European Disability Forum

1. Accessibility as a Foundation, not a Burden As more aspects of life move online, it is essential that all digital products and services meet minimum accessibility requirements. Without these, persons with disabilities (PwD) are excluded from basic rights such as employment, education, information, and public services.

The EU Public Procurement Directive has enormous potential to foster inclusion for persons with disabilities. Here we point out why it does not currently reach its full potential, and identify the gaps to address. The directive underserves persons with disabilities in a number of areas, particularly when it comes to support services.

The EU Public Procurement Directive has enormous potential to foster inclusion for persons with disabilities. Here we point out why it does not currently reach its full potential, and identify the gaps to address. The directive underserves persons with disabilities in a number of areas, particularly when it comes to support services.

EDF input to the European Commission’s call for evidence on the Digital Networks Act ............................................................................................................................ 11 July 2025 Link to the call for evidence Submitted by Daniel Casas, EDF Accessibility Policy Officer EDF feedback to the call for evidence The European Disability Forum (EDF) is an umbrella organisation of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Considering that almost 100 Million persons with disabilities live in the EU plus the even greater number of older persons, which will increase in the coming years, accessibility must be a priority. Making buildings accessible from the beginning or as part of a bigger renovation project is less costly and should be routine procedure.

Having followed the development of the work carried out by EFRAG, The European Disability Forum welcomes the fact that the Commission is retaining elements that are key regarding the social dimension of sustainability, coherent with the CSRD and particularly related to the inclusion of persons with disabilities, including the specific DR S1-11 Persons with disabilities.

We welcome the European Commission’s proposal for regulating Artificial Intelligence (AI) in the EU. The proposed Regulation for AI will help ensure protection of fundamental rights of persons with disabilities in the context of new technologies. The Regulation can also help promote AI that will improve accessibility for persons with disabilities and support their participation in society.

The European Disability Forum welcomes an increased focus at EU level on strengthening the development of skills during school education, particularly with the proposal of upcoming Council Recommendations. When it comes to learners with disabilities, the situation is particularly uncertain, and a great deal more needs to be done to ensure that all learners are reaching their full potential.

There is a housing crisis in the EU. This is a huge challenge for many, but persons with disabilities are even more affected by the rising prices and insecurity. Unfortunately, this is not new. Not only are 11% of persons with disabilities in the EU being overburdened by the cost of their housing, but only 28.9% of persons with disabilities consider that their dwelling actually meets their needs.

EDF feedback to the European Commission revision of European Standarisation Regulation ............................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Introduction The European Disability Forum is an independent NGO that represents the interests of 100 million Europeans with disabilities. EDF is a unique platform which brings together representative organisation of persons with disabilities from across Europe. EDF is run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.

Especially the accessibility of charging stations for electric vehicles and mobility devices will become more important in the coming years, also in the light of the EU Green Deal. The key thing to consider is the direct interaction between an individual and the electric vehicle charging point.

The European Disability Forum (EDF) is an independent NGO that represents the interests of 100 million Europeans with disabilities. We welcome the initiative for an Action plan for women in research, innovation and startups, as it an occasion to promote an intersectional approach and include evidence on how gender and disability intersect.

We strongly call on the European co-legislators to ensure accessibility of digital platforms and services, so that European law best serves the interest of all Union citizens, including of more than 100 million EU citizens with disabilities. The explanatory memorandums for the Proposals make references to the UN Sustainable Development Goals and mention social sustainability.

The European Disability Forum (EDF) has followed and supported the development of corporate reporting and sustainable finance requirements, in particular with regards to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards. These are instruments that ensure that companies will report on the employment and inclusion of persons with disabilities in a mindful way.

The forthcoming EU Gender Equality Action Plan IV (GAP IV) represents an important opportunity for the European Union to strengthen its global leadership on gender equality, womens rights and inclusive international cooperation. The EUs Gender Equality Action Plan 20202025 (GAP III) created important momentum, stronger policy frameworks, better gender mainstreaming and improved accountability mechanisms.

While access to employment remains a huge issue for persons with disabilities, the quality of that employment is equally concerning. Persons with disabilities make up 23.9% of people aged 16 and above in the EU, yet our rate of employment is 24.2 percentage points below that of non-disabled people. It is a particular issue for persons with cognitive, intellectual or psychosocial disabilities.

First of all, we would like to underline that our initial reception of the proposal is very positive. The proposal will result in binding legislation for both Cards. For many years EDF has campaigned for the European Disability Card, and we, and our extensive membership took part in the policy development process till now; most priorities we highlighted have been included in the proposal.

EDF welcomes the opening of the procedure to establish a European Disability Card. This idea emerged from the disability movement and has been a high priority ever since our Freedom of Movement campaign in 2011. The pilot project showed its feasibility and the opportunities it can bring.

Dear Sir / Madam, Please find attached the European Disability Forum's analysis of the enforcement of passenger rights. EDF welcomes the proposal on enforcement of passenger rights and, in particular, supports the following points: The amendment to Article 2 of Regulation 1107/2006 to ensure that, whenever a person with a disability is required to travel accompanied, the air carrier, agent or tour operator pay the…

Dear Sir / Madam, Please find attached the European Disability Forum's analysis of the proposed regulation on passenger rights in the multimodal context. EDF welcomes the proposal on passenger rights and, in particular, supports the following points: The provisions of accessible information in Articles 3, 8, 13, 18 and 10 subject to a clearer reference to the European Accessibility Act The provision of assistance…

The European Disability Forum (EDF) welcomes the European Commission’s initiative to gather evidence for the purpose of assessing the impact of the EU passenger rights regulatory framework, particularly related to Regulations on air passenger rights for passengers with reduced mobility (PRM), waterborne and bus & coach passenger rights.

The Citizens Omnibus Initiative should be an opportunity to remove long-standing barriers that prevent persons with disabilities from fully benefiting from freedom of movement and the Single Market. Simplification efforts should therefore strengthen, rather than weaken, the rights and protections afforded to persons with disabilities.

Persons with disabilities continue to face systemic barriers in accessing education and employment, including inaccessible learning environments, lack of reasonable accommodation, discrimination, and limited disability competence among educators, trainers, and employers.

The European Disability Forum (EDF) welcomes the proposal of a Directive on combating violence against women and domestic violence which comes as a first step to fill significant legislative gaps on violence against women and girls across the EU. We also welcome the inclusion of women and girls with disabilities in the proposal.

The European Disability Forum (EDF) welcomes the preparation of an EU Anti-Trafficking Strategy 2026-2030. Persons with disabilities face a heightened risk of being trafficked and exploited, yet they remain largely invisible in policy and practice.

The European Disability Forum (EDF) is concerned that EU Member States do not effectively ensure the rights of victims’ with disabilities enshrined in the Victims’ Rights Directive and the CRPD. The following key issues, have been identified: • Lack of information about what constitute a crime and how to report, particularly affecting people living in closed settings such as institutions, persons with intellectual…

The European Disability Forum (EDF) welcomes the European Commission’s proposal to amend Regulation (EU) 1025/2012 on European Standardisation as a first step towards ensuring a transparent European standardisation system with improved governance and empowered European rights-holders.

The European Disability Forum (EDF) welcomes the preparation of a new EU Strategy on Victims Rights. Persons with disabilities face a heightened risk of becoming victims of crime, including violence , abuse, exploitation, hate crime and gender-based violence.

The European Disability Forum views the European Social Fund as one of the most important and impactful forms of EU funding for reducing inequalities throughout the Member States. It has been key to improving the social inclusion of persons with disabilities all over Europe. We therefore strongly believe that the ESF+s budget must be enhanced in the next Multiannual Financial Framework.

The European Disability Forum (EDF) welcomes the European Commission’s planned Digital Compass Policy Programme initative, which seeks to set up a robust governance framework providing structured cooperation between the Commission and the Member States to achieve the EU’s digital targets envisioned in the EC Communication on 2030 Digital Targets.

The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.

The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.

EDF recommends for the EU to develop a fully self-standing and mandatory EU Talent Pool, for all labour migration purposes (as presented under policy option 4 in the call for evidence), and to include the following measures: 1.

The European Disability Forum (EDF) welcomes the initiatives of the European Commission to address harmful practices against women and girls. The disability movement is very concerned by harmful practices taking place in the EU, including against persons with disabilities.

The European Union and all its Member States have ratified the United Nations Conventions on the Rights of Persons with Disabilities (CRPD). This international treaty creates specific obligations relevant for the EU and all Member States in the creation of the European Health Union Package.

The European Disability Forum (EDF) Youth Committee is calling on the EU institutions to ensure that the events and actions organised within the European Year of Youth are involving young people with disabilities and that the events and actions are organised in an accessible and inclusive way providing real-time captioning, international sign interpretation and accessible materials.

The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) recognizes the importance of accessibility in enabling persons with disabilities to fully enjoy all human rights and fundamental freedoms, accessible transport and infrastructure being one of them. As a State Party to the UN CRPD, the EU has clear obligations to ensure that the rights of persons with disabilities are fully respected.

The European Disability Forum (EDF), umbrella organisation defending the rights of over 100 million persons with disabilities in the EU, welcomes the initiatives of the European Commission to improve access and efficiency of the justice system.

The European Disability Forum (EDF) considers that Proposal for a Council Decision does not sufficiently take into account the rights and needs of persons with disabilities and do not fully comply with the UN Convention on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its Member States, including Latvia, Lithuania and Poland.

The regulation should refer to the CRPD. Preamble (pmbl.) 43, art. 12 (4) and 13 (4d): as written in art. 7 CRPD, children with disabilities should be provided with disability and age-appropriate assistance to express their views on matters affecting them, including during the personal interview and upon assessing the best interests of the child. Pmbl 44, art. 13 (4) and 24: should refer to art.

The European Disability Forum, umbrella organisation defending the rights of over 100 million persons with disabilities in the EU, member of the European Women’s Lobby, welcomes this roadmap on the fitness check on the EU legislation on violence against women and domestic violence.

The European Disability Forum (EDF) is extremely concerned that the proposed Regulation on protection of adults does not comply with the obligations of the EU and all its Member States under the United Nations Convention on the rights of persons with disabilities (CRPD), and is generally in breach with the fundamental rights of equality and autonomy applicable to every EU citizen.

The European Disability Forum (EDF) recognises the importance of adoption and application of conflict of laws treaties as a means to provide legal certainty, avoid gaps and promote the uniform application of substantive international law including in the EU. However, conflict of laws legislation should not lead to human rights violations of the person impacted by the measures at stake.

The European Disability Forum (EDF) has been involved in the ERA Working Party tasked with the review and amendment of the TSI-PRM for more than a decade and considers it very useful for implementing the Regulation to advance accessibility of rail infrastructure and rolling stock for persons with disabilities.

EU-level data collection is key to understanding how well the EU and its Member States are implementing the United Nations Convention on the Rights of Persons with Disabilities (CRPD). When done effectively, this data can form the basis for our understanding of how our societies are progressing in realising the rights of persons with disabilities.

It is estimated that 15% of the worlds population have a disability. This percentage usually rises in humanitarian crises, making the access to relief and recovery services insufficient for persons with disabilities. When it comes to the evaluation of the Humanitarian Aid, the Commission must recognise its obligations to the UN Convention of the Rights of Persons with Disabilities (CRPD), in particular Art 11.

Ensuring that persons with disabilities participate on an equal basis with other people is not only a basic matter of social justice. It is also a human rights obligation under the UN Convention On The Rights Of Persons With Disabilities (CRPD), to which the EU, Ukraine, Georgia and Moldova are State Parties.