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1. Accessibility – an enabler of rights, autonomy and equality 3
3. Decent quality of life and living independently 13
4. Equal Access and non-discrimination 19
5. Promoting the rights of persons with disabilities globally 23
6. Efficiently delivering the strategy 28
8. Awareness, governance and measuring progress 30
Mainstreaming disability issues into other EU Strategies 31
Background
After a meaningful consultation with the European disability movement, in early 2021 the European Commission launched its action plan for its second 10-year EU Strategy on the Rights of Persons with Disabilities. The Strategy runs from 2021 to 2030.
In this document, released on the 3rd of March 2021, the Commission outlined flagship initiatives and actions to help the EU and its Member States implement the UN Convention on the Rights of Persons with Disabilities. These actions run until 2024, just before the Strategy’s halfway stage.
The European Commission established a monitoring framework for the implementation of the Strategy. This keeps track of progress in delivering all the flagship initiatives and actions that were promised for the first half of the Strategy. It also provides links to all the final deliverables. At the time of creating this position paper, certain actions are delayed and have therefore not been delivered.
Plans for the period 2025-2030 remain undetermined. The disability movement is calling strongly for the European Commission to commit to building on the momentum of the first five years of the current strategy, and to foresee ambitious proposals for the years leading up to 2030. These new proposals should fill the gaps left by activities that took place between 2021 and 2024, as well as those from the 2010-2020 Strategy.
Purpose of this document
This document will outline what the European Disability Forum considers should be the priority actions and flagship initiatives for the coming five years. We will present the actions we feel the EU institutions and its agencies must focus on with urgency, and how these actions can improve the lives of persons with disabilities across the EU and beyond.
The document will mirror the themes and chapters decided on during the launch of the Strategy in 2021. Each chapter will list the flagship initiatives and other actions we propose the European Commission to work on, and what they should look like in practice.
EDF proposals for the period 2025 to 2030
Flagship initiatives
Flagship 1: European Agency for Accessibility
Establish a new decentralised regulatory European agency for accessibility, based on and building upon the work of the AccessibleEU centre, to support the implementation of all EU harmonised accessibility legislation and continue advancing towards a more accessible Europe. The agency could take inspiration from the US Access Board1, and other relevant national agencies.
The responsibilities of the agency can include:
To provide EU institutions and policymakers, and Member States with specialised information on accessibility;
To provide policy recommendations based on scientific evidence and input from the most affected groups, such as persons with disabilities and older people;
To adopt accessibility technical specifications (i.e. standards) in support of specific EU policies and legislation, and in consultation with rights holders and stakeholders;
To support Member States and EU institutions to implement accessibility standards;
To carry out monitoring of accessibility legislation;
To raise awareness of the importance of accessibility for inclusive societies;
To hold regular contact with persons with disabilities through their representative organisations, accessibility professionals (architects, engineers, designers, ICT professionals…), academia, and industry.
The tasks of such an agency could include:
Training: provide training for professionals in different domains, EU and national public officials and the disability community;
Coordination with other EU agencies, such as the Body of European Regulators on Electronic Communications (BEREC) or the European Rail Agency;
Coordination and support to enforcement and redress mechanisms: at national level (e.g. Market Surveillance Authorities responsible for the Accessibility Act) and EU level (e.g. assisting the EU Ombudsman on enquiries related to accessibility);
Research: conduct studies/projects looking into innovative ways to implement accessibility;
Collaboration at a global level: with other similar bodies (e.g. UN CRPD committee, US Access Board; W3C-Web Accessibility Initiative, etc.);
This action
will help the EU implement CRPD Article 9 on Accessibility.
Flagship 2: Legislation on the affordability of assistive technology
Introduce legislation to guarantee the availability and affordability of assistive technologies for persons with disabilities in the EU single market, building upon the investigation carried out by the Commission in 2024.
Such legislation should tackle the situation that certain national certification schemes prevent persons with disabilities from accessing the most suitable piece of assistive technology for them (see EDF paper on assistive technologies). This legislation should:
Ensure that Assistive Technologies (AT) economic operators and users fully take advantage of the EU internal single market and benefit from the free movement of products and services. This means to set up a joint mechanism for the mutual certification of relevant AT across countries.
Guarantee that Member States facilitate accessible information on available AT and measures ensuring their affordability.
Establish an independent centre at national level to support in the selection of AT, taking into account the experience and expectations of the users, as well as the context of use of the AT. Such centres should have a person-centred approach about the selection, use and maintenance of AT.
Introduce further flexibility, ease and speed within the national AT delivery models.
Encourage research on innovative assistive solutions taking advantage of emerging technologies.
Guarantee the participation of organisations of persons with disabilities so AT are developed, deployed and funded with full consideration of users’ needs and experiences.
This action will help the EU implement CRPD Article 9 on Accessibility.
Other actions
Revise Regulation on the rights of persons with disabilities travelling by air
Ensure fair an equal air travel through an In-depth revision of Regulation 1107/2006 on the rights of disabled persons and persons with reduced mobility when travelling by air. Such revision should:
Eradicate the common cases of denial of boarding that still happen to persons with disabilities.
Introduce the right to swift and fair compensation if the carrier still denies boarding.
Establish the companies’ full liability for damaged or lost mobility equipment, that under the current Regulation 2026/1996 is only classified as luggage. The commission should include this provision in the aforementioned regulation or in other appropriate regulations.
This action will help the EU implement CRPD Article 20 on personal mobility.
New and revised legislation on accessibility of transport infrastructure and vehicles
Revise existing EU legislation or develop new legislation on the accessibility of transport infrastructure and vehicles, such as trains, buses, planes and boats. This should include the following:
Rail Transport: update Regulation 1400 / 2014 on the technical specifications for interoperability relating to accessibility of the Union's rail system (TSI-PRM). While this regulation sets accessibility obligations both for rollingstock and stations, there are many gaps, including lack of common requirements on level access and fully independent and spontaneous boarding.
Bus and coach Transport: update and complement with relevant legislation the UNECE Regulation 107 Uniform provisions concerning the approval of category M2 or M3 vehicles with regard to their general construction. While this regulation establishes accessibility requirements for certain type of buses2, important gaps exist. Among others, there are very few requirements for disabilities other physicals disabilities3 and no requirements at all for infrastructure, including bus stops and terminals.
Air Transport: introduce minimum accessibility requirements for aircrafts and airports as there are no EU rules in this field. Minimum requirements for aircraft should cover the availability of accessible toilet facilities, the provision of mandatory cabin wheelchair, the availability of minimum space for the accommodation of assistance dogs and accessibility of visual and audio information provided in the plane (including entertainment equipment).
Waterborne Transport: update Directive 2010/36 on Safety Rules and standards for passenger ships.
EU guidelines on urban public transport systems
Develop EU guidelines on the procurement of urban public transport systems. Such documents should provide technical guidance and best practices to local authorities to procure accessible public transport vehicles and infrastructure (such as trams, metros, taxis or buses) by specifying the minimum accessibility features that should be included in the tender. The accessibility features should focus not only on physical accessibility, but also on the understandability of signs, maps and instructions, and the clear announcement of stations/stops to facilitate passenger navigation.
This action will help the EU implement CRPD Article 20 on personal mobility.
Study on the barriers to travel with assistance dogs
Passenger Rights Regulations guarantee the right to travel with an assistance dog free of charge. However, putting this right into practice has proved challenging, especially when it comes to air travel. Due to the lack of EU-wide rules on recognition of assistance dogs, countries and transport operators have developed different approaches to decide what qualifies as an assistance. International accreditations systems coexist with national certifications frameworks, which are not always mutually recognised throughout Europe. Furthermore, the lack of appropriate staff training, the divergence of transport requirements and the difficulties in the booking process create a lot of uncertainty for passengers who have a legitimate right to travel with an assistance dog.
To address this, EDF would like to request the European Commission a study on the current barriers to travel with an assistance dog - including on their recognition by transport operators - analysing the different national frameworks, identifying gaps and assessing potential solutions at the European Level.
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This action will help the EU implement CRPD Article 20 on personal mobility.
his action will help the EU implement CRPD Article 20 on personal mobility.
Revision of the European Standardisation System
Revise the European Standardisation System to guarantee a fair, accountable, transparent, and inclusive system to develop harmonised European standards. The European Commission is undertaking an evaluation of Regulation 1025/2012 concerning the European Standardisation System. The European Commission should rethink how harmonised European standards in support of EU harmonised legislation and policies are developed, as the European and particularly national standards bodies are not inclusive, nor accessible, for persons with disabilities and their representative organisations. Besides, certain stakeholders, particularly industry representatives have greater influence on the outcomes of the standardisation process compared to civil society organisations. Finally, once adopted, harmonised European standards are not accessible for persons with disabilities to consult, despite being a crucial element to comply with EU legislation and, in most cases, its development was funded by tax payers’ money. Therefore, the European Commission should revise the standardisation regulation and propose a different system which ensures a fair and inclusive process for developing harmonised standards. As for accessibility standards this could be done by the European Agency for Accessibility proposed above, or, alternatively, by another dedicated agency focused on developing European standards needed for EU laws and policies.
T
This action will help the EU implement CRPD Article 9 on Accessibility.
his action will help the EU implement CRPD Article 9 on accessibility.EU standards on access services to audiovisual content
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This action will help the EU implement CRPD Article 9 on accessibility and Article 21 on Freedom of expression and opinion, and access to information.
hile the accessibility requirements of the European Accessibility Act will be supported by six Harmonised European Standards, there are currently no european standards to support the accessibility provisions of the Audiovisual Media Services Directive. This has led to different practices in Member States and little focus on quality of access services. The European Commission should request the development of an EU Standard on access services to audiovisual content, including on icons and quality aspects and taking into consideration existing national practices.Legislation on Accessible Labelling
Introduce legal requirements on accessible labelling to ensure that consumers with disabilities can enjoy increased autonomy and be fully informed of the contents of products they are buying, including food, home appliances, clothes and cleaning products. This could be done either with a new overarching regulation specifying the list of products to be covered by such new accessibility obligations or by amending existing regulations on labelling of goods sold in the internal market, such as the existing ones on food4 and textile5.
Such new requirements could include the obligation for all product labels to contain a QR code, easily locatable on the packaging using tactile markers. Scanning the QR code with a smartphone should allow consumers to access the information in accessible format. For example:
access the product name, weight, ingredients expiration date
give access to instructions on the use of the device being sold, and safety measures
give access to cooking instructions
give nutritional information and recommended daily consumption.
This action will help the EU implement CRPD Article 9 on accessibility
.
Guidance for Member States on implementing accessibility provisions for buildings in the Energy Performance of Building Directive
Support Member States with guidance to fully use the accessibility provisions included in Directive 2024/1275 to maximise its potential for making the built environment more accessible for persons with disabilities while ensuring their energy efficiency.
This action will help the EU implement CRPD Article 9 on accessibility and Article 19 on living independently and being included in the community.
.
Legislation on equal access to essential services
Introduce internal market legislation ensuring that access to essential services, as defined in the EU Pillar of Social Rights, will be possible through both, digital and non-digital means. This will prevent further exclusion due to a rapid digitalisation leaving many people, including persons with disabilities, without the possibility of accessing these services through human interaction.
This action will help the EU implement CRPD Article 9 on accessibility, and facilitate the realisation of other rights within the CRPD where access to services are essential.
.
Copyright exemptions on cultural works for accessibility
I
This action will help the EU implement CRPD Article 9 on accessibility and Article 30 on participation in cultural life, recreation, leisure and sport.
ntroduce copyright exemptions to a larger number of cultural works to facilitate accessible adaptations and availability of these for all persons with disabilities, building upon the success of the Marrakech Treaty for printed materials. Such copyright exemption could cover access services for audiovisual content (e.g. audio description, subtitles for the deaf and hard of hearing), museum exhibitions (e.g. audio guides, sign language interpretation, easy to understand materials). To give an example, at the moment, due to copyright, the same film must be audio described twice in France and in the French speaking region of Belgium, despite sharing the same language. Such copyright exemption would facilitate the accessibility provisions of the Audiovisual Media Services Directive.
Earmark EU funds for training on accessibility and communication
Invest EU resources in increasing the knowledge and availability of national sign languages, easy-to-read formats, Braille, speech to text and text to speech software, and any other accessible means of information and communication for persons with disabilities.
This action will help the EU implement CRPD Article 9 on accessibility, Article 21 on freedom of expression and opinion, and access to information, Article 24 on education and Article 27 on work and employment.
Single Digital Booking and Ticketing Regulation for transport
This action will help the EU implement CRPD Article 9 on accessibility and Article 20 on personal mobility.
ake sure that passengers with disabilities can also benefit from the announced single digital booking and ticketing regulation on travel by making sure that the platform is accessible following the requirements of the European Accessibility Act and that their specific passenger rights are also guaranteed for the whole trip (provision of assistance, liability for broken and lost mobility equipment, PRM information and complaint handling).
Revision of the Public Procurement Directive
S
This action will help the EU implement CRPD Article 9 on accessibility.
trengthen the accessibility provisions in the upcoming revision of the Public Procurement Directive, as public authorities do not often comply with article 42 on technical specifications and do not use accessibility as an award criterion. Consider introducing a redress mechanism for citizens to challenge publicly procured products, services and infrastructures when these do not live up to the obligations laid down in the EU Directive.Review State Aid Rules
Revise State Aid Rules to allow for support on costly accessibility adaptations, particularly on housing. EU legislation granting the use of State Aid, namely the General Block Exemption Regulation, should increase flexibility for such investments into accessibility and not be restrictive on the amount Member States can dedicate to such investments.
EDF priorities for the period 2025 to 2030
Flagship initiatives
Flagship 3: Directive for full freedom of movement of persons with disabilities
Introduce a Directive on the shared responsibility of Member States for disability support towards EU citizens moving from one Member State to another for the long term.
The
final approach of this Directive still needs to be further discussed
in order to find the best solution, but we would strongly advise that
the law allows persons with disabilities to retain coverage from
one’s Member State of origin through “portability” of one’s
benefits until the moment that the citizen has established residence
in a new Member State and
has
undergone the new disability assessment procedure.
As well as an agreement on a person’s Member State of origin continuing to fund their support until they have been assessed and recognised as a person with disabilities in their new Member State of residence, there must also be a mechanism, supported with EU funds, to offset any differences in disability allowances and personal budgets between Member States, and to ensure that whatever a person receives in financial support is adequate and proportionate to the cost of living wherever they are based.
Finally, the Directive should also put further responsibilities on the new Member State of residence not to allow undue delays in the reassessment of a person’s disability. A decision on their status and the recognition of their disability status in the system of the new country of residence should be done within a reasonable timeframe and give them access as soon as possible to the services that are available to them there.
This action will help the EU implement CRPD Article 18 on liberty of movement and nationality.
Other actions
Access to higher education and European mobility programmes
Collect data on the number of young persons with disabilities that take part in Erasmus+ mobility programmes, and collect this data on a regular basis to observe trends.
Survey young people with disabilities taking part in mobility programmes what barriers they have faced and that they think are most likely to put off other young people with disabilities from taking part in the programmes.
This action will help the EU implement CRPD Article 24 on education.
EDF proposals for the period 2025 to 2030
3.1. Fostering access to quality and sustainable jobs
Flagship initiatives
Flagship 4: Disability Employment and Skills Guarantee
Establish a Disability Employment and Skills Guarantee, inspired by the successful Youth Guarantee, to provide funding and support to ensure that persons with disabilities have equal access to mainstream education, training and employment opportunities, including self-employment and entrepreneurship. The Guarantee should also offer support in making every training and skills-development programme fully inclusive and accessible.
In order to meet the needs of persons with disabilities, the Disability Employment and Skills Guarantee would need to have some considerable differences with the Youth Guarantee. Notably:
It should be open to people who are receiving disability allowance and allow them to retain this allowance when in work, training or education. The fact of being the recipient of disability allowance should not result in the person in question not being considered to be a NEET (Not in Education, Employment, or Training) as is currently the case for the Youth Guarantee;
The age restriction should of course be lifted, as barriers to the open labour market for persons with disabilities are often experienced throughout a person’s entire life;
Extra resources should be on offer, from the funding attached to the Disability Employment Guarantee, to assist in providing reasonable accommodations for the person at work (since in most EU Member States reimbursement of costs for reasonable accommodation to employers are only subsidised for employees with a permanent contract).
The Guarantee would need to very carefully clarify about which types of work settings people can be supported into as part of the scheme. Excluded from the scope of the Guarantee should be sheltered workshops exclusively for persons with disabilities where workers do not have the legal status of employee and are not paid in line with national, regional or sectoral minimum wage requirements. Emphasis should be on placements in the open labour market, or in social enterprises that support people into mainstream forms of employment, focusing on transition.
The EU in its next Multiannual Financial Framework should increase the budget going towards the European Social Fund, to ensure that inclusion of new social initiatives does not dilute spending elsewhere.
This action will help the EU implement CRPD Article 27 Work and employment.
Other actions
A Directive to regulate the use of algorithms for managing, monitoring and recruiting workers
In line with the suggestion from the Commission that the EU will develop such a legislative proposal, the EU should commit to this plan and must ensure that this legislation very clearly removes risks of discrimination that candidates and employees with disabilities can face at the hands of Artificial Intelligence algorithms. It must be clear that algorithms used in managing, monitoring and recruitment cannot in any way put persons with disabilities at a disadvantage purely because of their disabilities.
Recommendations to the Member States on compatibility between disability allowance and other forms of income
F
This action will help the EU implement CRPD Article 27 Work and employment and Article 28 on adequate standard of living and social protection.
ollowing on from guidance to support Member States in further reforms of social protection, develop Recommendations to the Member States on the benefits of enabling persons with disabilities to retain disability allowance regardless of employment, marital status and inheritance, with examples of EU Member States and other countries where disability allowance is not impacted by these.Study on the extra cost of living of persons with disabilities
C
This action will help the EU implement CRPD Article 28 on adequate standard of living and social protection.
ommission a study into the extra cost of living of persons with disabilities. This study can be used to bring light to why disability allowance is a right, why disability allowance schemes must offer adequate financial support, and why it is important to allow persons with disabilities to retain disability allowance when receiving other forms of income.Study on income and pension gaps for informal carers
Issue a study into the extent to which people in the EU who offer informal support to family members and loved ones with disabilities, particularly women who are more likely to fill such roles, lose out on access to adequate income and pensions entitlements later in life.
Use the study to identify Member States and regions where informal carers are given the least support, and the extent of loss to income that can arise when State support is not available.
This action will help the EU implement CRPD Article 5 on equality and non-discrimination and Article 27 on Work and employment.
3.2. Independent living and inclusion in the community
Flagship initiatives
Flagship 5: EU Strategy on the transition from institutions to inclusion in the community
Building on the EU Guidance on Independent Living and Inclusion in the Community, develop an EU Strategy on the transition from institutions to inclusion in the community, and act against the segregation of persons with disabilities, including children with disabilities. Additionally, ensure and guarantee appropriate measures and support for the transition from institutions to independent living and community-based services, allowing for the full and effective participation of persons with disabilities in the community. The strategy should foresee the following:
How the EU and the Member States can regularly update and make publicly available the data on the number of persons with disabilities living in institutions on a regular basis that allows us to observe trends and progress
Obligations to better monitor projects for independent living using EU funds, to ensure they do not perpetuate institutional care, including the use of development funding going outside of the EU
Technical support to national and local authorities on preparing for the transition away from institutions
Training for service providers to move towards person-centred support and respect of the CRPD
Financial support for the “cost of transition”
Information campaigns to persons with disabilities, and current residents of institutions, on their options and choices outside of institutional care
Campaigns to attract people to become personal assistants and to improve working conditions in the sector
Support to national and local authorities to set up direct payment systems to persons with disabilities for their personal assistance budget
Support to families and informal carers
This action will help the EU implement CRPD Article 19 on living independently and being included in the community.
Flagship 6: Fund for accessibility in the new European plan on affordable housing
When announcing her commitments for the new Commission mandate, President Von Der Leyen shared her vision for a new focus on tackling the EU’s housing crisis. This included a new Commissioner for Housing, an action Plan on affordable housing, investments for affordable and energy efficient housing and a reform of State Aid rules to support affordable and energy-efficient housing.
As well as the actions above, we are calling on the European Commission, in the next Multiannual Financial Framework, to establish a fund for accessible housing within the framework of EU cohesion funding. The aim should be to create new affordable and accessible housing in the community, as well as to retrofit existing properties to make them accessible where possible.
All the proposed actions above must imperatively include a clear focus on the accessibility of housing stock for persons with disabilities and older people. The inaccessibility of housing is a key reason for people having to leave their home against their will. Accessible housing is in desperately short supply in Europe, and typically imposes far greater costs on tenants and buyers.
When the action plan proposed by President Von Der Leyen takes shape, it is of paramount importance that it be an action plan for accessible and affordable housing.
The new Commissioner for housing, in their cabinet, must also have a cabinet member who is knowledgeable on accessibility of housing for persons with disabilities and older people.
This action will help the EU implement CRPD Article 19 on living independently and being included in the community, Article 9 on accessibility, and Article 28 on adequate standard of living and social protection.
Other actions
Data collection on people living in institutions
Following on from the examination of the situation of persons with disabilities living in institutions by the FRA, collect and publish up-to-date data on the number of persons with disabilities living in institutions in every Member State. Publish these figures on a regular basis on an online platform that allows for the monitoring of progress in each Member States inspired by the online monitoring system used in the US.
This action will help the EU implement CRPD Article 19 on living independently and being included in the community, and Article 31 on statistics and data collection.
Use EU funds to support the families of persons with disabilities
In the next Multiannual Financial Framework, include in the scope of the European Social Fund Plus and the European Fund for European Aid to the Most Deprived (FEAD) the objective of offering greater in-home support to families of persons with disabilities.
Offer, with the help of EU funds, technical support to families of persons with disabilities to enable them to more easily cope with any challenges linked to a loved one’s disability, and to know how to offer the support their family member needs.
This action will help the EU implement CRPD Article 7 on children with disabilities, and Article 23 on respect for home and the family.
Study on the impact of the transition to adulthood for young persons with disabilities
Fundamental Rights Agency to conduct a study on this period of transition and what it means for young persons with disabilities, particularly concerning how disability allowance and support changes during and the barriers people face when trying to establish their own inclusion in the community. The study can also focus on the barriers young persons with disabilities face in accessing their sexual and reproductive rights, and how this impacts their experience of transitioning into adulthood.
This action will help the EU implement CRPD Article 28 on adequate standard of living and social protection.
EDF proposals for the period 2025 to 2030
Flagship initiatives
Flagship 7: Strong actions to end forced sterilisation
EDF calls for the adoption of a series of strong actions to end forced sterilisation, which would include:
Criminalisation: a ban of forced sterilisation in EU law;
An action plan to end forced sterilisation, including public apology, rehabilitation, reparation (including economic reparation), and guarantee of non-repetition.
After the adoption of the Directive on Combating Violence Against Women and Domestic Violence which failed to include the criminalisation of forced sterilisation, the European Disability Forum renews its call for EU to urge Member States to:
Criminalise forced sterilisation with no exception based on disability or legal capacity;
Enforce measures at EU and Member States levels to prevent forced sterilisation, ensure equal access to sexual and reproductive rights, and ensure access to justice, including reporting, as well as adequate criminal sanctions, and compensation for victims;
Encourage all EU Member States to ratify the Istanbul Convention on combating violence against women.
This action will help the EU implement CRPD Article 6 on Women with disabilities, Article 15 on freedom of torture or cruel, inhuman or degrading treatment or punishment, Article 16 on freedom from exploitation, violence and abuse, and Article 17 on protecting the integrity of the person.
Other actions
EU coordinator on ending all forms of violence against women
The Commission should nominate a coordinator on ending all forms of violence against women who will oversee the implementation and monitoring of the Directive on combating violence against women and domestic violence, and the Istanbul Convention. One of the roles of the coordinator should be to assess and address the challenges faced by women with intersecting identities, including women and girls with disabilities.
This
action will help the EU implement CRPD Article 6 on Women with
disabilities, Article 15 on freedom of torture or cruel, inhuman or
degrading treatment or punishment, Article 16 on freedom from
exploitation, violence and abuse, and Article 17 on protecting the
integrity of the person.
Recognition of national sign languages as part of the multilingual EU
Take action to ensure that national sign languages are given the legal status of languages, in order to be in line with Article 2 of the UN CRPD, which places sign languages on an equal footing with spoken languages.
This action will help the EU implement CRPD Article 9 on accessibility, and Article 21 on freedom of expression and opinion, and access to information.
Action plan on equality and intersectionality
Adopt an action plan on equality and intersectionality that will take into account the current and new strategies and plans addressing the barriers and discrimination faced by people with intersectional background, including disability, age, ethnicity, religion, gender and sexual orientation. The action plan will specifically present initiatives to address intersectionality in the policy work of the European Commission.
This action will help the EU implement CRPD Article 5 on equality and non-discrimination.
Awareness-raising campaign on women with disabilities
Develop and conduct an awareness raising campaign on women with disabilities, giving visibility to their rights and their role as active participants of society, including as leaders, mothers, mentors, in various domains. This initiative will help deconstructing the negative and stereotyped vision many people have of women with disabilities of all ages, and with various types of disabilities. They are often
This
action will help the EU implement CRPD Article 6 on Women with
disabilities.
Recommendation on autonomy and supported decision making of persons with disabilities and older persons
Collect and publish good practices related to autonomy and supported decision making of persons with disabilities, leading to the adoption of Recommendation on the topic. The Recommendation will particularly look at the transition from substituted to supported decision-making and abolition of substituted decision-making regimes. This initiative will foster the protection of the rights of persons with disabilities and older adults currently deprived of their legal capacity, or who are left without support. It could also help in ensuring that Member States implement the 2000 Hague Convention in a way that is compliant with the UN CRPD. It is required by article 12 of the UN CRPD.
This
action will help the EU implement CRPD Article 19 on living
independently and being included in the community, and Article 21 on
freedom of expression and opinion, and access to information.
EU study on disability hate speech and hate crime
Conduct a study on how persons with disabilities are affected by hate speech (including online), hate crime and cyberbullying, and the response from EU Member States. This will contribute to other initiatives of the Commission on combating hate speech and hate crime and discussion in the Council on extending EU crimes to hate speech and hate crime. This should extend to cases of persons with invisible disabilities who are denied recognition of their condition and treated with distain due to their symptoms such as, but not exclusively, people with Myalgic encephalomyelitis/chronic fatigue syndrome (ME/CFS).
This action will help the EU implement CRPD Article 14 on liberty and security of person, Article 15 on freedom of torture or cruel, inhuman or degrading treatment or punishment, and Article 16 on freedom from exploitation, violence and abuse.
Support representation of persons with disabilities in the media
Use funding from Creative EU to explore the representation of persons with disabilities in the media, particularly through:
Projects that promote persons with disabilities telling their own stories on screen or via other creative media as actors, podcasters, artists, writers, etc.
Research on the impact that the presence of persons with disabilities in the media has on public understanding and perceptions of disability
Training workshops for young persons with disabilities on how to use media for the purpose of disability advocacy and awareness, and particularly on how to get information across clearly in interviews and during television/radio appearances.
Data on
mental health
This action
will help the EU implement CRPD Article 8 on awareness raising.
Collect survey data through Eurobarometer on mental health and wellbeing of people throughout the European Union. The survey should also explore how intersectional groups are particularly impacted by mental health problems both from a social drift and social causation perspective, including young people with disabilities. The survey should be carried out on a regular basis to ensure the monitoring of trends.
The questions presented in the Eurobarometer survey should be designed in collaboration with independent organisations working on mental health.
This action will help the EU implement CRPD Article 31 on statistics and data collection.
FRA Disability Survey
Call on the Fundamental Rights Agency A to conduct a Disability Survey, as it has done in relation to other discriminated groups, such as the LGBTI and Roma surveys. Such survey is necessary to have an up-to-date overview of the current issues and human rights violations faced by people with disabilities in the EU.
This action will help the EU implement CRPD Article 8 on awareness raising, and Article 31 on statistics and data collection.
5. Promoting the rights of persons with disabilities globally
EDF proposals for the period 2025 to 2030
Flagship initiatives
Flagship 8: Disability Action Plan in EU External Action
Adopt a Disability Action Plan in EU External Action, similar to the Youth Action Plan in External Action, to ensure disability-inclusion in EU external action
A Disability Action Plan could offer a critical framework for European institutions, including EU Delegations and Member States, to adopt a more disability-inclusive approach in their external action activities, encompassing both international cooperation and humanitarian efforts.
The Action Plan should cover five main thematic areas:
Respecting and mainstreaming the rights of persons with disabilities
Ensuring funding mechanisms and clear monitoring
Ensuring full and effective participation and accessibility
Developing and implementing fully inclusive policy and programmes
Strengthening internal and external disability inclusive cooperation, coordination and partnership
The outcomes of such a plan would ensure that the rights of persons with disabilities are fully respected and systematically integrated into all EU external action policies and programmes. All EU-funded initiatives for external action would adhere to the principles of the CRPD. Persons with disabilities and their representative organisations would meaningfully participate in all EU external action decision-making processes on an equal basis with others. Their full and measurable inclusion would be guaranteed in all policies, guidance, and implementation of EU external action activities.
Finally, EU institutions, Member States, and partners would collaborate in a consistent and coordinated manner toward disability inclusion, fostering internal synergy in alignment with international standards and frameworks. Ultimately, the EU would position itself as a global leader in disability-inclusive external actions.
This
action will help the EU implement CRPD Article 32 on International
cooperation.
Other actions
Global Disability Summit
Make ambitious, bold and well-funded global commitments on international cooperation and humanitarian action at the 2025 Global Disability Summit (GDS). These commitments will be backed by dedicated financial resources, ensuring sustainable, inclusive actions that prioritise the rights of persons with disabilities worldwide and deliver measurable impact.
Provide a comprehensive progress report on the commitments made at the GDS 2022, demonstrating its dedication to transparency and leadership in advancing global disability rights.
This action will help the EU implement CRPD Article 32 on International cooperation.
Support Disability Rights in EU Accession Countries
Enhance support for EU accession countries in implementing the CRPD by:
Offering guidance to accession countries on critical issues such as labour market inclusion, inclusive education, independent living as well as accessibility of transport and public spaces.
Supporting national governments and local authorities in effectively using the EU Instrument for Pre-Accession (IPA) to fund this process and offering access to expertise to accelerate progress in these critical areas.
Establishing monitoring frameworks to ensure that financial and technical resources are optimally used to advance disability rights and that progress is consistently reported.
Supporting the disability movement in EU accession countries and involving them in dialogues during the preparation of the enlargement reports.
This action will help the EU implement CRPD Article 32 on International cooperation.
Budget for Community-based Support Beyond EU Member States
Ensure the next EU budget fully supports independent living for persons with disabilities and facilitates the transition to community-based support and services in third countries. The rules prohibiting investment in institutions for persons with disabilities should be as stringent for EU funding being spent in third countries as it is for structural investment and cohesion funds used by the EU Member States themselves, in the Common Provisions Regulation.
This action will help the EU implement CRPD Article 32 on International cooperation.
Ensure Disability-inclusive Climate Action
Ensure that disability inclusion is a central component in all EU climate adaptation and mitigation policies, as well as EU-funded projects, including the European Green Deal, the EU Nationally Determined Contributions (NDCs), the EU Climate Adaptation Strategy, and the Just Transition Mechanism. Additionally, support the active involvement of persons with disabilities as stakeholders in global, regional, and national climate negotiations, such as the Conference of the Parties (COPs) by advocating for official recognition of a disability constituency within the United Nations Framework Convention on Climate Change (UNFCCC).
Lead global efforts in disability-inclusive climate action by promoting both physical accessibility and accessible information and communication channels. Ensure that persons with disabilities participate meaningfully in all climate policy decision-making processes.
Advocate for a “Just Transition” that guarantees persons with disabilities benefit equitably from green economy initiatives, both in Europe and globally. This includes addressing socio-economic impacts, promoting job creation in green sectors, and ensuring accessible training and skills development.
Finally, ensure dedicated budget allocations for disability-inclusive climate action and for the transition to a sustainable, inclusive economy that benefit everyone.
This action will help the EU implement CRPD Article 32 on International cooperation, and Article 11 on situations of risk and humanitarian emergencies.
Include Persons with Disabilities in Humanitarian Action
Prepare for future crises by fully implementing existing UN and EU guidelines that address the rights of persons with disabilities, including the ECHO “Guidance note on the inclusion of persons with disabilities in EU-funded humanitarian aid operations”, the Sendai Framework for Disaster Risk Reduction 2025-2030 and the IASC Guidelines for the Inclusion of Persons with Disabilities in Humanitarian Action 2019.
Ensure meaningful and continuous consultation with OPDs in the design and implementation of humanitarian decision-making processes, civil protection systems, and preparedness strategies. Additionally, involve OPDs in shaping the actions taken by emergency services during crisis situations to ensure that interventions are inclusive, accessible, and effective for persons with disabilities.
This action will help the EU implement CRPD Article 32 on International cooperation, and Article 11 on situations of risk and humanitarian emergencies.
Continue Supporting Reconstruction in Ukraine
Organise a Reconstruction Conference dedicated to ensuring accessibility and inclusion in Ukraine’s rebuilding efforts. The conference will prioritise the use of a Universal Design approach, with the participation of persons with disabilities and their representative organisations (OPDs), ensuring that all infrastructure and services are accessible to everyone.
Align financial and logistical support for reconstruction with the identified gaps and recommendations provided by Ukraine’s disability organisations, ensuring that resources are allocated effectively and inclusively to meet the needs of all communities.
This
action will help the EU implement CRPD Article 32 on International
cooperation, and Article 11 on situations of risk and humanitarian
emergencies.
Protect Persons with Disabilities in Situations of Conflict and Fragile States
The inclusion of persons with disabilities in situations of conflict, war, and in fragile states is critical yet often overlooked. These individuals face heightened risks, including physical harm, displacement, and lack of access to essential services and barriers to mobility and communication. Compounded by societal stigma, they are particularly vulnerable to violence, neglect, and exploitation.
Ensure the protection and participation of persons with disabilities through bold and sustainable commitments and concrete actions, including allocated funding, will ensure the EU uphold the rights and dignity of these people. Inclusive policies and targeted support, such as accessible infrastructure and specialised care, are necessary to address the unique challenges persons with disabilities face and ensure they are not left behind in stabilisation, recovery and peacebuilding efforts.
Commitments such as the Geneva Conventions, the Additional Protocols, the recent Pact for the Future, and international humanitarian law should define the EU Response.
This
action will help the EU implement CRPD Article 32 on International
cooperation, and Article 11 on situations of risk and humanitarian
emergencies.
Guidelines on the inclusion Refugees and Asylum Seekers with Disabilities
I
This action will help the EU implement CRPD Article 32 on International cooperation, and Article 11 on situations of risk and humanitarian emergencies.
ssue guidelines on how to ensure the rights and support needs of refugees and asylum seekers with disabilities, including unaccompanied children with disabilities. The guidelines should give direction to the Member States when developing their National Implementation Plans, as well as to the EU’s enforcement of its new Pact on Migration and Asylum. The guidelines should encompass provisions for accessibility, protection, and tailored support services to meet the unique challenges faced by individuals with disabilities throughout the migration process.EDF proposals for the period 2025 to 2030
Improve representation within the Disability Platform
Invite Member States to bring national organisations of persons with disabilities to participate in discussions of the Disability Platform. Invite EU accessing countries to join the Platform. In line with the Commission’s Youth Dialogue, the Disability Platform should also have reserved places specifically for young persons with disabilities, to ensure that the perspective of young people is taken into account in a more systematic way.
Analyse the implementation of the actions and flagship initiatives from the first half of the strategy
It is important not only to propose new actions, but to follow up on how well those developed between 2021 and 2024 are being implemented. The Commission should analyse and report publicly on the successful implementation of the key actions and flagship initiatives developed during the first half of the strategy. This should be done with particular attention for the transposition of new EU legislation, such as those supporting the new EU Disability Card and Parking Card.
EDF proposals for the period 2025 to 2030
Improve provision of reasonable accommodation by the European Personnel Recruitment Office (EPSO)
Jobs in the EU institutions still remain largely inaccessible to many persons with disabilities because of the inflexibility of the competition process for recruitment. Applicants with disabilities are regularly denied reusable accommodations for the entrance exams or are provided with solutions that do little to help them. It puts them at a disadvantage compared to candidates without disabilities and has no bearing on their working abilities within a job. The EU institutions must lead by example by increasing the proportion of workers with disabilities among their staff, including in senior positions, and removing barrier during the recruitment process. EPSO must revise its rules regarding which types of reasonable accommodations it allows for candidates with disabilities taking competitions to work in the EU institutions.
Inclusive traineeship programmes in the EU institutions
Review of the approach to including persons with disabilities in the traineeship programmes of the EU institutions. Improvement the way reasonable accommodations are provided to trainees with disabilities, and extra grants are attributed to cover additional accommodation or transport costs linked to a person’s disability. Offer better guidance to staff in the EU institutions managing trainees with disabilities to ensure they are aware of issues they might face and how to address them in a respectful and professional manner.
EDF proposals for the period 2025 to 2030
Continue with the monitoring framework for the Strategy
The Commission should continue using a monitoring framework for the implementation of the Strategy, as it has done since it began in 2021. It should be transparent about delays, missed deadlines and any inability to deliver what has been promised in the Strategy.
Introduce changes to the Access City Awards
EDF would propose considering the following changes to the way the award operates:
Have the winning city of the Access City Award to host the following year’s European Days of Persons with Disabilities.
Promote the initiatives that foster meaningful cooperation with residents with disabilities, representative disability organisations and Service Providers. Although this is part of the assessment criteria, it could become one of the special mention awards.
Strengthen the role of the National Juries to allow for example for site visits, give sufficient time for consultation, and try to involve diverse stakeholders for a broad perspective on accessibility.
Create a community of practice with winning cities. This could include yearly meetings to discuss certain topics and keep up progress as well as creating a database of accessible tools and good practices for accessible cities. Non-winning cities could also participate in such structures to learn from their peers.
Use the expertise of awarded cities to support EU policies in the urban context. Topics to address could include Urban Mobility Plans under the Trans-European Transport Network (TEN-T) or the Accessibility of Electric Vehicles Recharging Stations.
Strengthen the link with the European Disability Card and the AccessibleEU Resource Centre. This could include a new category related to the use and promotion of the European Disability Card in the city and a yearly event with the centre on cities as well as a report or a repository of good practices.
Open the award to cities coming from EU Accession Countries. This would allow the possibility for these countries, who one day will be part of the EU, to start working on accessibility, integrate EU accessibility policies and standards and engage with EU cities active in the field.
Increase the scope of the award to also recognise the effort of cities in other key fields: provision of services for persons with disabilities, training on accessibility, public procurement good practices, disaster risk preparedness and smart cities
Revise the size of cities that can participate to allow for better comparability. Document credits
Mainstreaming disability issues into other EU Strategies
As well as taking an intersectional approach within the EU Strategy on the Rights of Persons with Disabilities, it is also essential that other existing, ongoing and foreseen EU strategies mainstream the needs of persons with disabilities. It will be particularly important to include the disability perspective in strategies such as the:
EU Gender Equality Strategy
EU Strategy on the Rights of the Child
EU Roma Strategic Framework for Equality, Inclusion and Participation
EU Anti-racism Action Plan
EU Green Deal
EU Digital Strategy
EU Strategy on Adaptation to Climate Change
This will require consulting persons with disabilities and their representative organisations in planning and delivering actions within these strategies.
This document was prepared by Haydn Hammersley
Assisted/Supervised by Alejandro Moledo
The
European Disability Forum
Mundo Madou
Avenue des Arts
7-8
1210 Brussels, Belgium.
Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the European Commission. Neither the European Union nor the granting authority can be held responsible for them.
1 The US Access Board is an independent federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards for the built environment, transit vehicles, telecommunications equipment, medical diagnostic equipment, and information technology, including technical assistance to implement them.
2 Class I buses with capacity of 22 passengers or more (M2 or M3)
3 No obligations visual, tactile or audio information, which clearly excludes visual and hearing-impaired passengers.
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