In 2023, the European Commission will start working on its proposal for the European Disability Card. This flagship initiative of the Vammaisten henkilöiden oikeuksia koskeva strategia 2021-2030 represents an important initiative for persons with disabilities – including the deaf community. Indeed, besides the benefits it will provide, the Card has the potential to be an important instrument for the enforcement of deaf persons’ rights to freedom of movement across the EU.
Indeed, deaf persons encounter several communication barriers, as well as difficulties in accessing disability-related services whenever they move across EU Member States. This is caused by the lack of a harmonised approach to disability recognition and accessibility across the EU which could be overcome thanks to the use of the European Disability Card.
To ensure that the Card is inclusive of the deaf perspective, through this document, EUD wants to provide concrete policy recommendations based on feedback and input from its member organisations – National Associations of the Deaf. Specifically, the cards should:
- Be underpinned by binding legislation. As such, the Commission’s proposal for the new Card must be in the form of a regulation as this would mean that the obligations of the Card would be uniform across all Member States;
- Ensure the scope includes transport, education in the framework of EU Mobility Programmes, employment to facilitate the transition phase to access the national disability benefit system when moving abroad, and health, whereby the Card facilitates the provision of accessibility and reasonable accommodation measures, rather than merely “nice to have” benefits;
- Place an obligation on Member States to ensure the mutual recognition of disability status in all EU Member States;
- Either a) fill the gap that Regulation 883 presents by ensuring that their proposal for an EU Disability Card includes the provision that the Card coordinates the (currently uncoordinated) social security benefits of economically active persons with disabilities. OR b) to amend and update Regulation 883 to extend the provision of coordinating social security benefits to economically active persons with disabilities;
- Ensure there is the choice of what to include about disability type on the Card in the most suitable manner, from a technical perspective, including the option to not state anything, e.g. a QR code;
- Include the provision for the creation of an online information platform to accompany the Card;
- Be accompanied with the obligation for EU Member States to develop and run training programmes within the sectors under the scope of the Card;
- Be accompanied with the obligation for common European guidelines to be developed for service providers on how to ensure accessibility and reasonable accommodation for each disability type;
- Ensure that each EU Member States’ public authority implementing the Card should provide a) clear and easily accessible information on how to apply for the Card, and b) all this information must be available in the Member State’s national sign language(s);
- Include the provision for an EU Disability Card Monitoring Body to be established at EU level to ensure proper and full implementation of the Card in all Member States.