The European Commission recently released a study into Social Protection for Persons with Disabilities in Europe. This study sets out the major differences in the way social protection schemes for persons with disabilities work in different countries.
The report looks at the situation in 35 European countries.
Some of the main findings include:
European countries use several schemes – some reliant on a person’s past tax contributions and others purely on the basis of the person’s disability status (even if they have never worked);
- “Capacity to work” is still the main way to judge if someone can qualify for cash support, but level of disability and support needs also play an important role;
- Access to benefits is often linked to a person’s residency status or nationality;
- Many European countries allow persons to work without losing their disability benefits. However, there are often limits for how much a person can earn;
- A considerable number of countries still do not allow people to claim disability benefits when working;
- Many countries have issues with inadequate or reduced disability benefits, and administrative mismanagement. In addition, there are inequalities between people receiving disability benefits on the basis of gender, type of disability and the place they reside.
Disability insurance vs Disability assistance
The report explains that most countries use a mixture of what are known as “disability assistance” and “disability insurance” schemes.
Disability assistance schemes do not rely on the past contribution of persons with disabilities. They are available for working-age people with disabilities who are not in the labour market, as an alternative source of income protection. Germany and Slovakia are the only two countries that do not provide disability assistance schemes.
For disability insurance schemes, entitlement depends on the person’s past insurance contributions. People have to contribute a minimum amount in order to receive support.
Twenty-seven countries have both disability assistance and disability insurance schemes: Austria, Belgium, Bulgaria, Cyprus, Czechia, Greece, Spain, Finland, France, Hungary, Croatia, Ireland, Italy, Luxembourg, Lithuania, Latvia, Malta, Poland, Portugal, Romania, Sweden, Slovenia, Albania, Bosnia Herzegovina, Montenegro, North Macedonia, Serbia and the United Kingdom.
Two countries have insurance-related provisions only: Germany and Slovakia.
Five countries have disability assistance-related provision only: Denmark, Estonia, the Netherlands, Turkey and Kosovo (UNSCR 1244).
Criteria for cash benefits
There are different criteria for gaining access to disability benefits.
Regarding disability insurance schemes, the criteria are most typically a person’s “capacity for work”, their “earning capacity”, the “level/severity of their disability”, the level of support needed, and the “source of disability”.
- “Capacity for work” is used in Austria, Belgium, Bulgaria, Cyprus, Czechia, Germany, Spain, Finland, France, Croatia, Ireland, Italy, Lithuania, Luxembourg, Latvia, Malta, Poland, Portugal, Romania, Sweden, Slovenia, Slovakia, Albania, Bosnia Herzegovina, Montenegro, North Macedonia, Serbia and the UK.
- “Earning capacity” is used in Belgium, Cyprus and Portugal.
- The “level/severity “of disability is used in Greece, France, Hungary, Italy, Portugal, Romania, Bosnia Herzegovina, Serbia and the UK.
- The level of support needed is used in Latvia, Poland and Slovenia, and the source of a person’s disability is a criterion used in Greece, Hungary, Latvia, Portugal, Romania, Slovakia, Bosnia Herzegovina, Montenegro and Serbia.
- Four countries do not have disability insurance schemes: Denmark, Estonia, the Netherlands, Turkey and Kosovo.
- In eleven countries, you need to have proven residency to be able to access the disability insurance schemes: Austria, Cyprus, Finland, France, Italy, Latvia, Poland, Romania, Sweden, Slovakia and Serbia.
- For seven countries, you must have the nationality to gain access to these cash benefits (Bulgaria, Hungary, Lithuania, Poland, Romania, Montenegro and Serbia).
Regarding disability assistance schemes, we see the same list of eligibility criteria.
- “Capacity for work” is used by Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Hungary, Ireland, Italy, Lithuania, Luxembourg, Latvia, Malta, Poland, Montenegro and Kosovo for assessing eligibility for disability assistance.
- “Earning capacity” is used by Austria, Belgium, France and the Netherlands.
- “The level/severity of disability” is used by Bulgaria, Cyprus, Estonia, Greece, Spain, France, Croatia, Hungary, Ireland, Italy, Malta, Poland, Portugal, Romania, Slovenia, Albania, Bosnia Herzegovina, Montenegro, North Macedonia, Serbia, Turkey, the UK and Kosovo.
- The level of support needed is used by Austria, Belgium, Bulgaria, Cyprus, Czechia, Estonia, Finland, Croatia, Italy, Latvia, Poland, Portugal, Sweden, Slovenia, Bosnia Herzegovina, Montenegro, North Macedonia and Serbia.
- “Source of disability “is used in Bulgaria, Cyprus, Czechia, Greece, Croatia, Hungary, Ireland, Luxembourg, Malta, Romania, Slovenia, Bosnia Herzegovina, Montenegro, North Macedonia, Turkey, the UK and Kosovo.
- Two countries have no disability assistance schemes: Germany and Slovakia.
Eligibility for benefits combined with income from work
In many European countries, income from work-related activities does not affect entitlement to disability-specific cash benefits. This is the case, for example, in Bulgaria, Cyprus, Czechia, Germany, Finland, France, Croatia, Hungary, Greece, Spain, Italy, Lithuania, Latvia, Malta, Romania and Slovakia.
Ceilings may apply to the work-related income for some benefits; such is the case in Germany, Finland, France and Italy. In other countries, the interaction between disability-specific cash benefits and income from work results in reductions in the benefit. Such is a case in Austria, Belgium, Estonia, France, Lithuania and the Netherlands.
It is generally not possible to combine cash benefits that are based on disability and insurance with income from work. This is the case in Luxembourg, Portugal, Sweden, Slovenia, Albania, Montenegro, North Macedonia and the UK.
Inadequacy of disability income
The report noted numerous issues with the insufficient levels of financial support provided to persons with disabilities. This was the case in Estonia, Greece, Croatia, Italy, Lithuania, Latvia, Malta, Romania, Albania, Bosnia Herzegovina, the UK and Kosovo.
A number of countries were shown to have a particularly low level support though disability cash benefits, when compared to other schemes. This was the case in Czechia, Germany, Romania, Slovenia and Bosnia Herzegovina.
Inequities in provision (for example, between those with different types of disability, between men and women, between different territories etc.) were reported in Czechia, Germany, Estonia, Hungary, Italy, Malta, Albania, Bosnia Herzegovina and Kosovo.
Worryingly, levels of protection and/or coverage were shown to be decreasing in Hungary, Lithuania, Sweden, Slovenia and Kosovo. It was reported that there are administrative and/or organisational issues with allocating cash benefits in Belgium, Greece, Croatia, Hungary, Lithuania, Malta, Romania and Sweden.
Read the European Commission’s report
For more information, please contact Haydn Hammersley, Social Policy Coordinator