EDF Recommendations for a Disability-inclusive Roaming Regulation

The European Commission published a proposal for the recast Roaming Regulation[1]. It is as an opportunity to strengthen rights of persons with disabilities as consumers of mobile communications services when travelling within the European Union (EU)/European Economic Area (EEA).

We note the strengths of the current legal proposal, specifically:

  • Ensuring same quality of mobile services at home and abroad;
  • Ensuring seamless and free of charge access to emergency services through voice calls and other means (e.g. SMS, emergency application), including for persons with disabilities
  • Preventing unexpectedly high costs and bills, namely when accessing value-added services, such as technical helpdesks, customer care of airlines or insurance companies, or even freephone numbers.

However, we propose further improvements to the proposal, to ensure the right of equal access to mobile communications by persons with disabilities when travelling within the EU/EEA. Specifically, we propose to:

  • Extend requirements of ensuring seamless and free of charge access to emergency services to crucial non-emergency numbers
  • Ensure that all information provided to roaming customers is accessible for persons with disabilities. For example, that the web page giving detailed information about the types of services that may be subject to increased costs is accessible in accordance with requirements of Directive (EU) 2019/882 (European Accessibility Act), the information does not exceed a level of complexity superior to level B1 (intermediate) of the Council of Europe’s Common European Framework of Reference for Languages, as well as is provided in easy-to-read format.
  • Consider implications of this Regulation on equal access to electronic communications by customers with disabilities during enforcement, monitoring and review.

[1] Proposal for a Regulation of the European Parliament and of the Council on roaming on public mobile communications networks within the Union (recast) COM/2021/85 final