Following the public consultation on the draft Delegated Act on the European Disability Card Directive in April 2026, the European Commission has published the final text on 1 July.
A “Delegated Act” is an EU law that adds technical details to a legislation that has already been adopted. In this case, the Act sets out specifications for the printed QR codes and security features of physical Disability Card and Parking Card.
The European Disability Forum (EDF) gave feedback to the draft law in the public consultation. We suggested several measures to improve the digital features. The final text reflects some of our recommendations, but several concerns remain:
- The Commission improved Recital 13 and Art. 5.3.d to limit the range of the radio frequency identification (RFID) readability to “approximately one meter” (we said less than 1 m)
- They did not exclude the vehicle number plate data from the RFID requirements (Art. 5.3.h.ii). This is an issue in cities where they assigned the European Parking Card to a specific vehicle, as some users, including blind persons, regularly move in different cars.
- They did not include our comments on interoperability with the verification applications in Article 6.5. We had asked for a text alternative for the visual representation encoded data.
- They did not include our proposal to add a tactile cue to help card users locate the QR.
Privacy and accessibility remain key priorities
It is important to note that EDF and its members had already been consulted by the European Commission before the public consultation.
During these 2 discussions, we clearly stated that the technical solutions must:
- Recognise that disability-related data is personal and sensitive, and therefore
- protect the privacy of the users and
- ensure the usability and accessibility of the solutions.
What happens next?
The European Commission together with the Member States will draft an additional law, which will take the form of an Implementing Act. Similar to the Delegated Act, it will deal with specific details that are too technical to be included in the original Directive.
In this case, the Implementing Act will describe the requirements for the fully digital versions of the European Disability Card and the European Parking Card. It will also include:
- Rules on verification,
- authenticity requirements for the prevention and combating of fraud,
- rules about interoperability between Member States, and
- the use of the cards in an EU digital identity wallet.
Contact
For more information, you can contact Marie Denninghaus (marie.denninghaus@edf-feph.org)