Outline of the call for evidence opened by the Commission
This initiative will create a European Disability Card that will be recognised in all Member States, promoting persons with disabilities’ right to free movement and residence across the EU by facilitating the mutual recognition of disability status for card holders within the EU. It will build on the experience of the EU parking card for people with disabilities, and the EU Disability Card pilot project.
EDF’s initial response
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.
We call for an EU Disability Card that allows for mutual recognition of disability status across EU countries and is accepted by all services offering preferential conditions or adaptations to persons with disabilities, whether provided by public or private entities. This means that the legislation should not set a limited list of sectors, but to apply to all services of the EU single market.
When it comes to the exemption of public social policies outlined by the Commission, EDF believes that the EU Disability Card should provide the possibility of granting such services on a temporary basis when the person with a disability has moved to the Member State to study or to work, while the person with a disability gets their disability re-assessed and certified. This will mean that persons with disabilities moving to another EU country because of a job contract or to study (e.g. Erasmus+ programme) will have the possibility to access support for reasonable accommodation, access to adapted housing, personal assistance schemes, etc.
All this will facilitate travelling in the EU for persons with disabilities, will create awareness among service providers about (the lack of) accessibility and improve access in the long run, and, at the same time, benefit them by increasing visitors’ numbers. The Card will strengthen the collaboration between national authorities and government agencies and raise awareness of disability issues nationally. Also, it will give certain persons with (invisible) disabilities a tool to enable access to services and goods without having to explain their disabilities and will provide persons with disabilities from Member States without a national Disability Card a document they can use also at national level.
We also encourage the Commission to improve the legal framework for the EU Parking Card. EDF believes the format, characteristics and the issuing procedure should be harmonised, in a form which is binding for Member States and clearly communicated to Card users. Also, the controls on fraudulent use of the Card and illegal use of disabled parking spaces should be strengthen.
It seems problematic that the Commission still considers as a possibility to merge the EU Disability Card and the EU Parking Card into a single card. EDF thinks this is not feasible as whereas the Parking Card needs to remain in the car, the person may need to present the Disability Card to enter the venue.
Additionally, the Disability Card should be:
- Based on binding legislation, being a Regulation a more appropriate instrument to avoid differences in implementation at national level.
- An accessible card with standardised size and digital capabilities.
- Include an EU-level website, available in all EU languages that provides practical details for every country (where to get the Card, how it works and a database of benefits).
- It must be ensured that the use of the European Disability Card is voluntary. It has to be codified in the law that each person with a disability can decide themselves if they want to apply for the Card and it should never be an obligation to hold such a Card to prove ones’ disability.
Besides the format and content of the Card, the Commission should consider:
- The EU should set up dedicated funding to support setting up the Card, the website and to guarantee continuing operational needs.
- A wide, accessible awareness-raising campaign in all EU countries to inform about the Card, aimed at users (so they can get the Card), service providers (so they can know about it and accept it), and the general public.
- Close collaboration with persons with disabilities, and especially their representative organisations, throughout its development.