Accessibility
The European Commission started infringement procedures against 24 EU Member States, for failure to transpose the European Accessibility Act – in fact a directive – into national legislation within the 28 June 2022 deadline. At that date, only three EU Member States had officially notified the European Commission that they finalised transposition and published their national laws: Estonia, Italy and Denmark. Updates and the details of the national laws (in the national language(s)) can be found here on the Eur-Lex portal. Whether the Act was properly transposed into the national laws is a separate matter, that will require further time to analyse. Reminder: companies have another 3 years of transition period to apply the new rules and make the necessary changes, except where a longer period is contemplated – as is the case for ticketing machines for example.
On 7 December, the European Commission published the study supporting its review of the Web Accessibility Directive after the first three years of application. The findings are: insufficient accessibility expertise; no evidence of significant accessibility-related costs; insufficient attention to the feedback mechanism; enforcement still below potential; divergent monitoring methodologies and application of these; lack of awareness of minimum requirements; divergent reporting and interpretation of compliance status. Interestingly, the study points at a risk of biased user-needs testing, to the advantage of visually impaired people, in that it is almost exclusively screen readers that are used. For future national monitoring, the study recommends providing a common EU template for reporting and to refine the definition of compliance status.
We learned from Iederin (umbrella group in the Netherlands of our Dutch member) that our support letter to their call to the Dutch Parliament for more funding for audio description contributed to obtaining a budget for audio description increased by an annual extra million euros in the next 4 years.
Equality
The next meeting of the Disability Platform subgroup on Disability Employment Package will take place on 19 January, to discuss deliverable 3: a catalogue of positive actions.
Mobility
On 30 November we attended the European Parliament’s Petitions’ Committee Annual Workshop on the rights of persons with disabilities. The topic this year was “Disability Assessment, Mutual Recognition and the EU Disability Card”.
We delivered a response on 19 November to the European Commission’s call for evidence on the Disability Card. At this stage of the legislative process, the European Commission is expecting opinions on the initiative in general, on its material scope and on the possibility of merging the future EU Disability Card with the EU Disability Parking Card. A more detailed public consultation will take place in the first quarter of 2023.
Reminder: in this perspective and that of having to react to an eventual legislative proposal toward the end of 2023, we call our member organisations in the EU to express their interest to participate in a EBU working group on the EU Disability Card, to inform the EBU advocacy.
On 6 December we responded to the EU public consultation on "Better protection for EU passengers rights". The aim of the consultation, which covers air, waterborne, rail and bus transport, is to understand shortcomings and consider policy measures (including legislation, possibly) to address them. In the background of the consultation is the Commission’s evaluation of the EU legislation. Our response essentially consisted in echoing the European Disability Forum’s response, adding some visually impaired people-specific considerations based on input from our member organisations in the EU. We placed a particular focus on multimodal transport journeys (where there is a clear gap in EU law) and on effective enforcement.
Miscellaneous
On 1st December, we participated in European Disability Forum webinar training on the European Semester process: what it means, how is it structured and how it affects national policies, on disability in particular. This has been a very inspiring event for us and we will doubtless share the lessons with our members to consider future lobbying action.
On 8 December, responding to the EU Disability Platform Secretariat’s call, we recommended topics for discussion and for a possible public event in 2023. Through the European Disability Forum, we also signalled our two suggested priority areas for 2023, i.e.:
- Disability assessment and social protection – this well connects with the EU Disability Card initiative (already followed in a dedicated Platform sub-group) and with the ESPN comparative study for the Commission on disability benefits, to be published any time now.
- Political participation and participation in public life – in the perspective of the European Parliament elections of 2024 and against the background of EU Council reaction to the Parliament’s own initiative legislative resolution on the reform of the EU electoral code.
We will see what EDF (as coordinator of the recommendations of civil society organisations) and the Platform Secretariat will retain eventually of all the recommendations received.
On 13 December, the European Parliament adopted the own-initiative report of the Civil Liberties, Justice and Home Affairs committee, “Towards equal rights for people with disabilities”. The most positive elements for us are that the Parliament: echoes the EDF recommendations for the future EU Disability Card and, e.g., calls the Commission to propose a binding legislative act; calls the Commission and Member States to invest more in organisations of persons with disabilities in order to facilitate their meaningful participation and increase their influence in decision-making; and, against the background of the Equal Treatment Directive remaining blocked at the Council, calls for measures to promote equality, diversity and horizontal inclusion for persons with disabilities.