EDF analysis of the EU's Sustainable and Smart Mobility Strategy

EDF analysis of the EU's Sustainable and Smart Mobility Strategy

The EU’s Sustainable and Smart Mobility Strategy was published on 9 December 2020 as part of one of the initiatives under the EU’s Green Deal. It outlines the main milestones to reduce transport emissions by 90% in 2050 under 10 “flagship initiatives”.

EDF gave input to the text of the Strategy via a consultation in September 2020 as well as informal feedback to Commission services and helped shape the Strategy in this way. It is relevant to persons with disabilities because transport accessibility is a part of the general “sustainability” concept and persons with disabilities should not be left behind when implementing far-reaching changes such as digitalisation.

One of the flagships concerns persons with disabilities directly, Flagship 9, “Making mobility fair and just for all”. It contains the following commitments:

  • EU passenger rights should be better implemented
  • The Commission will consider a multimodal framework for passenger rights that is simplified, more consistent and harmonised.
  • The Commission recognizes the need for affordable, accessible and fair mobility for passengers
  • The Commission will consider options to define sustainability criteria for Public Service Obligations (such as national railways for example) to bring about a multimodal PSOs system
  • Any future proposal for transport will be compliant with the Commission’s Disability Strategy

The other initiatives do not refer to disability or passengers’ issues in more detail. Here is a summary of the main pros and cons of the Strategy as a whole:


  • Passengers with disabilities and the need for more accessibility and inclusivity are mentioned explicitly under Flagship 9, “Making mobility fair and just for all”
  • Any future transport proposal has to be compliant with the new Disability Strategy (to be published in February 2021)
  • Accessibility and affordability are seen as part of sustainability
  • Possible funding opportunities to make transport accessible via “Recovery and Resilience Facility”


  • Passengers only mentioned in 1 out of 10 Flagships and accessibility is not mainstreamed throughout the Strategy
  • There is no concrete legislative initiatives mentioned to improve accessibility. It is indirectly included in the revision of the Trans-European Network Regulation (TEN-T).
  • There are no milestones related to accessibility, which means there is no concrete aim or deadline to achieve an inclusive transport system
  • Involvement of persons with disabilities and their organisations in the implementation of the Strategy is not mentioned.

In Conclusion, the overall content of strategy is good. Especially the requirement that all new legislation has to be compliant with the Disability Strategy is a success, it will help to implement Art. 9 of the UN CRPD in EU law. However, the strategy lacks concrete goals and milestones to achieve in terms of transport accessibility, it remains too vague on this topic. We will continue our advocacy work on this topic in line with our general position on the EU’s Green Deal.


EDF feedback to EC consultation on sustainable and smart mobility strategy (PDF)