Below is our contribution to the consultation on common indicators on the functioning of equality bodies.
These implementing acts will establish a list of common indicators on the functioning of equality bodies under Directives 2024/1499 and 2024/1500 on standards for equality bodies. The indicators will cover equality bodies’ human, technical and financial resources, their independent functioning, accessibility and effectiveness, and changes in their mandates, powers or structures. The indicators will ensure the comparability, objectivity and reliability of data collected at national level.
Our contribution
The European Disability Forum (EDF), umbrella organisation representing the rights of over 100 million persons with disabilities in Europe, welcomes the proposed adoption of a list of common indicators on the functioning of equality bodies.
We particularly welcome the mainstreaming of disability throughout the indicators and the inclusion of accessibility-related indicators, which are well framed and coherent. These are important steps to ensure that equality bodies are well equipped to promote and protect the rights of persons with disabilities in line with the UN Convention on the Rights of Persons with Disabilities (CRPD) ratified by the EU and all its Member States.
We identified some additional gaps that can be addressed by the indicators to ensure full inclusion and accessibility:
- Communication accessibility is still too narrowly defined, focusing mainly on ICT and web content. It should also encompass other forms of communication and information provision.
- The indicators should explicitly require the involvement of persons with disabilities and their representative organisations in the design, monitoring and evaluation of accessibility measures.
- There is no reference to training of staff on accessibility, reasonable accommodation, and communication with persons with disabilities.
To address these gaps, we propose to add the following three new indicators:
- A1_5: “The equality body provides information in accessible formats, such as Braille, plain language and easy-to-read, and accessible means of communication (e.g. in sign language, real-time text or through relay services).” (Yes/Partly/No + description)
- A1_6: “Persons with disabilities and/or their representative organisations are involved in the design, monitoring and evaluation of accessibility measures.” (Yes/Partly/No + description)
- A1_7: “Staff members are trained on accessibility, reasonable accommodation, and communication with persons with disabilities.”
Regarding the accessibility of premises, the current “yes/no/partially” responses do not provide sufficient detail to assess real accessibility levels. Equality bodies could instead report on more specific items, in line with Annex III of the European Accessibility Act (Directive 2019/882), including:
- Approaches to the building and entrances
- Paths in horizontal and vertical circulation
- Rooms used by the public
- Toilets and sanitary facilities
- Exits, evacuation routes and emergency planning
- Communication and orientation via more than one sensory channel
- Equipment and facilities used for service provision
Premises should be considered accessible only when meeting applicable standards, including EN 172010 on accessibility and usability of the built environment.
Finally, under the A1_Comments section, equality bodies should be asked to report on data and self-assessment of accessibility. The Regulation could include the following instruction: “Provide data or qualitative information on how accessibility is assessed (e.g. audits, feedback from users with disabilities, complaints received, improvements implemented).”