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European Platform for Rehabilitation

EPR

EPR's motto is Learning and Innovating Together.

Lobbying Activity

Response to The new Action Plan on the implementation of the European Pillar of Social Rights

3 Sept 2025

EPR, the European Platform for Rehabilitation, is a community of public and private not-for-profit service providers working with people with disabilities in 18 countries, and committed to high quality service delivery. EPRs mission is to build the capacity of its members to provide sustainable, high-quality services through mutual learning and training. In the past, EPR monitored and the European Pillar of Social Rights (EPSR), its 2021 Action Plan (AP), as well as its resulting initiatives, such as the European Care Strategy , the European Disability Strategy , and the Social Economy Action Plan . Below, EPR assesses the 2021 EPSR Action Plan, and presents priorities and proposals that should be included in the 2025 EPSR AP. (1) EPRs assessment of the 2021 EPSR AP: The European Pillar of Social Rights brought a compass to social policy in the EU under which important policy frameworks were developed. Key achievements included the Strategy for the Rights of Persons with Disabilities (Principle 17), to further implement the UNCRPD, which underwent important improvement from the previous strategy, and from which EPR welcomes its flagship initiatives; The European Care Strategy (Principles 11 and 18), which was key to address the care needs from childhood until the older age and which calls for quality services across the EU, and which must be further implemented by Member States considering that such services remain out of reach for many people; the EU AI Act (Principle 10) banning AI presenting unacceptable risk, including AI exploiting the vulnerabilities of persons due to their age, disability and socio-economic situation, which should be further reflected upon in the 2025 EPSR AP. (2) EPRs priorities and proposals: The 2025 EPSR AP must address the ongoing challenges of the sector of public and private not-for-profit services for persons with disabilities. Services for persons with disabilities need to adapt to evolving trends, including increased mental health needs, an ageing population, rapid service provision changes due to ICT advancements and AI, a transition towards community-based services, insufficient public funding, understaffing of key trained professionals, and a lack of training for staff providing services. According to the UNCRPD Committee, the EU lacks a dedicated strategy for the provision of services for persons with disabilities, there are widespread inequalities in the availability, affordability and quality of services, and Member States budgets exacerbate the services shortage. The 2025 EPSR AP should align with the UNCRPD by proposing new initiatives for the Disability Strategy for 2025-2030, supporting service providers to ensure top-quality, available and affordable services for persons with disabilities (Principle 17). Regarding the Union of Skills and the Quality Jobs Roadmap, it should be clarified how these two plans interact with the EPSR AP (i.e. if they are embedded within it). Moreover, the Union of Skills should consider the inclusion of persons with disabilities in all initiatives, and the role of service providers in supporting persons with disabilities to acquire skills (incl. when implementing the Basic Skills Action Plan, the STEM Education Strategic Plan, and the European Strategy for Vocational Education and Training) (Principle 1). The Quality Jobs Roadmap should ensure the quality of jobs for persons with disabilities, as well as in the sector of services for persons with disabilities (Principle 5). As a member of Social Services Europe, EPR would support the inclusion of an EU-wide European Social Services Action Plan or Initiative. New actions under the EPSR Action Plan propose initiatives to protect employment opportunities in the context of exponentially evolving AI, explore the accessibility opportunities unlocked by AI, and ensure its ethical use. The EPSR Social Scoreboard should provide more disaggregated data on disability.
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Response to Quality Jobs Roadmap

29 Jul 2025

EPR, the European Platform for Rehabilitation, is a community of service providers working with people with disabilities committed to high quality service delivery. EPRs mission is to build the capacity of its members to provide sustainable, high-quality services through mutual learning and training. We welcome the proposal for a Quality Jobs Roadmap and call the European Commission to ensure it guarantees the quality of jobs for persons with disabilities, as well as in the sector of services for persons with disabilities. People with disabilities often experience inequalities when it comes to employment, (e.g. in 2024 the disability employment gap reported by Eurostat was 24 pp). According to the Union of Skills Communication and the Eurofound report Living and working in Europe, engaging persons with disabilities represent an untapped potential in the EU labour force. Persons with disabilities face barriers to employment such as structural accessibility issues, gaps in inclusive employment policies, disability-related stereotypes and obstacles in developing their skills. To ensure the quality of jobs for persons with disabilities, EPR recommends: (i) quality jobs for persons with disabilities could be defined as those that are remunerated and in the open labour market, which provide reasonable accommodation and support for each employee, and which do not represent the loss of disability allowances once a person with a disability starts a job; (ii) a rights-based approach to disability within the Quality Jobs Roadmap, which recognises the diversity of persons with disabilities; (iii) access to quality education and training that recognises the skills and/or knowledge of persons with disabilities; (iv) openness in the mainstream labour market, with employers understanding the added value of a diverse workforce; (v) tackling stereotypes regarding persons with disabilities and work; (vi) enhancing the relationship between service providers and persons with disabilities, through a solution-oriented and strengths-based approach addressing individual needs and aspirations; (vii) offering financial and legislative support to employers; (viii) strengthening partnerships between service providers and employers, to improve the matching between services, the candidates skills and the offers for placement, and facilitating ongoing support for employees with disabilities; (ix) Employers flexibility to choose the model of support of their employees, in coordination with their employees with disabilities; and (x) access to a full range of support services to enable general inclusion, including childcare, transport and support for independent living. Currently the sector of services for persons with disabilities must adapt to evolving social needs, such as rapid changes in service provision due to ICT advancements and AI, a transition from segregated institutional settings towards community-based services, increased mental health needs and an ageing population with greater long-term care support needs. Therefore, to guarantee the quality of jobs in the sector of services for persons with disabilities, EPR calls for: (i) increased public funding for services, especially in rural areas; (ii) mitigating the understaffing of the sector, where there are severe shortages of trained psychologists, occupational therapists and personal assistants; (iii) increased training of staff, especially considering digital and technological innovations; and (iv) improving the working conditions of the sector to attract and retain workers and ensure the continuity of high-quality support.
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Meeting with Ana Carla Pereira (Director Justice and Consumers)

20 Mar 2025 · Exchange of views on the European Platform for Rehabilitation’s contribution to the disability strategy, the state of play of the strategy, the calls for project proposals for the EU level NGOs, discussion on the future MFF

Meeting with Tilly Metz (Member of the European Parliament) and EUROPEAN TRADE UNION CONFEDERATION and

16 Feb 2023 · Stakeholder Exchange on COVID

Response to Developing social economy framework conditions

30 Sept 2022

EPR is a community of service providers working with people with disabilities committed to high quality service delivery. Most of EPR’s members are social economy actors, as not-for-profit social service providers, and many of them also run WISE. The text below outlines some key measures, structures and features of a legal environment EPR that believes will enable social economy organisations to flourish. Sustainable public financial support is essential for not-for-profit service providers to be able to fulfil their role and reach their full potential and should be a key element of any framework. Many social service providers struggle with staff shortages, often due to underfunding, which leads to unattractive work conditions. Social economy actors should also be supported in the provision of training for staff and volunteers, as key to provide quality services and embrace innovation. Social economy actors need to be supported by funding and investment in their green and digital transitions to ensure their effectiveness and sustainability, in terms of infrastructure, staffing and operations. Social enterprises are active in sectors that will likely go through significant changes due to digitalisation, so support for adaptation in this regard is important. Measures such as tax exemptions and subsidies for social enterprises employing people with disabilities are necessary. Support for start-ups aiming at creating a social enterprise for employment of people with disabilities is also important. Financial support should not stop as soon as an initiative is successful. Provisions that enable the granting of and access to State Aid for both wages and any additional costs linked to the provision of reasonable accommodation, such as assistive technology, should be maintained in any future state aid revision and possibilities highlighted in any framework. Support to access EU funds such as the ESF+, the Recovery and Resilience Facility and InvestEU is critical to increase the capacity in social economy organisations and deliver quality projects. Promote socially responsible public procurement (SRPP) when procurement is chosen as the best method to commission services e.g. reserved markets to boost employment for disadvantaged workers. Good practices in this domain should continue to be promoted. Additional training and awareness raising activities should be provided to ensure commissioning authorities are able to implement SRPP in their calls for tenders. National legislation should facilitate the status and operation of WISEs, taking into account that they have different needs compared to traditional companies. The sharing of good practices within WISE should be facilitated, particularly in terms of inclusive work environments, training and career development and transitions to the mainstream labour market and funding should support these. The framework must cover and promote the role and value of WISE with a focus on those that reinvest their revenues into social causes. There is also a need for raising awareness of the added value of WISE, and to educate people about the added value of employing people with a disability. Poverty traps in social protection systems that sometimes hinder access to work should be addressed. Labour laws and programmes should allow and prompt the regular labour market to be more open and flexible to evolving needs and working capacities. This includes the transition to the open labour market from WISE and the possibility to move back to WISE, without losing social rights and ensuring decent work conditions. Promote partnerships and better dialogue between actors like WISEs, NGOs, funders and regulators, through e.g. sharing of good practices, training and information workshops. EU policy information must reach the national and local level through investment in activities that promote and disseminate them. EPR also supports the response from Social Services Europe, to which it contributed.
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Response to Erasmus+ 2021-2027 interim evaluation and Erasmus+ 2014-2020 final evaluation

12 Sept 2022

The European Platform for Rehabilitation, EPR, is a network of service providers working with people with disabilities committed to high quality service delivery. Our mission is to build the capacity of our members to provide sustainable, high quality services through mutual learning and training. Our motto is Learning and Innovating together, and a key tool we use to achieve our aims is EU funded projects. Our feedback from is based on our experience to date running projects under the current funding period. We believe that the new Erasmus Plus 2021-27 has advantages and disadvantages compared to the previous seven years: Lump sums: the new approach that binds budgets to lump sums on the one hand allows the applicant to request what is really deemed necessary for each activity, thus increasing flexibility within the 3 assigned lump sums. On the other hand, the calculation of budgets relating to the different activities or to be assigned to individual partners, in the absence of standard figures to be applied, is more difficult. The disappearance of the 4 types of staff categories and of groups of countries to which different standard budgets were assigned for a single working day tends to penalize some countries. Even if under the previous funding period the set budgets per staff day varied between countries, the actual staff cost varies even more, and combined with the limit of only 3 very different lump sum budgets for the standard projects, this means that it is difficult to assign countries with high wages significant tasks in the project, and thus favours countries where the labour costs are lower. This means mainly favouring organizations based in the South and East of Europe to the detriment of those in the North and West, which risks unbalancing the partnership and of the project, and geographical balances of partnerships in general. *To help mitigate this issue, allowing the inclusion of a variety of wage levels whilst not needing to reduce or greatly increase the scope of the project proposal, we would propose 2 more levels of lump sum: 180,000€ and 325,000€* New template: compared to the previous version, the new template is more rational and clearer. The return to Work Packages has improved the clarity of the template. The possibility of dedicating a WP and a specific budget to communication and dissemination (and to distinguish it from PMI) was a significant improvement. Admin requirements before submission: The fact that the Mandates are no longer required before the submission of the project allows the coordinator to save time and unnecessary exchanges with the other partners. Misalignment between required documents and potential Audit: In the previous program, some documents had to be mandatorily collected by the coordinator and made available in case of Audit (Signatures lists, timesheets, boarding passes for in-person meetings, attendance certificates, etc.). In the current program, however, the indication on the documents to be collected is very vague. The intent to simplify (by eliminating the list of mandatory documents) has instead complicated the work of the coordinator, who does not have clarity on which documents to produce or request from partners. Continuous reporting system: The new online reporting system seems to be more complete than the old Mobility Tool. Enhanced inclusion and diversity measures: the new measures are undoubtedly a great step forward. Erasmus Plus represents one of the pillars at European level in terms of education and exchange. These new measures are important from two points of view: • They promote and facilitate the participation of the most vulnerable groups in project activities, including mobility; • They increase awareness on the issue of inclusion and diversity among the organizations participating in the projects funded by the programmed, with a potential significant impact on the education system in the EU.
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Response to European Statistical System – making it fit for the future

21 Mar 2022

EPR welcomes the opportunity to respond to this consultation. EPR believes that the European statistical system must enable the EU and Member States to fulfil their obligations under the UN Convention on the Rights of Persons with Disabilities and commitment to the 2030 Agenda, which recognises that persons with disabilities are a vulnerable group of people. UNCRPD Article 31 is increasingly important & the creation, collection, processing of data is key for decision-making: "States Parties undertake to collect appropriate information, including statistical and research data, to enable them to formulate and implement policies to give effect to the present Convention "…"The information collected in accordance with this article shall be disaggregated, as appropriate, and used to help assess the implementation of States Parties’ obligations under the present Convention and to identify and address the barriers faced by persons with disabilities in exercising their rights". Although the article refers to collection of adequate information on people with disabilities, including statistical data & research, that information generated is segmented by the “disability” variable, that States have the responsibility for its dissemination ensuring its accessibility, the EU and Member States are still a long way from fully achieving the objectives. The disability “variable” must be included in "all" the tools of the European statistical system, to ensure compliance with the convention and ensure society and policy making supports people with a disability. The incorporation of the “Disability” perspective in European statistics must be based on the social model of disability, that adaptation of social & physical environments to accommodate people with a range of functional abilities improves quality of life & opportunity for people with and without disabilities, avoiding the medical model that focuses on deficiency &/or illness as a determining factor for non-inclusion. It must have a treatment similar to gender perspective, age & nationality or country of birth, and it is essential that a consensus be reached on the identification of people with disabilities; there must be unification of criteria when measuring disability in statistics & studies. There is a consensus around the use of the battery of questions of the “Washington Group” that can be incorporated into most European statistics. The most frequent alternative is incorporation of the European minimum health module (MEHM) already present in some general statistics, 3 variables on the state of health and 4 on unmet medical care needs, among the first 3 is the Global Activity Limitation Indicator that evaluates self-perception about limitations in activity. Included in all European statistics, the flow of information on disability would massively increase. Whatever the alternative, a clear & shared consensus must be reached at European level. Transparency and accessibility must be improved. Whilst guaranteeing security and data protection, the microdata of statistics & surveys should be available to help deepen, investigate and ultimately to better understand the needs of people with disabilities in order to develop policies, programs & projects, both by public authorities and civil society actors. It is not possible to plan actions or generate effective policies with data that have a cadence of two or three years. Segmentation by disability should be ensured annually in operations such as the Active Population Survey, or in each census update. To minimize cost, the commitment to the collection of statistical information through administrative records must be realised. In countries where there is an official disability recognition document, the crossing of information from such a database with statistics & surveys should be the general practice, increasing disability statistics. With the current technological development, this is feasible & effective.
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Response to Union of Equality: European Disability Rights Strategy

12 Nov 2020

EPR Feedback on the Roadmap for the European Disability Rights Strategy This contribution does not aim to be an exhaustive set of recommendations for the future strategy, rather to highlight key issues that may not be addressed elsewhere or by other contributors, as well as to offer comments on the Roadmap itself. EPR is a community of service providers working with people with disabilities committed to high quality service delivery. EPR’s mission is to build the capacity of its members to provide sustainable, high quality services through mutual learning and training. The Roadmap states that “the new Strategy will aim at ensuring the social and economic inclusion and participation of persons with disabilities in society”. We believe that it would be helpful to stress their *active* participation. The Roadmap states that “Specific attention is required for health services, especially after the weaknesses and gaps demonstrated by the COVID-19 crisis.” In addition, significant weaknesses and gaps in *social services* were also demonstrated, especially when it came to financial and other support for services to people with disabilities, and specific attention should be paid to them as well. The roadmap states that “Assistive technologies remain expensive and internal market opportunities are underused”. Actions in the strategy should explore synergies with research programmes in this area and develop initiatives that facilitate the accessibility of AT solutions, in collaboration with AT developers and support service providers. The strategy should Mainstream quality of services throughout its actions, in line with the European Pillar of Social Rights and Voluntary European Quality Framework for Social Services. The Roadmap states “support for modernisation and consolidation of community-based support services is key”. We consider quality to be a key dimension of modernisation and should be addressed in any actions regarding this topic, and would like to emphasise its importance. We call for “support for modernisation and consolidation of *quality* community-based support services”, including through stimulating mutual learning and exchange of good practices on the implementation of article 19 and how to empower people with disabilities to exercise their right to choose. Ensure synergies with the Action Plan for the Social Economy and develop initiatives to support social enterprises employing people with a disability, helping them to adapt to changing demands and new opportunities, including the Green Deal. Develop initiatives to support partnerships with employers and their engagement in the implementation of the future strategy, and collaboration with employment support services. Promote evidence based practices that support people with a disability in the mainstream labour market, such as Supported Employment, IPS, Disability Management. Take into account the specific challenges and needs of women and girls with disabilities in all initiatives, including those addressing education and the labour market. Propose an action to address violence against women with disabilities, and address their right to access sexual and reproductive health services. Develop an initiative relating to the ageing of people with disabilities, involving support service providers, and feed into actions linked to the Green Paper on Ageing.
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