European Union of the Deaf
EUD
The European Union of the Deaf (EUD) was founded in 1985.
ID: 938323993066-28
Lobbying Activity
Response to Update of EU rules on audiovisual media services
17 Dec 2025
As the only supranational organisation representing more than 1 million deaf people before the European Union through a network of National Associations of the Deaf (NADs) from 31 countries (27 Member States, Iceland, Norway, Switzerland and the United Kingdom), the European Union of the Deaf (EUD) issued a report on the implementation of the AVMSD. Based on a consultation conducted among its members, the EUD identified major shortcomings in the implementation of the AVMSD as follows. Only a small majority of the EU countries provide daily news in the national sign languages, often provided by public broadcasters. The countries where the daily news is sometimes to rarely provided in the national sign languages are those that do not have measurable targets and/or quota, or where the option is given to AVMS providers to provide subtitling or sign language. However, only half of the respondents confirm that broadcasted programmes in national sign languages are provided beyond news and emergency announcements, demonstrating the lack of equal access to for deaf people to the full range of audiovisual content. This is even worse among the private broadcasters, the on-demand platforms and the Very Large Online Platforms (Art. 7 DSA) where sign language is very rarely provided to ensure accessibility for deaf viewers. Moreover, only a minority of the EU countries provide deaf-led programmes produced in sign language by deaf and for deaf people, restricting the linguistic human rights of deaf people to be provided audiovisual content in a culturally and linguistically adequate way (Art. 21 and 30 of the CRPD). The situation is even alarming regarding the accessibility of emergency information broadcasted in national sign languages: only 8 of the 22 respondents confirmed that emergency announcements are always interpreted in their national sign languages. But only 5 countries specifically foresee this obligation in their legal framework. For those reasons, we call upon the EU to revise the AVMSD to include the following provisions: Expand the scope of the accessibility obligations to video-sharing platforms and other formats such as social media, video gaming platforms and audiovisual sections of news websites; Include clear definitions of all access services, such as written subtitles, sign language interpretation, and deaf-led programmes in national sign languages, for deaf sign language users; Include the definition of emergency information and require full accessibility in national sign languages without exceptions; Ensure that accessibility measures, including sign language provision, apply to the full scope of audiovisual content, not just news and emergency information, but also childrens programming, sports, culture, entertainment, movies, and music, among others; Set binding EU-wide timelines and targets, both quantitative and qualitative, for audiovisual accessibility across all providers, services, and content types, especially on the accessibility measures related to sign language; Include functional accessibility requirements and references to relevant technical specifications including those on the display and quality of sign language provision; Fund and promote good practice examples of accessible measures for deaf sign language users across Member States, including deaf-led programmes and content presented directly in national sign languages; Oblige audiovisual media service providers to develop and implement accessibility action plans in close cooperation with organisations of persons with disabilities, including NADs, under the supervision and enforcement of NRAs; Require MS to establish a clearly visible, accessible, and disability specific online contact point for audiovisual accessibility complaints, available in sign language, with enforcement by NRAs and regular monitoring by the EC. For more information, please consult our report attached to this contribution.
Read full responseResponse to The new Action Plan on the implementation of the European Pillar of Social Rights
28 Aug 2025
The European Union of the Deaf (EUD) is the sole supranational organisation representing deaf people at European level and would like to contribute to the public consultation by addressing both the implementation of the first Pillar Action Plan (2021) and the desired objectives and content of the new Action Plan (2025). The European Pillar of Social Rights (EPSR) contains 20 principles, but Principle 17, most relevant to deaf people, has mainly been addressed through the European Strategy on the Rights of Persons with Disabilities 20212030 (ESRPD). EUD regrets the lack of a mainstreamed, disability-inclusive approach across other principles. Under Principle 12 (Social protection), the EU missed the chance to advance revision of Regulation 883/2004 to ensure portability of social security benefits, as recommended by the CRPD Committee (2015, 2025). Principle 16 (Healthcare) has not tackled specific barriers faced by persons with disabilities, nor provided disability-disaggregated or intersectional data. Principle 5 (Employment) lacks a proactive, rights-based focus on inclusive workplaces and early awareness in education and training. The Disability Employment Package offers useful tools, but lacks binding measures, funding, and disaggregated indicators by disability, preventing targeted action for deaf people. The absence of a Horizontal Equal Treatment Directive continues to leave gaps in protection from discrimination in healthcare, education, and access to goods and services. Overall, siloed initiatives under the EPSR and ESRPD miss opportunities for coherent policy. Within the European Semester, disability is rarely addressed in Country-Specific Recommendations, and consultations with representative organisations like EUD remain limited, unstructured, and inaccessible. Our main recommendations for the new Action Plan (2025) are: - Adopt an updated Action Plan of the European Strategy for the Rights of Persons with Disabilities for 20262030 with specific actions, measurable indicators, and clear timeframes, developed without delay and in close consultation with OPDs in line with the CRPD Committees Concluding Observations (pt. 13) and ensure linguistic rights of deaf sign language users are addressed. - Ensure the portability of social security benefits to safeguard the freedom of movement of persons with disabilities in the context of employment, in line with Regulation (EC) No 883/2004 on the coordination of social security systems, especially the right to access professional sign language interpretation services for deaf sign language users moving into another Member State. - Strengthen the European Pillar of Social Rights by linking Pillar 17 with related areas such as healthcare (Pillar 16) and education (Pillar 1), ensuring relevance for deaf sign language users. - Promote EU-wide healthcare accessibility by setting standards, supporting Member States, collecting disaggregated data, and funding an EU mapping of accessible facilities for persons with disabilities, including deaf people. - Apply an intersectional approach to avoid siloed actions (under each Pillar) or indicators (in data collection) and deliver effective measures for all citizens, including deaf sign language users. - Promote official EU-level recognition of national sign languages and guarantee the linguistic rights of deaf sign language users in the Action Plans implementation. - Expand the Eurostat indicators to enable disaggregation by disability type (following the Washington Group Short Set) and intersectional identities (racial or ethnic origin, religion, languages, gender identity, socio-economic status, sexual orientation, age, etc.), and embed these in the Social Scoreboard. - Ensure structured, timely, and accessible consultations with organisations of persons with disabilities, including National Associations of the Deaf (NADs), at the national level before Member States submit their National Reform Programmes (NRPs).
Read full responseResponse to Gender Equality Strategy 2026-2030
4 Aug 2025
The Gender Equality Strategy 20262030 must adopt a truly intersectional approach, reflecting the lived experiences of all women and girls, including deaf women and those with disabilities. The fight against discrimination, including multiple and intersectional discrimination, must be a central pillar of the Strategy. This requires recognising the compounded barriers faced by women with intersecting identities, such as deafness, disability, race, or migration status, and addressing them in all actions and policy areas. The Strategy must ensure robust disaggregated data collection by gender, disability, age, ethnicity, and LGBTIQ+ identity, using both quantitative and qualitative methods, such as focus groups and lived experience narratives. Data must be gathered in consultation with organisations of persons with disabilities (OPDs) to ensure that measures are inclusive, responsive, and rights-based. A strong focus is needed on gender-based violence (GBV), which deaf women and girls face at disproportionate rates due to inaccessible services, lack of awareness campaigns in sign language, lack of preventive measures among men and boys, including those who are deaf, and insufficient professional training in the legal field. All GBV measures must be accessible and developed in collaboration with Deaf communities. Moreover, the Gender Strategy should adopt a more inclusive and intersectional approach that is going beyond a binary understanding of gender and explicitly recognising the rights, experiences, and barriers faced by non-binary, transgender, and gender-diverse persons, including those who are deaf or have disabilities. Furthermore, sexual and reproductive health and rights (SRHR) must be addressed as a standalone priority. A European survey, as called for by the 3rd European Deaf Womens Forum, should map SRHR barriers faced by women and girls, especially those with disabilities and refugees. Finally, EUD strongly recommends the addition of a dedicated priority area addressing the gendered impact of crises, including war, forced displacement, migration, natural disasters, and public health emergencies. Emergency preparedness, crisis response, and resilience policies must include inclusive gender-sensitive communication systems and disability-responsive protocols. For more information and evidence, please consult our extended feedback to the public consultation in attachment to this contribution.
Read full responseResponse to Digital Networks Act
18 Jun 2025
The European Union of the Deaf (EUD), representing 31 members, the National Associations of the Deaf (NAD) across the EU, the EEA, as well as Switzerland and the United Kingdom, wishes to highlight critical issues impacting more than 1 million deaf sign language users under the current European electronic communications framework. 1. Universal Service Obligations: Current Universal Service Obligations (USO) fail to address the realities of deaf people who use sign language. Our members report widespread disparities in broadband affordability and access. Deaf people rely heavily on high-speed data for video communication, yet most Member States do not provide suitable or affordable packages. Moreover, voice communication must be redefined to include Real-Time Text (RTT) and Total Conversation (TC) as default services for all users, rather than as specialised services for persons with disabilities. TC provides functional equivalence for deaf people in accessing electronic communications and should be enforced equally alongside RTT. The deployment of RTT and TC remains very limited across the EU to date. Finally, deaf people remain excluded from everyday communication due to the lack of 24/7 video relay services (VRS) in their national sign languages. In many Member States, these services are unavailable, underfunded, or operate with restricted hours and/or inadequate quality. 2. Access to Emergency Communications: Access to emergency communications remains inadequate for deaf people. Although RTT is enforced, it is not equivalent for those who do not use written language fluently. Many of our members report that access is either non-existent or fragmented, often relying on third-party VRS not integrated into Public Safety Answering Points (PSAPs). Key issues identified include: - Roaming limitations, where deaf people travelling within the EU cannot access emergency communications in their national sign language due to a lack of redirection or interoperability; - Untrained PSAPs staff, lacking the knowledge to handle direct calls in national sign languages and respond appropriately to emergency situations involving deaf people; - Lack of AML (Advanced Mobile Location) and crucial metadata transmission via some mobile apps, VRS, and RTT platforms to PSAPs; - Limitations of VRS use in emergency contexts, due to limited hours, insufficient quality, delays, errors, and lack of interoperability. 3. Accessibility of Helplines and Public Warnings in National Sign Languages: Currently, only the 116000 hotline is subject to accessibility obligations, yet it is still not available in national sign languages in most EU countries. Other EU-wide helplines (e.g. 116006, 116016, 116123), as well as national helplines, remain similarly inaccessible in national sign languages. Public warning systems also remain largely text-based. Deaf people do not receive alerts in their national sign language on their devices, making them vulnerable during emergencies due to the lack of accessible safety instructions. Alerts must be delivered in national sign languages without disruption. 4. Conclusion The current regulatory framework does not guarantee functional equivalent access to electronic communications to deaf people. We urge the Commission to strengthen obligations under the Digital Networks Act by mandating: - Affordable high-data internet packages; - Native rollout of RTT and TC in all devices, networks, and platforms; - Provision of 24/7 video relay services in national sign languages with quality benchmarks; - Roaming and interoperable TC access to emergency communications, including 112, and PSAPs training; - National sign language access for all helplines and public warning alerts. Please consult our report on the EECC for data, evidence-based recommendations and resources: https://eud.eu/euds-report-on-the-implementation-of-the-european-electronic-communications-code/
Read full responseResponse to Evaluation of the EU Lifts Directive
13 Feb 2025
The European Union of the Deaf (EUD), the only supranational organisation representing Deaf people at European level and its membership is composed of 31 national deaf associations (NAD) in the EU and neighbouring countries, would like to share its feedback to the European Commission's evaluation of the Lifts Directive. The Lifts Safety Directive (2014/33/EC) provides the Essential Health and Safety Requirements for the lifts and provides only minimum requirements to ensure access for persons with disabilities in two of the provisions in its Annex I on essential health and safety requirements under point 1.2 (Carrier) and 1.6 (Controls). Those provisions are limited to specific requirements for persons with disabilities, and do even not specify the minimal accessibility requirements, especially those relevant for deaf people. We therefore support the EDFs recommendations to rephrase both provisions guaranteeing that the lifts and their functions are designed and built following accessibility requirements and universal design and that the requirements shall apply to all lifts open to the public, not only to those intended for the strict use of persons with disabilities. Moreover, we strongly recommend the requirements to encompass the communications functions in addition to physical functions in compliance with the UNCRPD. Additional accessibility requirements on access to information and communications, especially in case of an emergency, should be included in the Essential and Health and Safety Requirements of the Directive so as to ensure the safety of deaf people, among other persons with disabilities. Indeed, lifts pose an emblematic case of accessibility that does still not include deaf people, due to a lack of visual information and communication, especially in case of an emergency where deaf people often do not have access to visual information and/or communication. Accessible communication with an assistance service operator is crucial in an unusual emergency situation, which can create distress and pose a security issue. The Directive states that the harmonised standards relevant to the Directive should also take into account the UNCRPD. However, as we will read in the next paragraph, the harmonised European Standard 81-70 (version of 2022) that develops further on the Directive provisions is not in compliance with the UNCRPD. The harmonised European Standard EN 81-70 is key to support the implementation of the Directive. However, it does not contain the necessary accessibility requirements for people with disabilities, especially for deaf people. This is particularly applicable under Points 5.4.2.5.3. to 5.4.2.4 on accessible communication systems. The alarm system providing visible signals (a yellow graphical symbol illuminated from initiation of the alarm until the end of the alarm; and a green graphical symbol illuminated during voice communication) is not effective for deaf persons as it does not allow them to communicate or express what urgency they are faced with, nor to receive the information from the assistance service operator on the help that is underway. Indeed, deaf people experience high levels of distress and are unable to communicate with the assistance service when there is a dysfunction in the lift due to lack of accessibility. The revised Directive and the updated European Standard EN 81-70 should include two-way communication requirements that are not only auditory based but also visually based, therefore mandating the provision of a video intercom system connected to a remote sign language interpreting service. Having regard to the Article 9 of the UNCRPD and considering the current version of the EN 81-70, the Directive 2014/33/EC is not effective due to the restricted interpretation of the EHSR on the accessibility of the lifts for persons with disabilities, especially deaf persons. Please find our detailed argumentation and recommendations in the document attached.
Read full responseMeeting with Nora Bednarski (Cabinet of Commissioner Helena Dalli)
8 Nov 2024 · Implementation of the Strategy for the rights of persons with disabilities and EUD’s position on the recognition at EU level of 29 national sign languages.