Among the initiatives of the new Strategy for the Rights of Persons with Disabilities (2021 – 2030), the European Commission aims to create a European Disability Card (the Card) by the end of 2023. The Card will be built on existing actions such as a pilot project which has been carried out among eight Member States of the EU (Belgium, Cyprus, Estonia, Finland, Italy, Malta, Romania, and Slovenia) as well as the European parking card for persons with disabilities.
The European Union of the Deaf (EUD) acknowledges the importance of this initiative for the deaf community. Besides the benefits that the Card provides in cultural, sport, and leisure sectors, the Card has the potential to be a significant tool to guarantee the right to freedom of movement to all persons with disabilities – including deaf persons. As today, economically active deaf persons and deaf learners encounter several barriers when moving from one EU Member State to another as their disability status might not be equally recognised in other countries. This could imply the loss of access to services such as sign language interpretation and other benefits for deaf persons in the country of arrival.
Considering the potential of the European Disability Card, EUD provided several recommendations in its feedback to the European Commission’s recent call for evidence on the Card. EUD recommended that:
• The European Disability Card should allow the recognition of the disability status among different EU Countries; deaf persons should have their deaf status recognised as established by their country of origin.
• The Card should fill in the gap left by Regulation 883/2004 and coordinate current disability benefits that economically active persons with disabilities receive in order to comply with the UN CRPD; Regulation 883/2004 addresses only benefits for people with disabilities who are economically inactive and does not include persons with disabilities able to work who require accessibility and reasonable accommodation measures for equal access to the labour market.
• Persons with disabilities should be able to choose what is disclosed on the Card, including their disability type; as deafness is an invisible disability, it is important for deaf persons to have the choice of disclosing their disability. This would facilitate a way for deaf persons, who do not use speech to communicate, to indicate their disability and receive adequate access to the required services and measures.
• The Card should be accompanied with common European guidelines on how to ensure accessibility or reasonable accommodation for various groups of persons with disabilities; as Member States remain free to choose what assistance and accommodations can be provided to persons with the Card, guidelines concerning the type of reasonable accommodations and available accessibility measures should be provided for specific disabilities such as deafness.
• The Card should extend the current benefits from the current scope; although it includes relevant aspects of deaf persons’ life – culture, leisure, and sport -, the Card should further extend its benefits. For instance, national, regional, and local public transport, education in the EU Mobility Programmes, employment facilitations in the transition phase to access the national disability benefit system when moving abroad, as well as commercial benefits should all be included.
• Each EU Member States’ public authority dealing with disability should provide a) clear and easily accessible information of how to gain access to the Card, and b) this information must be available in the Member State’s national sign language(s); the process to obtain the Card should be fully accessible. For deaf persons this means that all information about, and on how to obtain the Card should be in national sign language. In addition, national sign language interpretation should be available at any point during the application process or in case of questions concerning the Card.
You can read EUD’s feedback at this ligação.