians would lose their authority to control their victims.4
Response to Recommendation of the Commission on detention
22 Apr 2022
Detainees with disabilities continue to face many violations of their rights in EU Member States.
In 2017 the European Parliament adopted a resolution on prison systems and conditions. The resolution recognised the failure of EU Member States to protect the rights of prisoners with disabilities.
Violations of fundamental rights are also described in a report of the Council of Europe on Detainees with disabilities in Europe published in 2018. They range from the non-recognition of their disability, difficult living conditions in unsuitable cells, to lack of access to treatment, failure to provide assistance and support and even ill-treatment and torture. There is also a disproportionate number of persons on the autism spectrum and persons with intellectual and psychosocial disabilities in prison. For example, in France, “nearly a quarter of detainees are said to have ‘psychotic disorders’”.
EU rules on detention and pre-trial detention are important to ensure harmonisation of detention rules and respect of fundamental rights across the EU Member States.
The European Disability Forum welcomes the adoption of EU recommendations on pre-trial detention.
We call on the European Commission ensure the protection of the rights enshrined in the UN Convention on the Rights of Persons with Disabilities ratified by the EU and all its Member States.
In particular the EU recommendations on pre-trial detention should:
• Refer to the implementation of, and compliance with the UN Convention on the Rights of Persons with Disabilities (CRPD) and the Council of Europe’s Parliamentary Assembly resolution 2223(2018) on detainees with disabilities
• Ensure that EU Member States adequately assess and identify all types of disability of detainees and ensure and respect all the fundamental rights of detainees with disabilities, including the provision of:
o Assistance and accessible communication and information, such as information in accessible formats (e.g. Easy to Read format, sign language interpretation, etc.), for example in relation to the detention policies and the detainees’ rights.
o Accessibility, reasonable accommodation and procedural accommodation before, during and after pre-trial detention. For example when a person with disabilities is placed in detention, Member States should ensure that the choice of facility is based on the ability of the facility to meet the person’s needs in terms of accessibility and reasonable accommodation.
o Access to healthcare, including sexual and reproductive health as well as mental healthcare
o Sufficient range of activities suited to the needs of detainees with disabilities
• Require the collection of data on persons in pre-trial detention in EU Member States disaggregated by disability, gender and other relevant criteria to provide a clear picture of the number and circumstances of detainees with disabilities in all their diversity
• Require the establishment of a monitoring mechanism that would include regular visits of places of detention, by one or several independent bodies such as National Human Rights Institutions, and immediate investigation and remedies in cases of violence and ill-treatment, including against detainees with disabilities
• Require Member States to provide training on disability and the CRPD for judicial and prison staff and to include awareness of disability and multiple and intersectional discrimination in recruitment criteria
• Demand that Member States involve civil society, including representative organisations of persons with disabilities, in the development of detention rules and guidelines and in their monitoring
Read full responseResponse to Amendment to the Regulation (EU) No 1025/2012 European standardisation
6 Apr 2022
The European Disability Forum (EDF) welcomes the European Commission’s proposal to amend Regulation (EU) 1025/2012 on European Standardisation as a first step towards ensuring a transparent European standardisation system with improved governance and empowered European rights-holders.
However, as we demonstrate in the attached paper, we do not believe this amendment is enough to ensure that the European standardisation system is fit for supporting EU policies, nor that it is inclusive for persons with disabilities and their representative organisations. We support our arguments and recommendations with two examples illustrating some of the issues present in European standardisation (see Annex I in the attached paper).
Therefore, we call on the Commission to build on this positive development and launch a comprehensive revision of the Regulation to address the many challenges in relation to a truly representative, fair, and inclusive European standardisation system.
Please refer to the attached document for EDF's comprehensive feedback.
Read full responseMeeting with Helena Dalli (Commissioner) and Amnesty International Limited and
6 Apr 2022 · Cabinet Dalli invited Civil Society Organisations (CSOs) to discuss concerns equality and non-discrimination CSOs are raising regarding the situation of people fleeing from the Ukraine
Response to Civil aspects of the cross-border protection of vulnerable adults
29 Mar 2022
The European Disability Forum (EDF) recognises the importance of adoption and application of conflict of laws treaties as a means to provide legal certainty, avoid gaps and promote the uniform application of substantive international law including in the EU.
However, conflict of laws legislation should not lead to human rights violations of the person impacted by the measures at stake.
EDF is particularly concerned that the promotion of the ratification of the 2000 Hague Convention in its current form risks to contribute to the fragmentation of international law, especially in light of the wide ratification of the UN Convention on the Rights of Persons with Disabilities (CRPD). Its implementation could lead to direct violations of the CRPD by EU Member States.
EDF recommends that:
• The EU does not promote the ratification of the 2000 Hague Convention which in its current form reflects an out-dated and currently non-human rights compliant understanding of “protection” which has been clearly superseded by the CRPD.
• The EU develop measures to facilitate the abolition of substituted decision-making in all EU Member States, as well as to accelerate desinstitutionalisation, end coercive treatment and placement, and develop supported decision-making practices.
• The EU issues guidelines for EU Member States on cross-border protection on “vulnerable adults” based on the CRPD.
• Measures adopted to deal with conflicts of law and cross-border protection of “vulnerable adults” are based on the promotion of and compliance with the CRPD. States should prevent the application of legislation by another State in the context of cross-border issues and private international law when it does not comply with international human rights law, including the CRPD.
• The EU and its Member States systematically consult and involve representative organisations of persons with disabilities in all discussions related to the “protection of vulnerable adults” and measures that may impact the rights and lives of persons with disabilities in Europe and beyond.
You can find more information in our position paper attached that also describes the variety of legal capacity regimes existing across EU Member States.
Read full responseResponse to Recommendation on minimum income
25 Mar 2022
Numerous studies have shown that the cost of living for persons with disabilities, just to make ends meet, is far higher than for persons without disabilities. The additional costs of living in an inaccessible society is one of the reasons why an estimated 30 million persons with disabilities live in poverty in the EU. In fact, Eurostat figures suggest that persons with disabilities are around 10 percentage points more likely to be poor than persons without disabilities .
All too often, persons with disabilities have to pay out of their own pocket to make up for a society that remains inaccessible to them. Paying for adapted medical treatment, technical aids, accessible transport and mobility, accessible housing and personal assistance are just some of the reasons so many persons with disabilities are at real risk of not having enough to get by. Studies from all over Europe attest that, even with support in the form of disability payments, it is rarely enough to cover the person’s outgoings .
EU figures also show that persons with disabilities who are employed are more likely that persons without disabilities to face in-work poverty. In the EU 11% of persons with disabilities in employment are still living below the poverty line. Managing to get by on a typical work salary while covering so many disability-related costs is simply not feasible for many persons with disabilities. Any EU action on adequate income must avoid taking a one-size-fits all approach. It must recognise that to lead a secure and dignified life as a person with a disability will require adapted minimum income thresholds.
It must recognise that disability entitlements in the form of cash payments or tax reductions are a necessary means of compensating for the extra barriers and costs faced by persons with disabilities. They should therefore be entirely compatible with other forms of income such as paid work or inheritance, or the income of a partner or spouse. Persons with disabilities should be entitled to improve their economic situation through employment and inheritance in the same way as anyone else, without losing entitlements foreseen specifically to support with disability-related costs. Disability allowance should also be reviewed in line with the cost of living of different Member States and regions to ensure that they adequately off-set the extra cost of living for persons with disability, and sufficiently protect us from falling into poverty.
It is also necessary to ensure that persons with disabilities who exercise their EU right to freedom of movement continue receiving disability entitlements, either from their home Member State, their new Member State of residence, or a mixture of both. This will also require mutual recognition of disability assessment between Member States.
What will be deemed adequate income for a person without a disability will almost certainly fall far short of what is needed to prevent a person with a disability from falling below the poverty threshold. In its action on minimum wage and minimum income, we need the Commission to clearly acknowledge the unique situation faced by most persons with disabilities. Anything that overlooks this will fail in its attempt to reduce poverty levels among those most at risk.
You can see EDF's full report on poverty of persons with disabilities at: https://www.edf-feph.org/publications/european-human-rights-report/
Read full responseResponse to Proposal for a Council Recommendation on long-term care
25 Mar 2022
Countless persons with disabilities in the EU find themselves reliant on long-term care. Indeed, with an estimated 100 million persons with disabilities in the EU, support services for persons with disabilities should be part and parcel of the EU Care Strategy.
When it comes to catering this to the requirements of persons with disabilities, there are a number of key elements that must be taken into account. Firstly, in line with Article 19 of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD), and its General Comment number 5, persons with disabilities have the right to live and be fully included in the community, with choices equal to others. For persons with disabilities therefore, care or support services must ensure a number of things. Firstly, when it comes to assisted-living services, it is crucial that persons with disabilities be able to freely choose their place or residence, where and with whom they want to live, and not be obliged to live in any particular living arrangement. The EU Care Strategy must therefore focus its efforts on how to ensure an availability of in-home and community support services, including personal assistance for persons with disabilities of all ages, including for older people who acquire a disability as they age.
The Strategy should prioritise all types of support that reduce reliance on institutional care settings, and cases where persons with disabilities and families are forced to turn to institutions due to a lack of other, more appropriate support mechanisms. It should also offer support to families, and particularly women, who too often offer informal care to family members with disabilities without support from the State. The Strategy could explore addressing these issues through the diversion of EU funds towards personal assistance and in-home support schemes, which allow people to remain in their own homes should they wish to. It could also take the form of an action plan to more strictly monitor and stop misuse of EU funds that still end up being invested in refurbishing or building institutional settings. It is crucial that the transition away from institutional settings be taken seriously.
In order to ensure that personal assistance, in-home support and community-based services are available to offer people more choice in the kind of support they might want or need, and to enable EU Member States to make a transition from institutional to community-based care, the Strategy must also look at attracting, training and retaining carers. As well as making the profession an attractive one in terms of salary and working conditions, it is also in the interest of carers and the people they serve that quality training be given on how to offer support in a way that fits around the wants and needs of each service user. This should include training to make all service providers and assistants familiar with the UN CRPD and its General Comments, and what this means for how persons with disabilities should be supported and empowered.
Read full responseResponse to Cancer Screening Recommendation
21 Feb 2022
Recent studies show that persons with disabilities are at a higher risk to develop cancer, to receive a late diagnostic and treatment, and to die from cancer, comparing to persons without disabilities.
The European Disability Forum (EDF) welcomes the Europe’s Beating Cancer Plan and increased inclusion of persons with disabilities in EU health policies. Unfortunately, the mention of persons with disabilities in EU policies does not translate into concrete actions to ensure their equal access to cancer screening and care, and to address the pre-existing inequalities and factors putting them at higher risk of cancer or inadequate care.
The text of the 2003 Council Recommendation on Cancer Screening is vague and does not explain how Member States can ensure greater access to marginalised people and those at higher risk of cancer, including persons with disabilities. For example, there is no requirement on accessibility of the services and no definition of what “high quality cancer screening” means. Since the document was adopted almost two decades ago, it does not take into account the obligations of the EU and its Member States under the CRPD and the rapid digitalisation of European health systems.
The Council Recommendation must be extended beyond breast, colorectal and cervical cancer to include additional cancers, and include provisions on accessibility of the healthcare services, in particular of screening equipment, for persons with disabilities.
More generally, EDF calls on the EU to ensure access to health of persons with disabilities in line with the UN Committee on the Rights of Persons with Disabilities and the EU Strategy for the rights of persons with disabilities, in particular to:
• Collect disaggregated data and statistics on cancer screening and care, including by disability, notably through the Cancer Inequalities Registry.
• Adopt measures to promote and support disability-inclusive health services, including cancer prevention, screening and care.
o The new cancer screening scheme must require the development of services that are available, accessible, affordable, relevant, appropriate, and acceptable to service users with disabilities.
o EU fundings should support the development of disability inclusive cancer services in Member States.
o The European Commission should consider the development of accessibility standards for screening equipment such as that used for mammograms, and treatment processes such as radiotherapy.
• Introduce accessible public health campaigns and communication on cancer measures.
o Communication on cancer prevention, screening and treatment must include persons with disabilities and be disseminated in a variety of accessible formats, including sign language, Braille and Easy to Read.
o Information on cancer prevention and screening shall be available to all persons with disabilities, including those in institutions, in psychiatric hospitals and in prisons.
• Promote and support the training of healthcare professionals and people working with persons with disabilities, including people in institutions and other closed settings such as psychiatric hospitals and prisons.
• Consult representative organisations of persons with disabilities in the development, implementation and monitoring of cancer prevention and care policies.
Read full responseResponse to Emergency measures for Latvia, Lithuania and Poland
3 Feb 2022
The European Disability Forum (EDF) considers that Proposal for a Council Decision does not sufficiently take into account the rights and needs of persons with disabilities and do not fully comply with the UN Convention on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its Member States, including Latvia, Lithuania and Poland.
EDF recommends that:
- The Proposal for a Council Decision specifically refers to the CRPD and the rights of persons with disabilities that must be respected at all times.
- Under Article 2: The Proposal for a Council Decision require the establishment of sufficient number of registration points and the obligation to provide information about those points and ensure they are accessible to asylum seekers with disabilities, and the concerned Member States allow entry to all applicants with disabilities to assess their healthcare needs and applications
- Under Article 3: the Proposal for a Council Decision clarify that the basic needs of persons with disabilities must be ensured and that the temporary modalities must comply with Articles 21 to 25 of Directive 2013/33/EU that set the provisions for “vulnerable persons” including asylum seekers with disabilities.
-Under Article 5(1): the Proposal for a Council Decision require that the information is provided solely in language and format asylum seekers truly understand
- Under Article 9(1): the concerned Member States collect and share data disaggregated by age, gender and disability .
EDF also recalls that detention in the context of migration and asylum seeking is not in line with international human rights law, including with the CRPD.
EDF's detailed recommendations are available attached.
Read full responseResponse to Better protection for passengers and their rights
13 Jan 2022
The European Disability Forum (EDF) welcomes the European Commission’s initiative to gather evidence for the purpose of assessing the impact of the EU passenger rights regulatory framework, particularly related to Regulations on air passenger rights for passengers with reduced mobility (PRM), waterborne and bus & coach passenger rights.
Based on the impact assessment, including the issues identified during the evaluations of the three regulations on the rights of passengers with reduced mobility travelling by air, passengers travelling by waterborne transport, and passengers travelling by bus & coach, the Commission will suggest one of three actions to address existing issues – 1. soft law (inc. recommendations or interpretative guidelines), 2. targeted amendments to the mentioned regulations, or 3. a new legislative instrument addressing horizontal issues.
EDF would like to stress that to improve rights of passengers with disabilities in the three modes of transport, soft law measures would not be sufficient, as there are gaps not only in the implementation of the Regulations (e.g., enforcement issue, issues with interpretation of the legal texts, etc.) but also in the legal protections provided by the Regulations (e.g., ‘safety concerns’ still a way of denying boarding to passengers with disabilities, lack of full compensation for damaged or lost mobility equipment in air travel, etc.). Recommendations and interpretative guidelines are of course useful to support proper implementation of EU law, but the laws themselves have to provide sufficient protection to start with.
We provide examples of issues persons with disabilities face in relation to air, waterborne, and bus & coach travel, with recommendations on how to address existing problems in the attached document.
It is important to point out that data on equal access to relevant transport modes by persons with disabilities is not gathered systematically (e.g. due to absence of reporting obligations for carriers), which makes providing evidence-based policy recommendations more difficult. Lack of data on discrimination against passengers with disabilities therefore should not be interpreted as evidence that passenger rights laws in their current form and implementation provide sufficient protection to persons with disabilities. EDF has tried to fill in the gap in data collection by compiling cases of discrimination and inaccessibility related to travel in all transport modes over the years, and has recently launched an online database to gather evidence on transport discrimination. https://accessibility.edf-feph.org/
Read full responseMeeting with Annelisa Cotone (Cabinet of Commissioner Helena Dalli), Joseph Vella (Cabinet of Commissioner Helena Dalli)
13 Jan 2022 · Exchange on EU disability policies, including the new Disability Platform.
Response to Amendment of the EU rules on victims’ rights
10 Jan 2022
The European Disability Forum (EDF) is concerned that EU Member States do not effectively ensure the rights of victims’ with disabilities enshrined in the Victims’ Rights Directive and the CRPD. The following key issues, have been identified:
• Lack of information about what constitute a crime and how to report, particularly affecting people living in closed settings such as institutions, persons with intellectual disabilities and Deafblind persons
• Difficulties reporting crimes because of physical, communication and attitudinal barriers
• Substituted decision making systems (e.g. guardianship, curatorship) making reporting and access to justice difficult, especially when the legal guardian is the perpetrator of the crime
• Lack of accessible victims’ services to victims with disabilities, including shelters, legal aid and psychological support
• Failure to provide procedural accommodation (e.g. sign language interpretation, documents in Braille) to victims and witnesses with disabilities in the justice system and overall lack of accessibility (e.g. court building not accessible to persons with reduced mobility)
In light of the scope of the call for evidence on Criminal justice – EU rules on victims’ rights and the evaluation of the Victims’ Rights Strategy in which it took part, EDF recommends that the European Commission amend its legislation (policy options 2 and 3) to strengthen the rights of all victims of crimes in the European Union.
In particular the European Commission should:
1. Strengthen its legal basis by referring and aligning with the rights enshrined in the UN Convention on the rights of Persons with Disabilities, the Council of Europe Convention on preventing and combating violence against women and domestic violence (Istanbul Convention) and other key international instruments
2. Ensure that all victims can report crimes, including victims in closed setting such as persons in institutions, as well as migrants and victims in detention (sub-option b – broader scope of the legislative amendment)
3. Include enhanced binding provisions on accessibility of information on victims’ rights, victims’ support services and the justice system for persons with disabilities
4. Strengthen the legal provision on training of practitioners to ensure that they are trained on the rights and needs of victims with disabilities, including all types of disability and paying particular attention to children and women with disabilities
5. Require the collection of disaggregated data on victims by age, gender, disability and other relevant grounds such as ethnicity and religion
6. Require Member States to sanction the violation of victims’ rights and double-victimisation
Read full responseResponse to 2022 EU Justice Scoreboard
20 Dec 2021
The European Disability Forum, umbrella organisation defending the rights of over 100 million of persons with disabilities in the European Union, welcomes the call for evidence on the EU Justice Scoreboard 2022.
EDF agrees that effective justice systems are essential for the implementation of EU law and upholding the rule of law and values upon which the EU is founded, including the values of equality, non-discrimination and respect for human rights (article 2 TFEU).
As Parties to the UN Convention on the Rights of Persons with Disabilities (CRPD), the EU and all its Member States have the obligation to ensure equal access to justice of persons with disabilities (article 13 CRPD) through ensuring equality and non-discrimination (article 5 CRPD), accessibility (article 9 CRPD), including of communication and information (article 21 CRPD) and equal recognition before the law (article 12). They also have the obligation to collect data disaggregated by disability (article 31) to identify and address the barriers faced by persons with disabilities in exercising their rights.
Persons with disabilities living in the EU continue to face major barriers in accessing the justice system. Therefore, they may not have their right to an effective remedy fulfilled in violation with article 47 of the EU Charter of Fundamental Rights, EU directives on access to justice and the CRPD which impact the EU as a whole.
The EU Justice Scoreboard is an important tool to achieve more effective justice, including for persons with disabilities. In 2020 and 2021 the Justice Scoreboard included indicators covering only some persons with disabilities, namely Deaf, hard of hearing, partly sighted and blind people. 3 types of information were gathered by the Scoreboard:
• “Online information for visually or hearing impaired”
• Training in communication for judges on “communication with visually/hearing impaired”
• Survey conducted among court users or legal professional on “needs and satisfaction of visually/hearing impaired”
EDF calls on the European Commission to establish a “CRPD compliant-justice” indicator (similar to the “child-friendly justice” indicator already existing under indicator 3.2.1) covering all types of disabilities.
The CRPD indicator should include information on:
• Availability of information in accessible formats, including digital and paper-based information, such as in Braille, Sign Language and Easy to Read
• Procedural accommodations available for persons with disabilities, including provision of Sign Language interpreters, and other accommodations
• Physical accessibility of the justice system
• Training for all legal practitioners on the rights of persons with disabilities based on the CRPD
• Measures to ensure that persons with disabilities under substituted decision making (such as guardianship) can be listened to in person and express their will and preferences
• How court surveys address, and report on the rights and satisfaction of persons with disabilities, including children with disabilities (e.g. surveys)
Accessibility-related CRPD indicators should be in accordance with EU accessibility laws, and European and international standards (see document attached).
Read full responseResponse to European Year of Youth (2022)
13 Dec 2021
The European Disability Forum (EDF) Youth Committee is calling on the EU institutions to ensure that the events and actions organised within the European Year of Youth are involving young people with disabilities and that the events and actions are organised in an accessible and inclusive way providing real-time captioning, international sign interpretation and accessible materials.
The Youth Committee priority topics are the following:
Independent Living
Inclusive Education
Digital Transformation
EU mobility programmes
Mental Health
Employment of young people with disabilities
Climate change
Read full responseResponse to Social and labour aspects of the climate transition
19 Nov 2021
The European Disability Forum (EDF) fully supports the Commission’s goals under the Green Deal and the objective to achieve climate neutrality. Having said that, persons with disabilities have not sufficiently been considered in the resulting strategies and actions. Even though we believe that accessibility and inclusiveness are part of the key to a sustainable and green Europe, those aspects are unfortunately still seen as two separate issues. See the document attached for the detailed description of the problem and possible solutions.
Read full responseResponse to Improving access to emergency services through the single European emergency number ‘112’
28 Oct 2021
The European Disability Forum (EDF) welcomes the opportunity to give feedback to the roadmap consultation ahead of the publication of the draft delegated act. We also welcome the aims and some of the proposed solutions detailed in the roadmap aiming to ensure fully equivalent access for persons with disabilities to emergency communications.
Equivalent access for persons with disabilities to emergency communications across the Union is still not a reality, especially during roaming. The delegated regulation will support the aim of the the European Electronic Communications Code (EECC) in ensuring effective access to emergency services through emergency communications to the single European emergency number ‘112’. It is important that the aims and solutions in the delegated act are consistent with the harmonised accessibility requirements of the European Accessibility Act for electronic communications services, related products, and answering of emergency communications to the single European emergency number “112” by the most appropriate Public Safety Answering Points (PSAPs). The Act requires that from 28 June 2027 PSAPs in all Member States use the same communication means as received, namely by using synchronised voice and text (including real time text), or, where video is provided, voice, text (including real time text) and video synchronised as total conversation.
Attached you may find our detailed feedback and recommendations.
Read full responseResponse to Contingency plan for transport
28 Sept 2021
The European Disability Forum (EDF) welcomes the European Commission’s initiative to prepare a crisis contingency plan with the objective to coordinate response measures in the transport sector on the basis of lessons learned and initiatives taken since the beginning of the COVID-19 pandemic. Even though the initiative does not foresee a ‘hard’ legislative measure, as it is planned to result in a Communication, it is positive that it plans to “examine whether there is a need to introduce further legislative changes, provide additional guidance or policy recommendations” with the possibility of separate legislative proposals after this exercise.
See our complete feedback attached.
Read full responseResponse to Standardisation Strategy
29 Jul 2021
EDF Welcomes the European Commission’s initiative to “consolidate and improve the EU standardisation system, so that it continues to support a well-functioning single market and the competitiveness of EU industries and protects EU citizens and the environment.” This is an excellent opportunity to improve the European Standardization system, making it more inclusive and ensuring that it serves best interest of all EU citizens, including 100 million persons with disabilities in the EU.
Despite challenges, EDF has contributed to European standardisation for many years, and our efforts have been crucial for the success of European standards in support of accessibility for persons with disabilities (e.g. HEN301549; EN17210; EN 17161).
Please see our feedback to the roadmap consultation attached.
The European Disability Forum
The European Disability Forum is an independent NGO that represents the interests of 100 million Europeans with disabilities. EDF is a unique platform which brings together representative organisation of persons with disabilities from across Europe. EDF is run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.
Read full responseEuropean Disability Forum Calls for Stronger AI Safeguards and Accessibility Requirements
28 Jul 2021
Topic — EU regulation on artificial intelligence transparency, safety, and fundamental rights protection.
Message — The organization requests mandatory accessibility requirements across all AI systems, bans on biometric identification in public spaces, and independent assessments of fundamental rights impacts. They want organizations of persons with disabilities involved in AI development and complaint mechanisms accessible to all.1234
Why — This would protect their members from discriminatory AI systems and ensure accessibility features are built in from the start.56
Response to Policy Program - Digital Decade Compass
16 Jul 2021
The European Disability Forum (EDF) welcomes the European Commission’s planned Digital Compass Policy Programme initative, which seeks to set up a robust governance framework providing structured cooperation between the Commission and the Member States to achieve the EU’s digital targets envisioned in the EC Communication on 2030 Digital Targets. We also welcome the plan to formulate set of digital principles in the form of a joint inter-institutional solemn declaration of the European Commission, the European Parliament and the Council, based on a proposal from the European Commission. We call on the European Institutions to ensure inclusive digital transition, by committing to improving accessibility and digital inclusion persons with disabilities in all areas of public and private life, so that they equally benefit from EU action rather than be left behind due to the digital transformation.
To make sure that the Digital Compass Policy Programme benefits persons with disabilities in the EU, it must:
1. Establish an obligation for the European Commission and Member States to harmonize and mainstream accessibility and interoperability of digital technologies in the EU and ensure digital participation of persons with disabilities in all areas of digital public and private life.
2. Ensure that monitoring and reporting considers accessibility and digital participation of persons with disabilities, namely in the enhanced Digital Economy and Society Index (DESI) and in the European State of the Digital Decade Report – ESDDR.
3. Ensure that all public funding incorporates accessibility as funding criterion and targeted funding is provided to projects aiming to improve accessibility for persons with disabilities.
4. Meaningfully engage organizations of persons with disabilities, accessibility experts in the planned stakeholder forum, and possible expert group for implementation of the Digital Compass.
Please see attached document for more detailed feedback.
Read full responseResponse to Declaration of Digital Principles
9 Jun 2021
The European Disability Forum (EDF) welcomes the planned Communication from the European Commission / Commission Recommendation on Declaration of Digital Principles.
We appreciate that the Roadmap recognizes that the COVID-19 pandemic has “exposed the vulnerabilities of our digital space, and its impact on our societies”, creating a digital divide between persons able to benefit from the accelerated digital transformation and those who have encountered significant barriers during that transformation. For persons with disabilities lack of accessible digital technologies has resulted in violation of their rights to equal access to employment, education, culture and leisure, public and private services, including in relation to heath, commerce, emergency information and communications, as well as in areas of private and public participation.
It is also positive that the Roadmap states that “digital policies must help nurture more democratic and inclusive societies and ensure that all people in the EU can leverage the digital transformation for a better life.”
We highlight that digital principles must be systematically and consistently reflected in EU’s digital policy and legal frameworks in order for those declarative principles to be translated into tangible positive change in the lives of all persons in the European Union, including persons with disabilities.
To ensure the success of the Declaration of Digital Principles and the equal benefit of digital transformation for all EU citizens, the Union must ensure that:
• Accessibility is set as core underlying principle for EU’s digital transformation which is reflected within quantitative and qualitative targets.
• Accessibility is mainstreamed throughout all proposed initiatives.
• Public consultation for developing the framework approach for EU’s digital transformation, concreting legislative and policy initiatives within that framework, as well as development of new technologies are done in an inclusive, accessible, and participatory manner.
• Set goals and principles are supported by sufficient funding under the RRF and MFF instruments, ensuring accessibility as binding criteria for funding.
• Targeted funding for projects and initiatives aiming to advance accessibility of ICT are allocated, including through the participation of persons with disabilities in the development of digital solutions.
Read full responseResponse to Pathways to School Success
3 Jun 2021
Since the Pathways to School Success initiative aims to “promote better educational outcomes for all young Europeans”, learners with disabilities should be at its very heart. This group faces far higher levels of early school leavers and lower enrollment rates in higher education than persons without disabilities.
There are a number of barriers faced by learners with disabilities. One is the lack of access to learning materials available in formats that are accessible to them. This will depend on the individual but could include access to reading materials in Braille and easy-to-read format, or sign language interpretation, among other things. It is also necessary to ensure that online learning platforms and materials are accessible and compatible with assistive technology that enables learners with disabilities to use them. We would like to see this new initiative support investment in providing accessible learning materials to all learners who need them. We would also like to see investment made to render accessible all learning institutions that still have architectural barriers hindering the access of persons with disability.
Other learners with disabilities in mainstream settings might rely on teachers and teaching assistants who are trained to support them in their learning. For some learners, the availability of a trained classroom assistant can be the deciding factor as to whether or not they are able to complete school. We see a tendency in some countries to provide classroom learning assistants during primary school education, but then to seriously reduce their presence as of secondary school. This new EU initiative should focus on training and hiring classroom assistants to accompany and mentor learners with disabilities who need extra support in all levels of education.
Transitions between different levels of education pose a major obstacle for learners, particularly those with disabilities. Transition services at all educational levels are crucial (from pre-primary to primary school, from primary to secondary education, from school to post-school activities as post-secondary education, vocational training, employment, independent living, and community participation). This initiative should also take into account the difficult transition learners with disabilities face when entering the labour market. We would like to see it work to integrate personalised career counselling and work experience placements in national and regional education systems throughout the EU. We would also like to see an increased emphasis on vocational education and training workshops, as well as in improving digital literacy.
Another crucial prerequisite to reduce underachievement and early school leaving among learners with disabilities it is to promote early identification and intervention for children with disabilities who are at risk of learning difficulties.
In general, we would like to see the Pathways to School Success initiative making it easier for learners with disabilities who wish to do so, to be able to enroll in mainstream educational settings and to receive the necessary support to be able to successfully complete their education in inclusive settings alongside their peers without disabilities. We would also like to see it support Member States to i) collect more and reliable quantitative and qualitative data on children with disabilities in and out of the education system, and ii) develop indicators based on the human rights approach.
Last but not least, we think that this initiative should emphasise the development of actions to promote an inclusive culture and positive attitudes towards learners with disabilities within school communities. As we know, learners with disabilities are at a high risk of being bullied. According to the results of PISA 2018, pupils’ sense of belonging is declining, and bullying is widespread, factors that could explain the early school leaving of many young people.
Read full responseResponse to New EU urban mobility framework
20 May 2021
***Please see the document attached for our full feedback***
For the revision of the Directive, we would like to highlight the following aspects:
• Accessibility of transport vehicles (buses, trams, taxis, light rail, rail, etc.) – Rail vehicles are covered by the TSI-PRM but there is no binding legislation for the other transport modes. The result is that still new vehicles are purchased that are not accessible – for example new De Lijn buses in Belgium still don’t have visual and audio information announcing the following stop, which is a basic feature. And we are not even talking about ramps or lifts.
• Accessibility of transport infrastructure (stations, stops, multi-modal hubs, etc.) – some aspects will also be covered by the TEN-T Regulation but the UMP should also include smaller stops and stations outside the TEN-T network. It is a sad reality that still bus and tram stops are being built that do not match the vehicle fleet and result in accessibility problems. This has happened for example in Brussels, Belgium.
• Accessibility of the urban environment in general (streets, pavements, parks, playgrounds, shopping areas, and all other public places). The new European Standard EN 17210 on accessibility and usability of the built environment should be referenced and its use encouraged.
• Accessibility of information: This includes both static and real-time information on board of vehicles, at stops/stations, and on-line. As mentioned above, this should be a standard feature but it is not installed in all vehicles and stations in the EU. Easy-to-read formats are crucial for many persons with disabilities.
• Sustainable Urban Mobility Plans: SUMPs should be obligatory and they should include accessibility requirements. Persons with disabilities and their representative organisations should be consulted systematically both on a local and national level about their needs; Start planning now – it is cheaper to make designs accessible from the start; Use and create accessibility standards; Exchange good practices; Enforce the rules; training and awareness raising. The SUMPs should help align all the aspects mentioned above, e.g. when bus stops are renovated it should be made sure that the curb height matches the bus fleet to allow step-free access.
• Intersectional approach to urban planning: it is important to consider other barriers which person with disabilities can encounter when trying to access public transport. For example in cities like Brussels, the fact that self-ticketing machines are not accessible for all persons with disabilities can result in a financial loss for passengers with disabilities because it is more expensive to buy a ticket from the bus driver than a ticketing machine at the stop. So, affordability of accessible public transport is also important. Women, LGBTI or racialized persons with disabilities can face further barriers due to pubic harassment or personal safety concerns when using public transport.
• Public procurement: This is partly covered by the Public Procurement Directive but there should be clearer rules for accessibility requirements of public transport vehicles, infrastructure, and ticketing machines. Currently, each city procures its own vehicles and the requirements are not harmonized or aligned, resulting in the purchase of inaccessible vehicles and waste of public money. The wheel does not have to be re-invented every time, the technical solutions exist but there is a mismatch between the specifications in the call for tenders, the manufacturers’ proposals, and the reality of persons with disabilities that needs to be fixed.
In conclusion, we fully support the objectives of the Roadmap. In order to achieve the EU’s climate goals, we have to shift to more sustainable transport modes but persons with disabilities can only make this pro-active choice if they have full, independent access to all means of transport, including urban public transport.
Read full response4 May 2021
We strongly call on the European co-legislators to ensure accessibility of digital platforms and services, so that European law best serves the interest of all Union citizens, including of more than 100 million EU citizens with disabilities.
The explanatory memorandums for the Proposals make references to the UN Sustainable Development Goals and mention social sustainability. The EU acknowledges the importance of digital technologies in all aspect of modern life, highlighted by the coronavirus crisis, and the dependency of our societies on digital services. The document also claims that “the proposal is also fully consistent and further supports equality strategies adopted by the Commission in the context of the Union of Equality”. In reference to fundamental rights, the memorandum highlights freedom of expression and information, right to non-discrimination and protection of personal data and privacy. Lastly, it appreciates that “specific groups or persons may be vulnerable or disadvantaged in their use of online services,” noting disability as one of the grounds.
Therefore, having provided feedback to the European Commission’s public consultation on the Digital Services Act package, we are surprised and disappointed with the disregard of accessibility of digital services and platforms for persons with disabilities in the EU proposals. The proposed legal texts make no reference to the UN Convention on the Rights of Persons with Disabilities (UN CRPD) which the EU is bound to implement through initiatives such as the two proposed Regulations. There is also no mention of EU legislation aiming to advance accessibility, notably the European Accessibility Act and the Web Accessibility Directive, which creates inconsistency of existing and new Union legislation.
It is important to understand that lack of accessibility of online platforms and digital services will reinforce and create new barriers for millions of persons with disabilities in the digital domain. Therefore, we call on the EU to ensure:
Accessibility of all digital services and platforms for persons with disabilities;
Mainstreaming of accessibility throughout the legal texts, so that information, feedback and complaints mechanisms, dispute settling systems, public reports of services and national authorities, stakeholder-engagement platforms at national and EU-level are accessible as well;
Consistency with relevant international and Union legal frameworks, particularly with the UN CRPD and European Accessibility Act;
Meaningful engagement with persons with disabilities in structures aimed at facilitating the implementation of the current Regulations, for example in the European Board for Digital Services, or when drawing up codes of conduct and crisis protocols;
Effective data collection and reporting: Data on infringement of accessibility requirements under this Regulation should be reported by intermediary services to competent authorities, and included in the annual reports of these authorities in order to assess the effectiveness of this Regulation as regards ensuring accessibility of digital platforms and services for persons with disabilities.
https://www.edf-feph.org/access-denied-eu-must-ensure-accessible-digital-services-for-persons-with-disabilities/
Our concrete amendment suggestions to the texts of the proposals are included in the attached EDF Position on the DSA and DMA.
Read full responseResponse to European statistics on population - ESOP
4 May 2021
EU-level data collection is key to understanding how well the EU and its Member States are implementing the United Nations Convention on the Rights of Persons with Disabilities (CRPD). When done effectively, this data can form the basis for our understanding of how our societies are progressing in realising the rights of persons with disabilities. Quality data can also guide us to where more action needs to be taken and of course to track progress over time. With the COVID-19 pandemic, the ensuing economic crisis and the disproportionate impact this has had on persons with disabilities, data collection on this group will be increasingly crucial in the years to come.
Although Eurostat data on disabilities is currently disaggregated by age and gender, well-informed policy responses to the needs of persons with disabilities require the collection of data disaggregated according to the nature of a person’s disability as well, as is done through the use of the Washington Group set of questions on disability. This is something that is crucial to understanding how different types of disability have an impact on things such as rates of poverty, employment and educational attainment. However, we currently lack this data at EU level, with data that places all persons with disabilities in a single category, or simply splits persons with disabilities into two groups according to what are defined as “severe” or "some" activity limitation. This overlooks the hugely different barriers faced by persons with different types of disabilities, especially those with multiple disabilities.
Another major shortcoming is the fact that persons with disabilities living in residential care are not reflected in data coming from the EU Statistics on population. Such is the lack of data on persons living in institutions that we do not even have a clear figure of how many people live in such settings in the EU, although independent studies estimate the number at over a million. A new regulatory framework for European statistics on population that takes into account the realities of persons with disabilities must ensure that we have reliable data on this group collected in a consistent way throughout all Member States, particularly given that persons with disabilities living in institutions are the most likely to have high support needs, high levels of poverty and low levels of employment.
The EU and all Member States are party to the CRPD. Article 31 of the Convention states that information collected on persons with disabilities 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.” Addressing barriers cannot be done if we do not have disaggregated data on disability from all the Member States, including on persons with disabilities living in institutions.
EDF therefore calls on the EU to support the inclusion of these points in the new regulatory framework for European statistics on population.
Read full responseResponse to Social Economy Action Plan
20 Apr 2021
Social economy enterprises are a key stepping stone for the social and labour inclusion of persons with disabilities and can assist in the transition towards the open labour market. When these enterprises reinvest their profits into social causes, the added value is doubled. It will be important for the EU action plan on the social economy to clearly recognise the value of social economy enterprises in providing employment opportunities for persons with disabilities, and address the responsibility of social enterprises to focus on training and skilling their employees with disabilities to facilitate career progression and a transition into the open labour market if the employee wishes to. Particular efforts must be made to ensure that training programmes are made accessible for persons with disabilities, and that workers are free from discrimination when it comes to promotions and pay-scale progression.
It will also be crucial for the action plan to address the need for persons with disabilities working for social enterprises to have a guaranteed legal status of “employee”, and to thus be entitled to all the rights attached to this status in their Member State. This means a guarantee of minimum wage in countries where this exists, or a wage equivalent to that generally received in their sector of work in countries without laws on minimum wage. It also means entitlement to paid annual leave, sick leave, educational leave, unemployment benefits and all other social protection mechanisms, as well as the right to exercise trade union rights, again in line with the national norm. This legal status consideration is a mandatory step towards fulfilling Article 27 of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) at EU and national levels, which is binding law both for the European institutions and Member States.
The Action plan should explore the importance of persons with disabilities not only as employees in social enterprises, but also as entrepreneurs who want to create their own business or start-up. EU Member States should be incentivised through this action plan to promote self-employment and entrepreneurship among persons with disabilities by facilitating access to capital, simplifying procedures to set-up and register a business, and facilitating access to information in accessible formats for business owners.
The Action Plan should also set the basis for streamlining the role and value of Social Economy enterprises, with a particular focus on those that reinvest their revenues into social causes, in generating inclusive employment for persons with disabilities in all relevant policies (State Aid, public procurement, Structural Funds, Recovery Programmes within Next Generation EU, etc).
The action plan should also pay particular attention to furthering the quality employment of women with disabilities. Statistically, women with disabilities are significantly less likely to be employed and more likely to be in underpaid, low-quality jobs with poor working conditions. It should also seek to combat harassment, including sexual harassment, faced by women with disabilities working in social enterprises, in line with the discussion paper adopted by UN Women in 2020 and the Joint statement by UN Women, the Committee on the Elimination of Discrimination against Women and the Committee on the Rights of Persons with Disabilities on ending sexual harassment against women and girls with disabilities.
Read full responseResponse to Individual Learning Accounts – A possibility to empower individuals to undertake training
19 Apr 2021
This is a very welcome initiative to help the EU achieve its target of having 60% of adults participating in training and lifelong learning.
For this initiative to reach persons with disabilities, a number of things will have to be taken into consideration. The first would be the size of the budget provided to adult learners, and the flexibility of the programme to extend the budget to assist in covering the cost of additional accessibility requirements or support in order for the person to take part in the training. This could be, for example, the ability to use the personal budget to pay for sign language interpreters or personal assistants to be present during the class, or to have learning materials printed in Braille format. The budget itself needs to be sufficient to cover these costs.
Enabling for flexibility and possible extensions of the budget for learners with disabilities would be a worthwhile investment to reach those who are often most cut off from training and life-long learning opportunities. It will be especially important for women with disabilities, who face even greater barriers in completing education and entering the open labour market.
Another thing that should be taken into account in this proposal for individual learning accounts is the issue of the gap in digital skills. Funds should be made available in particular to assist persons with disabilities in increasing competency in digital skills and in learning how to make the best use of assistive technology to meet their own accessibility requirements.
The digital skills gap is in itself something that should be considered when funding and supporting training and lifelong learning for persons with disabilities. There should not be an overreliance on funding training courses that are exclusively online, and thus inaccessible to certain persons with disabilities or older people who are perhaps not sufficiently confident with online learning platforms to enroll. The money from these Individual Learning Accounts should also not go towards supporting learning settings that are inaccessible to persons with disabilities and/or further their exclusion and segregation.
Adults with disabilities, as any other adult, should be able to choose the professional training they want and every subject should be available for them just as for persons without disabilities. The right investment through the Individual Learning Accounts could help make this a reality.
Read full responseResponse to Extension of the list of EU crimes to hate speech and hate crime
9 Apr 2021
The European Disability Forum welcomes the commitment of the European Commission to protect the rights of victims in the European Union (EU) and the initiative to extend the list of EU crimes in Article 83(1) of the Treaty on the Functioning of the European Union (TFEU) to hate speech and hate crime.
Similar to other discriminated persons in the EU, persons with disabilities are at higher risk of being victims of hate speech and hate crime. In general, persons with disabilities, including women with disabilities, and persons with intellectual and psychosocial disabilities, are at higher risk of harassment, violence and crime, including within the digital world. According to data published by the Fundamental Rights Agency of the European Union (FRA), 50% of persons with disabilities have reported being harassed over a 5-year period, comparing to 37% of persons without disabilities.
Yet, disability related hate speech and hate crime are not recognised and sanction as such by all EU Member States. In addition, persons with disabilities continue to face barriers in reporting offences due to a multitude of barriers in the justice system. This leads to lower reporting and limited data on hate crimes and hate speech faced by persons with disabilities in the EU.
EDF calls on the EU to extend the list of EU crimes to cover hate speech and hate crime beyond the grounds covered by Framework Decision 2008/913/JHA. The list of EU crimes and EU legislation and initiatives to combat hate speech and hate crime should cover the grounds of disability, age, gender and sexual orientation (in line with list of discrimination grounds under Article 19 TFEU).
This will contribute to the implementation of the UN Convention on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its member states and the Disability Rights Strategy 2021-2030 and Victims’ Rights Strategy 2020-2025. Article 16 of the CRPD requires parties to the Convention “to take all legislative, administrative, social, education and other measures to protect persons with disabilities, both within and outside the home, from all forms of exploitation, violence and abuse, including their gender-based aspects.”
More specifically we recommend that the EU:
• Involve representative organisations of persons with disabilities
- In the design, development, implementation and monitoring of initiatives related to combatting hate speech and hate crime
- In the design, delivery, and monitoring of victim support services
• Extend the list of EU crimes to cover hate speech and hate crime and cover the grounds of disability, age, gender (in line with the list of discrimination grounds under Article 19 TEFU).
• Ensure that minimum rules on the definition of criminal offences and sanctions in the areas of hate speech and hate crime take into account bias based on disability, including the digital domain, and that the disability of the victims never allows for lighter sentences for the perpetrator.
• Take measures to improve the rights of victims with disabilities, including to ensure they can adequately report the offence or crime to national authorities (in light of EDF recommendations on the EU Strategy on Victims’ Rights 2020-2024), and that they receive accessibility and inclusive support. Expansion of third-party reporting mechanisms could also be considered.
• Support the creation by Member States of mandatory training on disability rights for all law enforcement and criminal justice system officials.
• Collect data on hate speech and hate crime, including in online environments, disaggregated by the motivation bias (including disability-bias), and the victims’ disability, gender and age.
Our full submission is attached.
Read full responseResponse to 2021 EU Justice Scoreboard
8 Apr 2021
The European Disability Forum, umbrella organisation defending the rights of over 100 million of persons with disabilities in the European Union, welcomes the roadmap consultation on the EU Justice Scoreboard.
EDF agrees that effective justice systems are essential for the implementation of EU law and upholding the rule of law and values upon which the EU is founded, including the values of equality, non-discrimination and respect for human rights (article 2 TFEU).
As Parties to the UN Convention on the Rights of Persons with Disabilities (CRPD), the EU and all its Member States have the obligation to ensure equal access to justice of persons with disabilities (article 13 CRPD) through ensuring equality and non-discrimination (article 5 CRPD), accessibility (article 9 CRPD), including of communication and information (article 21 CRPD) and equal recognition before the law (article 12).
Persons with disabilities living in the EU continue to face major barriers in accessing the justice system. As a consequence, they may not have their right to an effective remedy fulfilled in violation with article 47 of the EU Charter of Fundamental Rights, EU directives on access to justice and the CRPD which impact the EU as a whole.
The EU Justice Scoreboard is an important tool to achieve more effective justice. Unfortunately, in its current form it provides very limited information on effective access by persons with disabilities. Such information is necessary to support reforms in national justice systems required to make justice systems more effective.
The European Commission must establish a “CRPD compliant-justice” indicator – similar to the “child-friendly justice” indicator and cover all types of disabilities.
The CRPD indicator should include information on:
• Availability of information in accessible formats, including digital and paper-based information, such as in Braille, Sign Language and Easy to Read
• Procedural accommodations available for persons with disabilities, including provision of Sign Language interpreters, and other accommodations
• Physical accessibility of the justice system
• Training for all legal practitioners on the rights of persons with disabilities based on the CRPD
• Measures to ensure that persons with disabilities under substituted decision making (such as guardianship) can be listened to in person and express their will and preferences
• How court surveys address, and report on the rights and satisfaction of persons with disabilities, including children with disabilities (e.g. surveys)
Accessibility-related CRPD indicators should be in accordance with EU accessibility laws, and European and international standards, in particular:
• The Web Accessibility Directive (for websites and mobile applications of courts)
• The European Accessibility Act (for other services and products procured and used by courts; e.g. self-service terminal for queuing tickets, or built environment requirements for the buildings)
• European Standard on accessibility requirements for ICT services and products (EN301549)
• European Standard on accessibility and usability of the built environment (EN17210)
• World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI) guidance on cognitive accessibility
• Council of Europe’s Common European Framework of Reference for Languages
• ISO/IEC guidance on audio descriptions
• ISO/IEC guidance on visual presentation of audio information (including captions and subtitles)
• ISO/IEC Guidance on the audio presentation of text in videos, including captions, subtitles and other on-screen text (i.e. audio subtitling)
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
22 Mar 2021
Considering that almost 100 Million persons with disabilities live in the EU plus the even greater number of older persons, which will increase in the coming years, accessibility must be a priority. Making buildings accessible from the beginning or as part of a bigger renovation project is less costly and should be routine procedure. Accessible buildings do not have any negative impact on persons without disabilities so why not make all buildings accessible?
Separate solutions to ‘fix’ accessibly are more expensive and unsustainable. Including accessibility from the planning and concept phase reduces costs and leads to a better outcome. While renovation is still relatively more expensive than accessibility in new buildings, there will still be economies of scale and the opportunity cost of doing a “complete” renovation instead of several small ones.
The Structural Funds Regulations already have the obligation to ensure accessibility – the EU must include the same provisions in the EPBD. Most importantly, no EU funding should be spent to create new inaccessible buildings and infrastructure.
See more detailed recommendations in the document attached.
Read full responseMeeting with Eva Gerhards (Cabinet of Commissioner Helena Dalli), Silvan Agius (Cabinet of Commissioner Helena Dalli) and
22 Mar 2021 · Exchange of Views on the Transition from institutional to Community-based Care.
Response to Evaluation of the European Union Agency for Railways (ERA)
19 Mar 2021
The European Disability Forum (EDF) has been involved in the ERA Working Party tasked with the review and amendment of the TSI-PRM for more than a decade and considers it very useful for implementing the Regulation to advance accessibility of rail infrastructure and rolling stock for persons with disabilities.
To continue the progress of the Working Party, it must be ensured that during the restructuring of the European Railway Agency (ERA) the role and importance of the TSI-PRM Working Party and the role of civil society organisations, including of persons with disabilities, is not diminished. Currently, there is discussion on merging the mandate of the Working Party under an umbrella of an ‘inclusive transport’ platform. While we agree that rights of all passengers should be respected equally, we are concerned that the important discussions on accessibility that have made rail travel possible for millions of persons with disabilities, but still need quite a lot of advancement, might lose focus and effectiveness.
We want to maintain similar level of decision-making for the Working Party within the structure of ERA, and have guarantee that we will be at the decision-making table as until now, with continued funding for our participation. Our involvement so far has been a good practice example on how the EU meaningfully engages organisations of persons with disabilities (DPOs). Inclusion and meaningful participation of persons with disabilities is a prerequisite to make sure that EU initiatives affecting persons with disabilities are successful. It also ensures that EU does not breach its obligations under the UN Convention on the Rights of Persons with Disabilities, and respects the right of persons with disabilities to freedom of movement enshrined in EU Treaties.
It is also important that given extension of ERA’s mandate it is supported by sufficient human and financial resources so that the Agency can fulfil its role efficiently. This also includes structures, departments, and accessibility experts, tasked with implementation of the TSI-PRM.
Read full responseResponse to Supporting broad and inclusive participation of mobile EU citizens in elections to the European Parliament
18 Mar 2021
On behalf of the European Disability Forum, please find attached our response to the public consultation.
Read full responseResponse to Proposal for a Regulation - Migration and Home Affairs
8 Mar 2021
The regulation should refer to the CRPD.
Preamble (pmbl.) 43, art. 12 (4) and 13 (4d): as written in art. 7 CRPD, children with disabilities should be provided with disability and age-appropriate assistance to express their views on matters affecting them, including during the personal interview and upon assessing the best interests of the child.
Pmbl 44, art. 13 (4) and 24: should refer to art. 24 CRPD ‘respect for home and family life’: children with disabilities have equal rights with respect to family life; state parties should provide appropriate assistance to persons with disabilities in the performance of their child-rearing responsibilities.
Pmbl 4, art. 13 (4) and 24: as stipulated in art. 24 CRPD, each child should not be separated from his or her parents against their will.
Pmbl 48: include ‘disability’ as a criterion to demonstrate the existence of a relationship of dependency between an applicant and his or her child, sibling or parent and in order to guarantee family unity and to respect the best interest of the child.
Pmbl 55 and art. 12 (4): the personal interview should be performed in an accessible way, providing f.e. sign language interpretation for a Deaf or Deaf-blind person, ensuring easy to read information for persons with intellectual disabilities and guaranteeing that the interview takes place in an accessible venue for wheelchair users or persons with other types of physical disabilities.
Art. 24 refers to persons with “serious illness, severe disability or severe trauma” as “dependent persons” and the capacity of family members to “take care” of the dependent person. Describing persons with disabilities as dependent persons reintroduces a medical understanding of disability and mental health which does not comply with the CRPD and international standards. The terminology must be revised to align with the CRPD.
Pmbl 59 and art. 34: the CRPD Committee recommended to the EU during its review in 2015 to issue guidelines to its agencies and member States that restrictive detention of persons with disabilities in the context of migration and asylum seeking is not in line with the CRPD.
Pmbl 60 and 69: include references to the CRPD, to which both the EU and all member states have ratified.
Pmbl 72: the examination procedure should use uniform and accessible conditions for the consultation and exchange of information on “minors and dependent persons”, including consulting with and informing persons with disabilities themselves.
Art. 3 (i): access for applicants to adequate and accessible reception conditions.
Pmbl 20 and art. 6 (1) and (2): the location of the screening should be accessible to all persons with disabilities.
Art. 10 (1): refer to the CRPD under ‘international obligations’ and the obligation to ensure that applicants with disabilities who are not entitled to the reception conditions set out in the Reception Conditions Directive are ensured of an adequate standard of living and right to live in the community, and not forced to live in institutions or other closed settings.
Art 11 (2): all information and communication around the applicable procedures under this Regulation should take into account the disability of the applicant and be provided in various accessible formats (sign language interpretation, Braille, Easy to Read, etc).
Art 37 (2a) and 39 (1): information regarding the transfer should specify the accessibility requirements and reasonable accommodations needed by the person with disabilities, rather than his or her “special needs” (article 37). The transferring member state should ensure that the necessary reasonable accommodations are taken, rather than “ensuring that those special needs are adequately addressed” (article 39).
Art 39 (2): information regarding the applicant shall only be transfered after obtaining his or her consent, even when the person is deprived of his or her legal capacity, as in line with article 12 CRPD and General Comment No. 1 of the CRPD Committee.
Read full responseResponse to Europe’s digital decade: 2030 digital targets
8 Mar 2021
The European Disability Forum (EDF) welcomes the European Union’s planned Communication on a Europe’s digital decade: 2030 digital targets which sets a “vision of a common future including all Europeans”.
It is positive to see EU’s proactive approach of aiming to ensure that everyone in the Union can benefit from digital transformation irrespective of their place of residence. It is also positive that this aim is supported with a 20% minimum expenditure target in Member States under the Recovery and Resilience Facility (RRF) in addition to the digital component of the 2021-2017 Multiannual Financial Framework (MFF). The concept of “European digital citizenship” can only be realised through harmonisation of Member State actions and digital targets, therefore we support European Union’s strong coordinating role in this regard. Finally, we are pleased to see EU’s commitment to promote inclusive digital transformation in external cooperation initiatives.
To ensure the success of EU’s 2030 digital targets and the equal benefit of digital transformation for all EU citizens, the Union must ensure that:
• Accessibility is set as core underlying principle for EU’s digital transformation which is reflected within quantitative and qualitative targets.
• Accessibility is mainstreamed throughout all proposed initiatives for reaching the 2030 targets.
• Public consultation for developing the framework approach for EU’s digital transformation, concreting legislative and policy initiatives within that framework, as well as development of new technologies are done in an inclusive, accessible, and participatory manner.
• Set goals and principles are supported by sufficient funding under the RRF and MFF instruments, ensuring accessibility as binding criteria for funding.
• Targeted funding for projects and initiatives aiming to advance accessibility of ICT are allocated, including through the participation of persons with disabilities in the development of digital solutions.
See more detailed feedback in the attached document.
Read full responseResponse to European Health Emergency Response Authority
24 Feb 2021
The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the European Health Union Package and the new EU health emergency preparedness and response authority (HERA).
Under article 11 of the CRPD, the EU and its Member States must ensure that all emergency preparedness and response measures are fully inclusive of persons with disabilities.
Persons with disabilities were one of the most affected groups of the COVID-19 pandemic in the European Union, in terms of the number of people being infected, dying and being subjected to human rights violations. The EC proposals which are part of the European Health Union Package must ensure that the EU and Member States are better equipped to deliver a disability inclusive response to future health threats and pandemics. In this context, strengthening the preparedness of the EU and its member states is critical.
The European Disability Forum, umbrella organisation of persons with disabilities defending the rights of over 100 million persons with disabilities in the EU, run by persons with disabilities and their families calls on the European Commission to incorporate the rights of persons with disabilities in the establishment of HERA.
Recommendations:
1. Nothing about us, without us (art. 4.3 CRPD): persons with disabilities through their representative organisations must be adequately consulted and actively involved in the creation of HERA, and in the response to all future health threats and pandemics. All prevention and response plans should be developed with the active involvement of organisations of persons with disabilities.
2. Disability focal point (art. 33.1 CRPD): a disability focal point must be established within HERA to ensure implementation of the CRPD. It must coordinate its work with the other disability focal points in EU institutions and bodies.
3. Right to life (art. 10 CRPD): protecting the right to life to all persons living in the EU, including persons with disabilities, must be a core objective of HERA, from preparedness, threat assessment and response in terms of medical countermeasures.
4. Accessibility (art. 9, CRPD): accessibility should be at the core of deployment of countermeasures to prepare for and address cross-border health threats. It must be a requirement in the production and procurement of emergency supplies. HERA must ensure that emergency supplies, including personal protective equipment, and additional medical services are available and accessible to persons with disabilities. All internal and external communication messages and platforms (such as websites and apps) must also be fully accessible to persons with disabilities, both as employees of HERA, and as users of its information and communication platforms.
5. Equality and non-discrimination (art. 5 CRPD): HERA must ensure that countermeasures do not discriminate against persons with disabilities, irrespective of their gender, age and other grounds of discrimination; also in line with the EU Charter of Fundamental Rights and the European Pillar of Social Rights.
6. Data collection and disaggregation (art. 31 CRPD): data collected must be disaggregated by age, gender and disability
Our recommendations on the EU Heath Union are attached to this submission.
Read full responseResponse to Evaluation of patient rights in cross-border healthcare
11 Feb 2021
The European Disability Forum, umbrella organisation the rights of over 100 million persons with disabilities in the EU welcomes the upcoming evaluation of the Cross-Border Healthcare Directive by the European Commission.
Under article 25 of the United Nations Conventions on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its Member States, articles 21 and 35 of the EU Charter on Fundamental Rights, and the EU Directive on Cross-Border Healthcare, EU citizens with disabilities should have the right to the enjoyment of the highest attainable standard of health without discrimination on the basis of disability when seeking healthcare in other EU member state.
In 2015, the CRPD Committee specifically recommended that the EU evaluates the impact of the Directive on Cross-Border Healthcare with regard to gaps in access for persons with disabilities, including accessible information, reasonable accommodation and training of professionals.
Persons with disabilities have higher unmet needs for medical examination than the rest of the population due to discrimination and barriers in the healthcare system. Persons with disabilities also face human rights violations within the health system that range from barriers to services and support, such as lack of access to public health information, lack of access to health facilitates and services, to denial of their right to informed consent to treatment, for example, forced sterilization of women with disabilities, or involuntary treatment and placement in psychiatry. Stigma, discrimination and human rights violations were brought into sharp focus by the COVID-19 pandemic. Persons with disabilities were excluded from the health response- and faced discrimination in triage guidelines and being de-prioritised for healthcare.
We call on the European Commission to examine the human rights violations faced by patients with disabilities in the evaluation of the Cross-Border Healthcare Directive.
The European Commission should include persons with disabilities, through their representative organisations, in the stakeholder consultations on the evaluation of the Directive, and in all other initiatives on health.
The evaluation should look at the following issues:
• Whether existing EU and national policies to support the implementation of the Cross-Border Healthcare Directive are inclusive of persons with disabilities and contribute to the implementation of the CRPD, by evaluating:
o The inclusion of the rights of patients with disabilities in national legislation and policies implementing the Directive
o The administrative burdens and barriers faced by patients with disabilities when seeking healthcare in another Member State and reimbursement thereafter, including inaccessibility and lack of reasonable accommodation at all stage of the process, and higher disability related costs (in line with articles 4(2)(a) and 6(5) of the Directive regarding guidelines and information on accessibility of hospitals for persons with disabilities, and accessible information concerning healthcare providers, patients’ rights, etc.)
• Whether the implementation of the Cross-Border Healthcare Directive may lead to human rights violations, including by evaluating:
o The respect of the ‘informed choice’ of the patient (article 4(2)(b) of the Directive on responsibilities of the member state of treatment) and risks faced by patients to be subjected to involuntary treatment and placement in psychiatry
o The scope and impact of article 8 of the Directive on ‘healthcare that may be subject to prior authorisation’ on patients with intellectual or psychosocial disabilities, including in relation to involuntary treatment and placement in psychiatry
o The availability and accessibility of complaints procedures and mechanisms in place for patients suffering arm arising from the healthcare they receive (article 4(2)(c) of the Directive)
Read full responseResponse to Digitalisation of cross-border judicial cooperation
5 Feb 2021
The European Disability Forum (EDF), umbrella organisation defending the rights of over 100 million persons with disabilities in the EU, welcomes the initiatives of the European Commission to improve access and efficiency of the justice system. Modernising judicial cooperation between EU countries to improve access to justice in cross-border cases, through the use of digital technology, can be very beneficial to persons with disabilities.
Persons with disabilities currently face multiple barriers in the justice system (including digital barriers) that hinders their access to justice in cross-border cases. They are also affected by the digital gap.
The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) ratified by the EU and all its Member States, requires all States Parties to ensure full accessibility of the justice system of persons with disabilities (articles 9 and 13 CRPD).
EDF recommends that the European Commission includes the following points in its initiative:
• Recognise accessibility as a core principle of the modernisation of the judicial cooperation between EU countries and ensure accessibility is a requirement in all related EU initiatives
o Ensure that proposed EU legal or policy measures are consistent with existing Union policies on accessibility, in particular with Directive (EU) 2016/2102 on the Accessibility of the Websites and Mobile Applications of Public Sector bodies
o Ensure that public courts and other public judicial bodies demonstrate at least a level of accessibility equivalent to that set by European standard EN 301 549 V3.1.1 in the procurement of the different ICT products and services.
o Ensure that public courts and other public judicial bodies provide and regularly update a detailed, comprehensive and clear accessibility statement on the compliance of their websites and mobile applications with Directive (EU) 2016/2012
o Ensure the application of the above three requirements to judicial bodies at local, regional, national and European-level, as well as extend them to institutions dealing with alternative dispute resolution, including in relation to all cross-border cases
• Provide accessible alternatives to digital services and formats, and reasonable accommodations based on the individual preferences and needs of the person with disabilities when necessary (whether participants or workers in the justice system, in all cross-borders cases). For a blind person for instance, that would mean that they could receive information in Braille, even if an accessible PDF is available- in case they do not have access to a computer or a smart phone.
• Invest in increasing the digital skills of persons with disabilities in the EU, including employees of the justice system with disabilities, and of older persons with disabilities, with specific actions related to increasing their knowledge of digital accessibility features and how to make use of them
• Increase the competences of ICT professionals in accessibility for persons with disabilities and invest in training future professionals to become specialised technical support and accessibility for persons with disabilities
• Ensure that persons with disabilities and their representative organisations at European, national and local levels, are involved in meaningful consultation when guiding the implementation of the points listed above
Read full responseResponse to Proposal for a Regulation establishing a European Centre for Disease Prevention and Control (ECDC)
2 Feb 2021
The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.
Persons with disabilities were one of the most affected groups of the COVID-19 pandemic in the European Union, in term of contamination, deaths and human rights violations. The EC proposals which are part of the European Health Union Package must ensure that the EU and Member States are better equipped to activate a disability inclusive response to future health threats and pandemics.
The European Disability Forum, umbrella organisation of persons with disabilities defending the rights of over 100 million persons with disabilities in the EU, run by persons with disabilities and their families calls on the European Commission to incorporate the rights of persons with disabilities in this proposal for a regulation.
Recommendations
1. Nothing about us, without us (art. 4.3 CRPD): persons with disabilities through their representative organisations must be adequately consulted and actively involved in the development of the European Health Union Package, and in the response to all future health threats and pandemics
2. Right to life (art. 10 CRPD): protecting the right to life to all persons living in the EU, including persons with disabilities, must be a core objective of the European Heath Union Package, from prevention and preparedness, testing, treatment and vaccination
3. Preparedness and response (art. 11 CRPD): the EU and its Member States must ensure that all emergency preparedness measures are fully inclusive.
4. Accessibility (art. 9, CRPD):
a. Emergency public information and communications: The EU Health Package should be in consistent with EU policies and legislation to ensure persons with disabilities have equal access to technologies and information required during public health emergencies.
b. Information systems: Digitalisation process should ensure that development of new technologies to tackle public health emergencies are accessible for persons with disabilities.
c. Labeling of medical devices, including protective equipment, sanitary products should be accessible for persons with disabilities. Protective equipment design should also take into account different access needs of persons with disabilities
d. Cost: As well as foreseeing the availability of medicines and devices in the EU, the package also needs to work to ensure their affordability to all
5. Equality and non-discrimination (art. 5 CRPD): relevant initiatives under the Package must aim at combating human rights violations faced by discriminated groups such as persons with disabilities, including women and children with disabilities
6. Data collection and disaggregation (art. 31 CRPD): data collected must be disaggregated by age, gender and disability
7. EU in the World (art. 32 CRPD): the EU and its member states must ensure equitable access to testing, treatment and vaccination for persons with disabilities in countries with less robust healthcare systems and economies. They must also speed-up the delivery of vaccine delivery not just in Europe but also in the world.
Our full recommendations are attached to this submission.
Read full responseResponse to Proposal for a Regulation on serious cross-border threats to health
2 Feb 2021
The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.
Persons with disabilities were one of the most affected groups of the COVID-19 pandemic in the European Union, in term of contamination, deaths and human rights violations. The EC proposals which are part of the European Health Union Package must ensure that the EU and Member States are better equipped to activate a disability inclusive response to future health threats and pandemics.
The European Disability Forum, umbrella organisation of persons with disabilities defending the rights of over 100 million persons with disabilities in the EU, run by persons with disabilities and their families calls on the European Commission to incorporate the rights of persons with disabilities in this proposal for a regulation.
Recommendations
1. Nothing about us, without us (art. 4.3 CRPD): persons with disabilities through their representative organisations must be adequately consulted and actively involved in the development of the European Health Union Package, and in the response to all future health threats and pandemics
2. Right to life (art. 10 CRPD): protecting the right to life to all persons living in the EU, including persons with disabilities, must be a core objective of the European Heath Union Package, from prevention and preparedness, testing, treatment and vaccination
3. Preparedness and response (art. 11 CRPD): the EU and its Member States must ensure that all emergency preparedness measures are fully inclusive.
4. Accessibility (art. 9, CRPD):
a. Emergency public information and communications: The EU Health Package should be in consistent with EU policies and legislation to ensure persons with disabilities have equal access to technologies and information required during public health emergencies.
b. Information systems: Digitalisation process should ensure that development of new technologies to tackle public health emergencies are accessible for persons with disabilities.
c. Labeling of medical devices, including protective equipment, sanitary products should be accessible for persons with disabilities. Protective equipment design should also take into account different access needs of persons with disabilities
d. Cost: As well as foreseeing the availability of medicines and devices in the EU, the package also needs to work to ensure their affordability to all
5. Equality and non-discrimination (art. 5 CRPD): relevant initiatives under the Package must aim at combating human rights violations faced by discriminated groups such as persons with disabilities, including women and children with disabilities
6. Data collection and disaggregation (art. 31 CRPD): data collected must be disaggregated by age, gender and disability
7. EU in the World (art. 32 CRPD): the EU and its member states must ensure equitable access to testing, treatment and vaccination for persons with disabilities in countries with less robust healthcare systems and economies. They must also speed-up the delivery of vaccine delivery not just in Europe but also in the world.
Our full recommendations are attached to this submission.
Read full responseResponse to Proposal for a Regulation on a Union framework addressing public health emergencies (EMA)
2 Feb 2021
The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.
Persons with disabilities were one of the most affected groups of the COVID-19 pandemic in the European Union, in term of contamination, deaths and human rights violations. The EC proposals which are part of the European Health Union Package must ensure that the EU and Member States are better equipped to activate a disability inclusive response to future health threats and pandemics.
The European Disability Forum, umbrella organisation of persons with disabilities defending the rights of over 100 million persons with disabilities in the EU, run by persons with disabilities and their families calls on the European Commission to incorporate the rights of persons with disabilities in this proposal for a regulation.
Recommendations:
1. Nothing about us, without us (art. 4.3 CRPD): persons with disabilities through their representative organisations must be adequately consulted and actively involved in the development of the European Health Union Package, and in the response to all future health threats and pandemics
2. Right to life (art. 10 CRPD): protecting the right to life to all persons living in the EU, including persons with disabilities, must be a core objective of the European Heath Union Package, from prevention and preparedness, testing, treatment and vaccination
3. Preparedness and response (art. 11 CRPD): the EU and its Member States must ensure that all emergency preparedness measures are fully inclusive.
4. Accessibility (art. 9, CRPD):
a. Emergency public information and communications: The EU Health Package should be in consistent with EU policies and legislation to ensure persons with disabilities have equal access to technologies and information required during public health emergencies.
b. Information systems: Digitalisation process should ensure that development of new technologies to tackle public health emergencies are accessible for persons with disabilities.
c. Labeling of medical devices, including protective equipment, sanitary products should be accessible for persons with disabilities. Protective equipment design should also take into account different access needs of persons with disabilities
d. Cost: As well as foreseeing the availability of medicines and devices in the EU, the package also needs to work to ensure their affordability to all
5. Equality and non-discrimination (art. 5 CRPD): relevant initiatives under the Package must aim at combating human rights violations faced by discriminated groups such as persons with disabilities, including women and children with disabilities
6. Data collection and disaggregation (art. 31 CRPD): data collected must be disaggregated by age, gender and disability
7. EU in the World (art. 32 CRPD): the EU and its member states must ensure equitable access to testing, treatment and vaccination for persons with disabilities in countries with less robust healthcare systems and economies. They must also speed-up the delivery of vaccine delivery not just in Europe but also in the world.
Our full recommendations are attached to this submission.
Read full responseResponse to Proposal for a Regulation - Migration and Home Affairs
27 Jan 2021
The proposal of a “vulnerability assessment” does not adequately consider the rights and needs of persons with disabilities. The proposal fails to explicitly commit to providing reasonable accommodation and support for asylum seekers with disabilities, such as accessible communication formats. During the “health and vulnerability checks”, authorities should pay “particular attention (…) to individuals with vulnerabilities, such as (…) persons with an immediately identifiable physical or mental disability.” Persons with disabilities, including persons with intellectual and psychosocial disabilities, are diverse. To request authorities to make examinations upon mere observation of “immediately identifiable disability” ignores the diversity amongst persons with disabilities and de facto discriminates persons with disabilities. It reintroduces a medical understanding of disability and mental health which does not comply with the CRPD which the EU and all its member states have ratified.
Specific recommendations:
Preamble 22: the proposed regulation should explicitly refer to the UN Convention on the Rights of Persons with Disabilities (CRPD), its human rights based approach to disability, Article 11 on situations of risk and humanitarian emergencies, the Global Compacts on Refugees and Migration and follow up on the recommendation on refugees with disabilities received by the CRPD Committee, IASC Guidelines on Persons with Disabilities in Humanitarian Action;
Preamble 20 and article 6 (1) and (2) ‘Requirements concerning the screening’: the location of the screening should be accessible to all persons with disabilities;
Preamble 23 and article 7 ‘Monitoring of fundamental rights’: monitoring should comply with the obligations of the member state under the CRPD. The national monitoring mechanism should cooperate with the CRPD national monitoring mechanism under article 33.2 CRPD;
Article 8 ‘Provision of information’: all information and communication around the screening should take into account the disability of the third country national and be provided in various accessible formats (sign language interpretation, Braille, Easy to Read, etc.);
Preamble 26, 27 and Article 9 ‘Health checks and vulnerabilities’: these checks need to identify person with disabilities, based on a human rights approach to persons with disabilities. The screening should ensure that reasonable accommodation and the necessary reception and procedural support are provided, on an equal basis with others. It should guarantee that persons with disabilities receive the necessary support and assistance in the reception centers, to live independently in the community and are able to give their free and informed consent prior to any health treatment;
Article 10 ‘Identification’: disaggregated data by disability (by using and promoting the Washington Group Set of Questions), gender and age of the third country nationals should be collected;
Ensure that all support services which persons with disabilities are entitled to in the host country are accessible and inclusive for third country nationals with disabilities, including assistive technology;
Include the rights of persons with disabilities and the CRPD in every element of the EUs approach to migrants, refugees and asylum seekers, in your responses to COVID-19 and initiatives towards the implementation of the Pact on Migration and Asylum;
Meaningfully involve and consult with persons with disabilities and their representative organisations in designing, implementing and evaluating the New Pact on Migration and Asylum and any related initiatives, including on COVID-19;
Encourage funding the representative organisations of persons with disabilities provide support, information, inclusion, such as the NCDP project
Use the 2020 OECD-DAC policy marker on inclusion and empowerment of persons with disabilities to identify and report the activities related to disability inclusion and their financing.
Read full responseResponse to Evaluation of the Victims’ Rights Directive
21 Dec 2020
The European Disability Forum, umbrella organisation defending the rights of over 100 million persons with disabilities in the EU welcomes the upcoming evaluation of the Victims’ Rights Directive by the European Commission.
Despite the adoption of the Victims’ Rights Directive and related legal framework, many victims in the EU are not granted their rights. Even when measures are available, they are often inaccessible to victims with disabilities. Persons with disabilities face difficulties reporting crimes, accessing support measures and services, and exercising their rights to a criminal proceeding and support throughout.
Physical and/or communication barriers make crimes difficult to report, and myths and stereotypes prevent persons with disabilities from being considered credible by the police and the criminal justice system. Persons with disabilities are often not aware of the legal remedies available or are afraid of stigmatisation and victimisation. States also fail to provide victims’ services accessible to persons with disabilities, from lack of (or inaccessible) information on their rights to inaccessible helplines and shelters. In the criminal proceedings itself, persons with disabilities often do not receive appropriate procedural accommodation and, in many instances, court buildings are not accessible to people with reduced mobility.
Women with disabilities are particularly affected as they are more at risks of being victims of crimes, including sexual and domestic violence, and excluded by the justice system.
We call on the European Commission to particularly examine the specific gaps faced by victims with disabilities in the evaluation of the Victims’ Rights Directive.
The evaluation should look at the following issues:
• Whether existing EU policies to support the implementation of the Victims’ Rights Strategy are inclusive of persons with disabilities and contribute to the implementation of the UN Convention on the Rights of Persons with Disabilities, ratified by the EU and all its Member States.
• Whether existing national legislation and policies on victims’ rights include the rights of persons with disabilities, and mandatory provision of accessibility and reasonable accommodation for victims with disabilities in the criminal justice system and in victim support services, in line with articles 3-7, 22-23 and articles 8-9 of the Directive, including:
o Whether existing victims support services, such as helplines and shelters, are accessible to victims with disabilities, in particular women and girls with disabilities;
o Whether victims of crimes with disabilities, especially women and girls with disabilities victims of domestic violence, have an equal right to avoid contact with the offender in line with article 19 of the Directive, including when the offender is a legal guardian or carer;
o Whether the rights of children with disabilities victims of crime are guaranteed in the national legislation and policies, in line with article 24 of the Directive.
• Whether EU Member States adopted measures to raise awareness on the rights of victims with disabilities, including women and children with disabilities victims of violence, and to combat stereotypes that hinders their rights, including through the training of practitioners, in line with article 25 of the Directive.
• Whether EU Member States collect disaggregated data on victims, including by disability, age and gender, to evaluate the implementation of the Directive and adopt targeted measures to support disadvantaged groups of victims, in line with article 28 of the Directive.
Read full responseMeeting with Nicolas Schmit (Commissioner) and
14 Dec 2020 · Meeting on the European Disability Strategy.
Response to Review of the application of the Web Accessibility Directive
8 Dec 2020
The European Disability Forum (EDF) welcomes the opportunity of providing feedback to the Web Accessibility Directive evaluation roadmap.
At this stage the only suggestions we can make are the following:
- On Purpose and scope: "It will cover the Directive’s scope (the bodies covered, content exclusions)", in our view, this would also need to cover all exemptions, not only those related to certain content. This addition would allow to assess the appropriateness of excluding certain websites and mobile applications.
- On the information to be consulted with stakeholders, it should not focus just on "the availability of public online content", but also on public online services.
- An additional piece of information to be gathered from stakeholders could be to explain and assess the specific policies put in place at national level to transpose and comply with the Directive. This will enable the exchange of best practices across EU countries.
Read full responseResponse to EU Strategic Framework on Health and Safety at Work [2021-2027]
26 Nov 2020
Ensuring the health and safety of all employees means paying particular attention to accessibility for persons with disabilities in the workplace. Perhaps nowhere is this need for accessibility more apparent than in the evacuation of the workplace in case of emergencies. An EU Strategic Framework on health and safety at work must outline the need for employers to establish ways for all employees with disabilities to safely evacuate the premises and to be able to do so to the greatest extent possible autonomously. It is therefore necessary, for example, for persons with reduced mobility to be able to easily evacuate the building. In cases where the design of the building means the person cannot evacuate alone, it is of paramount importance that there are clear instructions for where the person must go in order to be assisted with their evacuation, that a secure and fireproof area be foreseen for them to await assistance, and absolute clarity for the people assisting with the evacuation, including the fire crew, as to where the person will be waiting. Employers would also need to foresee other precautions on the basis of the needs of their employees with disabilities such as (although not exhaustively) visual alarms for people who are deaf or hard of hearing, and clear signage with large print and high contrast for persons with reduced vision to be able to navigate their way to an emergency exit. Some employees with intellectual disabilities might need exercises such as fire drills to be conducted in easy-to-understand language or using picture diagrams.
We therefore recommend that the Commission highlights the use of relevant safety protocols which address the needs of persons with disabilities, including the recently adopted European Standard 17210 on accessibility an usability of the built environment, resulted from the Commission Mandate 420. In addition to general accessibility requirements for the built environment, it also includes provisions for fire safety, evacuations and emergency exits (clause 14), including a complementary annex with more information (Annex A).
Health and safety in the workplace is also about taking preventative measure to ensure the health of workers is not compromised. For employees with disabilities, this can be linked to the provision of reasonable accommodation in line with their needs. When adjustments are not made and assistive devices/technology not provided in line with a worker’s specific needs, it can place strain on a person with disability and put their health at risk. The importance of providing reasonable accommodation for employees, particularly persons with disabilities, must therefore be strongly emphasised in the EU Framework Strategy on health and safety. Naturally, this should also include strong provisions on disability-awareness training, so that staff and managers are well equipped to provide the timely support that people need.
Read full responseResponse to European Child Guarantee
30 Sept 2020
In order to ensure that children who are at risk of poverty, social exclusion, or are otherwise disadvantaged, have access to essential services of good quality, the Guarantee will need to pay special attention to children with disabilities.
Households that have children with disabilities in the EU have been shown to be disproportionately at risk of poverty and social exclusion. This is in part due to many parents being unable to work because of lack of access to appropriate care facilities or personal assistance for their children (see https://mcusercontent.com/865a5bbea1086c57a41cc876d/files/ad60807b-a923-4a7e-ac84-559c4a5212a8/EDF_HR_Report_final_tagged_interactive_v2_accessible.pdf). It is an issue that affects women in particular, who often take on the role of informal carers. In other cases, it is the increased cost of living to make up for the inaccessibility of services, housing, public transport, or the need for personal assistance, that result in such households falling into poverty.
Housing itself is also a persistent issue. Families regularly struggle to find housing that is accessible for persons with disabilities, and when they do the rent usually far exceeds what would need to be paid for an inaccessible property.
There is also the issue of residential care, which is typically only used as a temporary solution for children without disabilities until they find foster families, but all too often becomes a permanent “solution” for children with disabilities, who remain institutionalised for most, if not all, of their lives. This will need to be taken into account in the design of the Child Guarantee. Member States need to be supported in making sure adequate support is given to housing children with disabilities and their families in line with human rights conventions such as the United Nations Convention on the Rights of Persons with Disabilities, and that children with disabilities are not in institutional care.
The Guarantee’s focus on early childhood education also needs to pay particular attention to ensuring that children with disabilities are not left behind. The recommendations and financial resources to emerge from the Guarantee must go towards making sure mainstream education is inclusive and accessible for learners with disabilities, including digital learning. Emphasis should not only go towards increasing the accessibility of the physical settings and digital tools used to teach, but also towards training teachers and classroom assistants in fully including learners with disabilities in the mainstream classroom setting, including hiring sign-language interpreters when needed.
Given the challenges faced by children with disabilities and the disproportionate impact of poverty and social exclusion on this group, the European Disability Forum urges the EU institutions to clearly mainstream disability issues in all planned activities arising from the Child Guarantee.
Read full responseMeeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)
16 Sept 2020 · Fostering attention to accessibility in EU legislation
Response to Digitalisation of justice in the European Union
10 Sept 2020
The European Disability Forum (EDF) welcomes the initiatives of the European Commission to improve access and efficiency of the justice system. The creation of a toolbox of measures to boost digitalisation in justice systems across the EU can be beneficial to improve access to justice of persons with disabilities. To avoid further inequalities, the EU must consider the potentials and risks it creates for persons with disabilities.
Persons with disabilities currently face multiple barriers in the justice system (including digital barriers) and are also affected by the digital gap.
The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) ratified by the EU and all its Member States, requires all States Parties to ensure full accessibility of the justice system of persons with disabilities (article 13 UN CRPD).
EDF recommends that the European Commission includes the following points in its initiative:
• Recognise accessibility as a core principle of the digitalisation of the justice system and ensure accessibility is a requirement in all EU initiatives on digitalisation, including in the ‘toolbox’ of measures to boost digitalisation in justice systems across the EU
• Provide accessible alternative to digital services and formats, and reasonable accommodations based on the individual needs of the person with disabilities – whether participants or workers in the justice system
• Invest in increasing the digital skills of persons with disabilities in the EU, including of older persons with disabilities, with specific actions related to increasing their knowledge of digital accessibility features and how to make use of them
• Increase the competences of ICT professionals in accessibility for persons with disabilities and invest in training future professionals to become specialised technical support and accessibility for persons with disabilities
• Encourage the exchange of good practice in accessible digital justice between Member States
• Gather data on accessibility and impact of digitalisation of justice on persons with disabilities, in particular in the EU Justice Scorecard
• Ensure that persons with disabilities and their representative organisations at European, national and local levels, are involved in meaningful consultation when guiding the implementation of the points listed above
More information is available in our recommendations paper attached.
Read full responseResponse to Fitness check of the EU legislation on violence against women and domestic violence
13 Aug 2020
The European Disability Forum, umbrella organisation defending the rights of over 100 million persons with disabilities in the EU, member of the European Women’s Lobby, welcomes this roadmap on the fitness check on the EU legislation on violence against women and domestic violence. We also welcome the adoption of the Gender Equality Strategy 2020-2025 and Strategy for Victims’ Rights 2020-2024, which include the perspective of women and girls with disabilities.
Women with disabilities constitute 16% of the total population of women in the European Union, and 60% of the overall population of 100 million persons with disabilities. This corresponds to an estimated 60 million of women with disabilities; equivalent to the total population of Italy. Women and girls with disabilities face multiple and intersectional discrimination in all areas of life, and are more at risk to face violence, abuses and harmful practices. Violence may take place in various settings (including in institutions and segregated schools) and take different forms, including harassment and sexual violence, but also forced abortion and sterilisation.
Reports show that:
• women with disabilities are two to five times more likely to face violence than other women
• 6 out of 10 women with intellectual disabilities report being sexually abused
• 34 % of women with a health problem or a disability have experienced physical or sexual violence by a partner in their lifetime
• sterilisation of women with disabilities without their knowledge or consent is a widespread form of violence, in particular affecting members of ethnic minorities such as Roma women (European Parliament resolution 2018/2685(RSP))
Yet, the EU and its Member States lack adequate legislation, policies and programmes to combat gender based and domestic violence. This include a lack of research and data on how different forms of violence affect various groups of women, including women and girls with disabilities, as well as a lack of funding to develop measures to prevent, combat and sanction violence.
Different women and girls with disabilities will face different forms of violence and issues to claim their rights. For instance, women with intellectual disabilities, women with psychosocial disabilities and women who have sensory impairments are more at risks of violence and face numerous barriers as victims. Deaf-blind women, for example, are very often discriminated against because of failure from States to provide accessible information and communication.
We call on the European Commission to particularly examine the specific gaps faced by women and girls with disabilities victims of violence in its Fitness check. It should in particular look at the following issues:
• Whether existing EU legislation and policies are inclusive of women and girls with disabilities, and contribute to the implementation of the UN Convention on the Rights of Persons with Disabilities ratified by the EU and all its Member States
• Whether existing EU legislation and policies addressed compounded forms of violence faced by women based on various grounds of discrimination such as disability, ethnicity, age, sexual orientation, gender identity, religion and belief
• Whether EU and national legislation comply with the Council of Europe Convention on preventing and combating violence against women and domestic violence – for instance whether they prohibit forced sterilisation as a form of violence against women
• Whether the research conducted and data collected, especially from the European Institution Gender Equality, consider the situation of various groups of women, including various groups of women and girls with disabilities, as to ensure their situation is known and adequate measures can be adopted
• Whether EU funds are used to combat violence against women and girls with disabilities, and whether EU funded initiatives to combat violence are inclusive and accessible of women and girls with disabilities
Read full responseResponse to New Pact on Migration and Asylum
6 Aug 2020
Refugees and asylum seekers with disabilities face the same risks as other refugees, however compounded by many other issues: finding themselves at heightened risk of violence, including sexual and domestic abuse, discrimination, inaccessible facilities, inaccessible support services or disruption of these services being disproportionately more likely to put their lives at risk, risk of being confined to segregated, institutional settings, and in some cases pre-existing health conditions which leave them more at risk of developing serious illness or dying.
EU legislation obliges member states to identify persons with disabilities in reception and detention centres, but there is a lack of formally defined procedures to identify and support persons with disabilities. Many are identified on an informal or ad hoc basis, or late in the procedure.
Lack of data dissagregated by disability, gender and age means that it is not possible to correctly assess the situation.
Lack of necessary support and assistance to persons with disabilities, in the reception centers, and during the asylum-seeking procedure.
Especially women and children with disabilities at heightened risk of violence, including sexual and domestic abuse.
As a state party to the UN Convention on the Rights of Persons with Disabilities (CRPD), the EU and all its Member States are obliged to provide persons with disabilities, including refugees with disabilities with the same range and quality of support services, including health care as the ones available to persons without disabilities. This was recommended by the UN Committee on the Rights of Persons with Disabilities to the EU in 2015.
EDF’s recommendations for the new Pact on Migration and Asylum are:
• explicitly refer to the UN Convention on the Rights of Persons with Disabilities, its Article 11 on situations of risk and humanitarian emergencies, the Global Compacts on Refugees and Migration and follow up on the recommendation on refugees with disabilities received by the CRPD Committee
• collect data disaggregated by disability, gender and age of refugees and asylum seekers
• identify refugees and asylum seekers with disabilities, chronic illnesses and their families when arriving to the European Union as to properly plan and manage their reception and to guarantee they receive the necessary support and assistance in the reception centers and during the asylum-seeking procedure
• ensure that all mainstream support services to refugees and asylum seekers are accessible and inclusive to persons with disabilities and their families
• ensure that refugees and asylum seekers with disabilities and chronic illnesses have access to inclusive education, health care, decent living conditions, accessible housing and support to live in the community
• ensure that refugees and migrants with disabilities have access to integration programmes, language and digital competency training and to the necessary technical equipment, as to be able to make decisions for their own lives
• policies on family reunification need to be accessible and inclusive to the needs of persons with disabilities, as its high requirements and short deadlines do not take into account that persons with disabilities need more time to access services and complete the process
• include the rights of persons with disabilities in every element of the EU's approach to refugees and asylum seekers, including in the responses to and recovery from COVID-19
• meaningfully involve and consult with persons with disabilities and their representative organisations in designing, implementing and evaluating the New Pact on Migration and Asylum and any related initiatives, including on COVID-19
Read full responseResponse to Sustainable and Smart Mobility Strategy
29 Jul 2020
Smart and sustainable mobility will contribute to a more connected and fairer Europe. When investing in intelligent transport systems or focusing on greener transport, measures need to be taken to ensure accessibility for persons with disabilities. Accessibility is a right enshrined in Article 9 of the UN Convention on the Rights of Persons with Disabilities (CRPD), signed and ratified by the EU and all Member States. Accessibility is a right in itself but also a precondition for accessing other rights. Where our transport systems and other environments are inaccessible, 100 million Europeans are excluded from equal participation in society. Accessibility will become even more important in the coming years with demographic change in Europe.
Measures to ensure accessibility include the construction and renovation of transport infrastructure and vehicles, the development of multi-modal transport terminals, the development of strategies such as the Sustainable Urban Mobility Plans (SUMPs), investment in connected mobility including Intelligent Transport Systems and real-time passenger information, allocating the necessary EU funding under programmes such as the Connecting Europe Facility or the Structural Funds, and other measures.
To allow passengers with disabilities to make sustainable choices such as switching from using a private car to rail travel, special attention shall be paid to making rail travel accessible and affordable for everyone.
Connectedness, multimodality, and integrated mobility planning are very important to allow everyone to travel independently and spontaneously. It is vital that accessibility is ensured from the very first step of the conceptualization and development of sustainable solutions, as experience and studies have shown that ensuring accessibility from the start reduces costs and leads to a better outcomes for everyone. So, persons with disabilities should be included at all levels of planning and development of initiatives, and measures should be put in place to ensure accessibility and inclusiveness of participation.
For further information, see:
EDF Position Paper on Inclusive Green Deal: http://www.edf-feph.org/eu-green-deal
EDF Recommendations on transport exit measures in light of COVID-19: http://www.edf-feph.org/newsroom/news/edf-recommendations-exit-measures-transport-services-light-covid-19
Read full responseResponse to Delivering for children: an EU strategy on the rights of the child
27 Jul 2020
In 2019 the EU counted around 68 million of children below 15 (Eurostat, 2020). Yet, there is total lack of data on the number of boys and girls with disabilities.
Some of the existing data indicates that in 2017, about 5% of EU families with children had a child or children with disabilities (Eurostat, ilc_hch13). As much as 9.4% of girls and young women and 7.4% of boys and young men aged 16–24 had a disability (Eurostat, Health variables of EU-SILC, 2017).
In most EU countries, children with disabilities con¬tinue to be institutionalised, segregated in special schools and are victims of violence and abuse, in and outside the family setting. Despite the disproportionate risks that they face, children with disabilities have been given very little consideration in national or European child rights legislation.
The European Disability Forum, umbrella organisation defending the rights of over 100 million persons with disabilities in the EU, calls the Commission to include the following issues in the Strategy for Children Rights 2021-2024:
- Reference & compliance with the UN Convention on the Rights of Persons with Disabilities (CRPD): the Strategy must refer to the CRPD ratified by the EU and all member states. It must be CRPD compliant, advance the rights of children with disabilities and implement the 2015 recommendations of the CRPD Committee.
- Data collection: the EU and member states must urgently collect data on children with disabilities, including those living in institutions; where general data is collected, it should be disaggregated by disability, gender and age.
- Consultation with children with disabilities: in the preparation, design, implementation and monitoring of the strategy, the Commission must consult organisations of persons with disabilities.
- Access to inclusive education and recreational opportunities: the Strategy must include actions to ensure access to inclusive education to all children with disabilities in the EU, including to the European schools and from pre-primary education onwards. Children with disabilities are children first and foremost and have the right to family life, social inclusion and the full range of leisure, recreation, sport and cultural activities as other children. In all these actions, the EU must take specific measures if needed to ensure their full inclusion.
- Ending child poverty: households with children with disabilities, especially single-parent and female-headed ones, are more likely to face poverty (EIGE, 2019). The Strategy must address the specific difficulties face by families with children with disabilities so they can grow up in decent and dignifying living conditions.
- Living in the community: children with disabilities continue to be institutionalised (EIGE, 2019). The Strategy must ensure that children with disabilities can grow up in the community. This should include measures to develop support services for children with disabilities and their families in local communities, including early assessment, health care, (re-)habilitation and other specific support measures, and foster desinstitutionalisation.
- Protection against violence: the Strategy must ensure that the actions on protecting children against violence specifically address the needs of children with disabilities and the specific issues faced by them, including abuse in institutions and in the family settings, and the forced sterilisation and contraception faced specifically by female adolescents/youth with disabilities. The Strategy should align itself with the Gender Equality Strategy and the Victims’ Rights Strategy in calling the EU and member states to ratify the Council of Europe Convention on preventing and combating violence against women and domestic violence (Istanbul Convention).
- Mainstreaming: the intersectional discrimination and specific issues faced by children with disabilities should be included in all areas addressed by EU strategies, including external policies.
Read full responseMeeting with Jutta Urpilainen (Commissioner) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and
28 May 2020 · Roundtable with Civil Society (NGOs)-The EU global response to COVID-19
Meeting with Nicolas Schmit (Commissioner) and
29 Apr 2020 · Videoconference meeting on social support care service and COVID-19
Meeting with Dubravka Šuica (Vice-President) and
29 Apr 2020 · Social Services in Europe, Statutory Duties of Public Social Services, Explanation, Impact & challenges of COVID-19, Elderly, Role of the EU, Rights of persons with disabilities, social dialogue & cross-sectoral social dialogue
Meeting with Stella Kyriakides (Commissioner) and SGI Europe and
29 Apr 2020 · VC meeting on the Impact of COVID-19 on Social Services and the risks for persons in vulnerable situations
Response to Revision of Alternative Fuels Infrastructure Directive
16 Apr 2020
Especially the accessibility of charging stations for electric vehicles and mobility devices will become more important in the coming years, also in the light of the EU Green Deal.
The key thing to consider is the direct interaction between an individual and the electric vehicle charging point. For example its height and position – it is important that the charging equipment is reachable for all, including if people are unable to stand. Hence, it needs to be reachable for those who are sitting down and should be standing freely. In addition, the use of any plug is important. This needs to be easily usable by those with less strength or restricted movement in their limbs.
The height and accessibility of any screen is also important and similar considerations need to apply. In addition, the size of the font on the screen is important and there should be the possibility of making this larger, if necessary. The possibility of users hearing instructions – so for there to be the possibility of audio, as in bank cash machines – is also important. Ideally, the information should be perceivable by at least two sensory channels.
These considerations will become important, particularly if electric charging infrastructure will be self-service. In addition, if there are websites and apps involved, these should similarly be accessible according to Directive 2016/2012 and Directive 2019/882.
The above considerations should be applied to all electric vehicle charging points, not just those in public places. For example, if there are charging points in rental accommodation, it is not known whether the next occupant will need an accessible charging point or not. Furthermore, it is also not enough to have one accessible charging point per x number of points as they have to be distributed evenly in public places, so ALL charging points should be accessible to persons with disabilities and so should be the labelling and instructions.
In order to ensure coherence on EU level and to make sure that all persons with disabilities in the EU have the same opportunities and access there should be EU level legislation governing this. National plans or measures are not sufficient as they will end up in diverging measures that can be confusing and inconsistent. It will also be helpful to allocate specific EU funding for this to ensure that compliance by the Member States with the Directive is high.
To provide technical guidance, there is already a European Standard (EN) on ‘design of all’ (EN 17161:2019). A reference to these should be included in the Directive. Alternatively, the Commission could request that a specific, harmonised accessibility standard be developed for electric vehicle charging points. In addition, if electric vehicle charging becomes more of a service-based model involving self-service terminals, the EU Accessibility Act (Directive (EU) 2019/882), which covers accessibility requirements for products and services, could apply. The Directive should also make reference to the UN Convention on the Rights of Persons with Disabilities. It currently does not, even though the Convention was in force when the Directive was adopted. The EU is obliged to act in line with the Convention.
To sum up, persons with disabilities have not been explicitly mentioned in the text and we were not consulted on the Directive before. But there is no doubt that it is important to include accessibility of charging points, e.g. for electric vehicles and other mobility devices, and the accessibility of labeling and information, explicitly in the text and link it to other EU initiative as well as the UN Convention on the Rights of Persons with Disabilities.
Read full responseResponse to EU Strategy on victims' rights (2020-2024)
1 Apr 2020
The European Disability Forum (EDF) welcomes the commitment of the European Commission to protect the rights of victims in the European Union (EU) and its proposal for an EU Strategy on victims’ rights for 2020-2024.
Despite the legal framework on victims’ rights developed in the last two decades by the European Commission, many victims in the EU are not granted their rights. Even when measures are available, they are often inaccessible to victims with disabilities. Persons with disabilities face difficulties reporting crimes, accessing support measures and services, and exercising their rights to a criminal proceeding and support throughout.
Physical and/or communication barriers make crimes difficult to report, and myths and stereotypes prevent persons with disabilities from being considered credible by the police and the criminal justice system. Persons with disabilities are often not aware of the legal remedies available, or are afraid of stigmatisation and victimisation. States also fail to provide victims’ services accessible to persons with disabilities, from lack of (or inaccessible) information on their rights to inaccessible helplines and shelters. In the criminal proceeding itself, persons with disabilities often do not receive appropriate procedural accommodation and, in many instances, court buildings are not accessible to people with reduced mobility.
Women with disabilities are particularly affected as they are more at risks of being victims of crimes, including sexual and domestic violence, and excluded by the justice system.
To the break barriers faced by victims with disabilities, EDF calls for the adoption of an ambitious and inclusive EU strategy on victims’ rights (2020-2024).
In order to have a meaningful impact, the strategy on victims’ rights must:
1. Ensure participation of civil society in its design, implementation and monitoring, including victim support organisations and organisations of groups over-represented in victim groups, such as organisations of persons with disabilities, including those of women with disabilities.
2. Strengthen its legal basis by referring and aligning with the rights enshrined in the UN Convention on the rights of Persons with Disabilities, the Council of Europe Convention on preventing and combating violence against women and domestic violence (Istanbul Convention) and other key international instruments.
3. Prioritise implementation and evaluation of relevant EU laws, including by developing key tools for implementation and regular evaluation mechanisms.
The Strategy should also include specific provisions to ensure the rights of victims with disabilities, as a specific group of victims. In particular, it should look at:
• Guaranteeing accessible information and communication prior, during and after criminal proceedings;
• Providing adequate and accessible services to victims with disabilities;
• Ensuring active participation of victims with disabilities at all stages of the criminal proceeding;
• Training practitioners on the rights of the most marginalised victims
• Sanctioning violation of victims’ rights;
• Collecting disaggregated data on victims of crimes.
EDF detailed recommendations are available in the position paper attached.
Read full responseResponse to European Year of Rail (2021)
30 Mar 2020
The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) recognizes the importance of accessibility in enabling persons with disabilities to fully enjoy all human rights and fundamental freedoms, accessible transport and infrastructure being one of them. As a State Party to the UN CRPD, the EU has clear obligations to ensure that the rights of persons with disabilities are fully respected. Article 9 of the UN Convention lists the appropriate measures to ensure persons with disabilities access, on an equal basis with others, to transportation among other crucial issues. Furthermore, accessible transport is a vital precondition for persons with disabilities to exercise of one of the four freedoms granted by the EU Treaties - free movement of citizens within the EU.
As a sustainable, innovative and safe mode of transport rail travel is one of the preferred modes of transport by many persons with disabilities. However, millions of persons with disabilities are still unable to exercise their right to free movement through spontaneous and independent rail travel on equal basis with others due to accessibility barriers and weak protection of their rights as passengers.
We welcome the European Commission’s proposal to declare 2021 ‘European Year of Rail’ to promote rail transport as part of its strategy for sustainable and smart mobility under the European Green Deal and in support of EU’s commitment to the United Nations 2030 Agenda and the sustainable development goals. We hope the European Union and Member States will take this opportunity to further mainstream accessibility of rail transport and advance rights of passengers with disabilities, including youth and older persons with disabilities, and the wider demographic of persons with reduced mobility. Therefore, we want to highlight that the European Year of Rail should have strong focus on passengers. We also emphasize the need to ensure that all campaigns, programmes, projects, and initiatives within the scope of European Year of Rail are accessible to persons with disabilities at Union and Member State-level, as well as in external action.
We look forward to European Year of Rail to highlight the importance of accessible, spontaneous and independent rail travel, to promote best practice and advance accessibility and equal right to travel by persons with disabilities – a growing demographic that is motivated to contribute to EU’s climate-neutrality agenda but is largely excluded from this engagement due to existing gaps in rail accessibility and passenger rights policies and implementation of those in practice. We hope to work with the European Commission on the implementation of the European Year of Rail at EU-level and on the meaningful engagement of our members at national-level.
Please see our detailed position attached, including contact details for any follow-up.
Read full responseMeeting with Jutta Urpilainen (Commissioner) and International Disability and Development Consortium
5 Mar 2020 · Discussion on inclusive international partnerships
Meeting with Adina-Ioana Vălean (Commissioner) and
4 Mar 2020 · The rights of persons with disabilities in transport and mobility files
Meeting with Monika Ladmanova (Cabinet of Vice-President Věra Jourová)
25 Feb 2020 · the rights of persons with disabilities
Meeting with Mónica Silvana González (Member of the European Parliament)
6 Feb 2020 · Disability
Meeting with Janez Lenarčič (Commissioner) and
6 Feb 2020 · The situation of persons with disabilities in the context of humanitarian aid and civil protection
Response to Gender equality in the EU
30 Jan 2020
Women with disabilities constitute 16% of the total population of women in the European Union, and 60% of the overall population of 100 million persons with disabilities.
Yet, despite being more than 60 million (equivalent to the population size of Italy), women and girls with disabilities continue to face multiple and intersectional discrimination in all areas of life, including, socio-economic disadvantages, social isolation, violence against women, forced sterilisation and abortion, lack of access to community services, low-quality housing, institutionalisation, inadequate healthcare and denial of the opportunity to contribute and engage actively in society. Women with disabilities are also two to five times more likely to face violence.
The status of women and girls with disabilities is not only worse than that of women without disabilities, but also worse than that of their male peers. This is especially so in rural areas with fewer services and opportunities for this group than in urban environments.
The EU Gender Equality Strategy 2020-2024 if ambitious and sufficiently resourced has the potential to improve the rights of women and girls. The EU can play a very important role in combating prejudice and stereotypes by ensuring visibility of women with disabilities in all processes. The launch of a new gender equality strategy is an opportunity to ensure that women with disabilities are visible, for instance shown in pictures and speaking at the launch and other related events.
The Strategy should be based on the fundamental rights of women and men in the EU, as established in the EU treaties, the Fundamental Rights Charter and the UN Convention on the Rights of Persons with disabilities to which the EU and all its member states are party.
Finally, the Strategy should be consistent with EU external action and the Sustainable Development Goals. It should ensure that the EU and its member states commit to the realisation of women and girls’ rights, accelerate the implementation of existing legislation and the adoption of new instruments, and invest in women’s organisations and organisations of women with disabilities. It should promote the ratification of the Istanbul Convention, its swift implementation and adoption of further EU legislation to combat violence against women and girls.
We call the European Commission to include in the Strategy specific actions to protect the gender equality rights of women and girls with disabilities. Our recommendations are available in the document attached.
Read full responseMeeting with Iratxe García Pérez (Member of the European Parliament)
22 Jan 2020 · Political priorities of people with disabilities
Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)
22 Jan 2020 · Green Deal/Sustainability and accessibility
Meeting with Nora Bednarski (Cabinet of Commissioner Helena Dalli)
7 Jan 2020 · Future EU disability policy including UN CRPD implementation, disability mainstreaming and follow-up to the 2010-2020 disability strategy.
Meeting with Helena Dalli (Commissioner)
12 Dec 2019 · Meeting on the disability strategy
Response to Contract summary template for electronic communications service providers
6 Sept 2019
Please find it in the attachment.
Read full responseResponse to Evaluation of rights of persons with disabilities and with reduced mobility (PRM) when travelling by air
5 Sept 2019
The European Disability Forum is an EU umbrella organization that represents the interests of 80 million Europeans with disabilities. EDF is a unique platform which brings together representative organisations of persons with disabilities from across Europe. We represent air passengers with disabilities and we have been one of the main stakeholders of the Regulation since its creation.
Since its adoption in 2006, the Regulation on air passengers’ rights for persons with disabilities has been very successful in raising awareness of passengers’ rights and established the principle of assistance at airports. This is highly appreciated by persons with disabilities and their representative organisations. The Regulation is also one of the "success stories" of the European Union, which has shown EU citizens the importance of the EU.
However, the Regulation always left a few issues untouched that are of extremely high importance for persons with disabilities. 13 years after it was originally adopted, EDF sees the urgent need to fill those legislative gaps that still allow for discrimination of persons with disabilities when travelling by air. The current assessment is therefore a welcome opportunity for EDF to voice our concerns and highlights the most urgent issues that should be tackled in a possible future revision of the Regulation.
Here are the main points which should be looked at in the evaluation:
DENIED BOARDING: Sadly, even in 2019, persons with disabilities are still denied boarding because of their disability, even though they hold a valid ticket and they have indicated their need for assistance in advance to the airline. This happens mainly because of “safety reasons” but are usually not justified or explained sufficiently. But also seemingly random decisions are taken which are not based on any facts but purely prejudices.
MOBILITY EQUIPMENT: Another persisting problem that needs to be covered by the Regulation is the damage, loss, and destruction of mobility equipment for persons with disabilities by the luggage handling services. In fact, one of the crucial points here is that mobility equipment such as wheelchairs, walkers, mobility scooters, crutches, or similar are not luggage. Mobility equipment is often made-to-measure and can be very costly to replace. One also has to keep in mind that mobility equipment is crucial for passengers with reduced mobility or a disability to remain independent in their daily lives and cannot be replaced easily.
BOOKING AND INFORMATION: Currently, the Regulation does not mention anything about the booking procedures and the communication between the different parties involved. Since booking is usually done via a travel agent or the airline, but assistance is provided by the airport and often sub-contracted to a third party, this often creates problems. The passenger, for whom the information flow is not transparent and clear, is at the receiving end of all the problems resulting from miscommunications. Booking procedures for PRM assistance are often complicated and add an extra burden on passengers. Airlines and airports often complain that passengers do not pre-notify their need for assistance, but making the procedure easier could help.
Other issues that need to be looked at more closely are amongst others the quality of assistant services and equipment such as wheelchairs or ambulifts, the recognition of assistance dogs/animals, choice of seating, accessibility and efficacy of the complaints procedure, and the assistance provided on board. Also the general accessibility of the buildings and the transport vehicles and infastrucutre should be included in the evaluation, not just the assistance services.
A more detailed position paper with examples and recommendations will follow.
Read full responseResponse to Evaluation of rights of passengers when travelling by sea and inland waterway
16 Jul 2019
The European Disability Forum (EDF) is an umbrella organisation of persons with disabilities that defends the interests of over 80 million Europeans with disabilities. We are a unique platform which brings together representative organisation of persons with disabilities from across Europe. We are run by persons with disabilities and their families and we are a strong, united voice of persons with disabilities in Europe.
EDF believes that all people have the right to enjoy seamless, accessible and independent travel. This is in accordance with the EU Treaties that guarantee the right to free movement for all citizens as well as Article 9 of the United Nations Convention on the Rights of Persons with Disabilities. Despite this fact, persons with disabilities can still not fully benefit from this right as the transport system throughout the EU remains largely inaccessible.
The EU's set of passengers' rights Regulations is a very important step towards independent travel and has already brought about much positive change over the past 10 years. However, those Regulations do not go far enough to provide for transport on an "equal basis with others" as it is demanded in the UN Convention on the rights of persons with disabilities, which has been ratified by the EU itself as well as all its Member States.
Ferry boats often remain inaccessible in practice, assistance is not always provided, reservations are still refused to persons with disabilities for alleged safety reasons (or without any reason), ports are not barrier-free and lack accessible information systems for visually impaired persons or for persons who are deaf or hard of hearing. Also, the Regulation does not cover leisure boats or cruise ships, both of which are often used by persons with disabilities and older persons with reduced mobility because they prefer this leisure activity instead of walking.
Some concrete examples of complaints we receive are about the health and safety risk of persons with disabilities having to stay on the car deck during the journey because of inaccessible vessels; or persons with disabilities are "stowed" in a separate room away from other passengers because of the lack of access. If lifts are installed, they are often out of order. Another concrete complaint from Italy was that staff who are designated to assist PRMs on board of the vessel "disappear" when help is needed or they refuse to help PRMs because they are "too heavy".
But problems have also been reported in Sweden, where persons with cognitive disabilities have problems finding their way around the complex port or ship where information is often complicated and confusing. Persons with disabilities are also still denied travelling even though they are holding valid tickets: a deaf family from Belgium was denied boarding because of their disability and they were told they could only travel with a hearing assistant.
Therefore, Regulation 1177/2011 is very important for EDF but we think that it should go even further in order to properly implement the provisions of the UN Convention. We fully support a strengthening of this Regulation to make travelling easier for persons with disabilities and to facilitate the enforcement of the rights given in the Regulation.
Read full responseResponse to Evaluation of rights of passengers in bus and coach transport in the EU
16 Jul 2019
The European Disability Forum (EDF) is an umbrella organisation of persons with disabilities that defends the interests of over 80 million Europeans with disabilities. We are a unique platform which brings together representative organisation of persons with disabilities from across Europe. We are run by persons with disabilities and their families and we are a strong, united voice of persons with disabilities in Europe.
EDF believes that all people have the right to enjoy seamless, accessible and independent travel. This is in accordance with the EU Treaties that guarantee the right to free movement for all citizens as well as Article 9 of the United Nations Convention on the Rights of Persons with Disabilities. Despite this fact, persons with disabilities can still not fully benefit from this right as the transport system throughout the EU remains largely inaccessible.
The EU's set of passengers' rights Regulations is a very important step towards independent travel and has already brought about much positive change over the past 10 years. However, those Regulations do not go far enough to provide for transport on an "equal basis with others" as it is demanded in the UN Convention on the rights of persons with disabilities, which has been ratified by the EU itself as well as all its Member States.
Coaches and bus terminals often remain inaccessible in practice, assistance is not always provided, ,there is a lack of accessible information systems for visually impaired persons or for persons who are deaf or hard of hearing. Also, the Regulation does not cover shorter distance journeys or urban buses, both of which are often used by persons with disabilities and older persons with reduced mobility especially because they are reduced in their mobility.
When consulting EDF's members on the implementation of the Regulation, significant shortcomings in both the scope and in the implementation became obvious. While some of the issues might have been resolved by now it is impossible to tell because Disabled Persons' Organisations don't have the capacity to check on every single bus station in the country and on all bus and coach services.
Some examples of the main problems: the "accessible" bus terminals that had to be designated under the Regulation are not really accessible or, in some large countries such as Finland, are only located in the South. In many Member States, including Portugal for example, accessibility of the vehicles is still a major issue.
Therefore, Regulation 181/2011 is very important for EDF but we think that it should go even further in order to properly implement the provisions of the UN Convention. We fully support a strengthening of this Regulation to make travelling easier for persons with disabilities and to facilitate the enforcement of the rights given in the Regulation.
Read full responseMeeting with Frans Timmermans (First Vice-President)
20 Mar 2019 · EU policies concerning persons with disabilities and future approach
Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc) and AGE Platform Europe
31 Jan 2019 · Transport matters
Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)
24 Jan 2019 · Meeting on disability related policies, legislation and the EU budget
Response to Inventory of assets for railway infrastructure related to persons with reduced mobility (PRM)
18 Nov 2018
EDF very much agrees with the general purpose of the ERA Recommendation and supports the creation of the Inventory of Assets database. However, we ask for a speedy and complete collection of the data within shorter deadlines than proposed in order to make the tool useful for the implementation of the TSI-PRM and for the use of passengers.
The proposed deadlines are far too long and will make the IoA tool already outdated by the time it will enter into force. Therefore, EDF objects to the transition time and would like to ask for a faster implementation of the IoA.
Read full responseResponse to European Disability Strategy (2010-2020) – evaluation
25 Oct 2018
- EDF welcomes a thorough evaluation of the current European Disability Strategy (EDS), in order to build the future European Disability Strategy post 2020.
- In developing the next EDS, it is important to consider the following:
o The planning and development of the next strategy should directly involve persons with persons with disabilities through their representative organisations (DPOs), in the form of a structured dialogue; while an online consultation is helpful, it is also very important to foresee inclusive, accessible face-to-face meetings with DPOs to discuss priorities for the 10-year period; DPOs’ views, in line with the Article 4.3 and 3.3 general comment from the CRPD committee, should be given specific attention. It will also be important, in planning the online element of the consultation, that the questions are developed in consultation with organisations of persons with disabilities so they are targeted and relevant to their daily lives, and to the CRPD.
o The recommendations from the CRPD committee should be fully included in the process. Fundamentally, the CRPD committee called for a Comprehensive Strategy for the implementation of the CRPD for all institutions (see link: https://www.eesc.europa.eu/resources/docs/un_concluding-observations-on-the-initial-report-of-the-european-union.pdf);
o EDF’s Resolution on the Next European Disability Strategy, adopted at the 4th European Parliament of Persons with Disabilities, should be used as a reference (see link: http://www.edf-feph.org/sites/default/files/final_resolution_on_european_disability_strategy_0_0.pdf);
o It is important to include all Commission focal points and other EU institutions, the EU Independent Monitoring Framework, so the strategy is a comprehensive disability rights strategy for the EU, as recommended by the CRPD committee;
o In particular, the European Parliament’s report on the EDS is important. This was a collective input from the EP, with structured involvement of DPOs (see link: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+REPORT+A8-2017-0339+0+DOC+PDF+V0//EN);
o The EESC will also submit an own initiative report on the EDS, which should also be used as a reference during the consultation;
o The system of structured dialogue at the EU level should be reviewed and adapted to act as structured dialogue on the CRPD.
o The review of the strategy should also incorporate an evaluation of the EU’s global development, humanitarian and human rights work, including in its overseas European Delegations (their inclusiveness accessibility and mainstreaming in their programmes)
- Part of the consultation should be focused on how changes to the upcoming Multiannual Financial Framework can present new opportunities for implementing the CRPD and achieving the objectives of a future strategy.
- The review of the Strategy should also foresee how the CRPD can be fully incorporated in key EU Initiatives such as the European Pillar of Social Rights and the Digital Single Market, and UN initiatives such as the Sustainable Development Goals.
Read full responseMeeting with Marianne Thyssen (Commissioner)
12 Jul 2018 · European disability policy
Response to Commission implementing decision on establishing a model accessibility statement under the WAD
15 Jun 2018
On behalf of the European Disability Forum, please see Part 2 of the document attached.
Read full response15 Jun 2018
On behalf of the European Disability Forum, please see Part 1 of the document attached.
Read full responseMeeting with Christos Stylianides (Commissioner)
28 Nov 2017 · Disabilities - Humanitarian Aid
Response to Recast of Regulation (EC) 1371/2007 on rail passengers' rights and obligations
17 Nov 2017
According to our assessment, the new proposal strengthens the rights of persons with disabilities and of persons with reduced mobility (PRMs), notably by aligning more closely with the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). Therefore, the European Disability Forum was happy to hear about the recast of the Regulation to improve some aspects of the text, although some provisions still need to be improved, especially the clause that requires pre-notification 48 hours in advance.
EDF welcomes the recast of this Regulation and in particular supports the introduction of the following points:
• A clear reference to the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) has been introduced
• There are no exemptions for disability-related provisions (Art. 2)
• If ticketing machines are not accessible the tickets can be purchased free of charge on board of the train (Art. 10)
• re-routed and alternative transport services have to be accessible (Art. 16)
• contingency plans for bigger stations have to be drawn up and include persons with disabilities (Art. 18)
• assistance has to be available at all times when trains are operating (Art. 23 – 24)
• staff has to be trained on disability issues (Art. 26)
• the competences of the National Enforcement Bodies are better defined and include specific tasks (Chapter VII)
However, EDF regrets deeply that
• The 48-hour rule to book assistance remains (Art. 24)
• It has not been clarified that the booking of assistance needs to be free of charge (Art. 22)
• The requirements for staff training are not more comprehensive and detailed
• The enforcement powers of National Enforcement Bodies (NEBs) for individual complaints have not been significantly strengthened and/or harmonized
Read full responseMeeting with Corina Crețu (Commissioner)
18 Jul 2017 · Impact of Cohesion Policy changes on the persons with disablities.
Meeting with Davinia Wood (Cabinet of Commissioner Christos Stylianides), Themis Christophidou (Cabinet of Commissioner Christos Stylianides), Zacharias Giakoumis (Cabinet of Commissioner Christos Stylianides) and
28 Jun 2017 · Taking into account the needs of people with disabilities in humanitarian action
Meeting with Günther Oettinger (Commissioner)
9 Mar 2017 · diversity & inclusion
Meeting with Christos Stylianides (Commissioner)
21 Jun 2016 · Integration of disability issues in humaitarian aid
Meeting with Violeta Bulc (Commissioner) and
26 Jan 2016 · Meeting EDF representatives
Meeting with Marianne Thyssen (Commissioner)
29 Oct 2015 · EU disability policy priorities
Meeting with Marianne Thyssen (Commissioner)
20 Apr 2015 · European Disability Policy
Meeting with Neven Mimica (Commissioner)
5 Mar 2015 · The inclusion of persons with disabilities in lower and middle income countries through Commissioner’s work over the next 5 years.
Meeting with Věra Jourová (Commissioner) and Amnesty International Limited and
16 Feb 2015 · Equal Treatment Directive
Meeting with Frans Timmermans (First Vice-President) and Amnesty International Limited and
9 Jan 2015 · Roundtable with NGO's on fundamental rights
Meeting with Věra Jourová (Commissioner) and Human Rights Watch and
9 Jan 2015 · Roundtable with NGOs on fundamental rights and non-discrimination