Table of contents 1.Introduction 1.1 Purpose and scope 2.Background to the intervention 2.1 Description of the intervention and its objectives 2.1.1 Need for action 2.1.2 The Strategy 2.1.3 The UNCRPD 2.1.4 The competences of the EU 2.1.5 Intervention logic 2.2 Baseline and points of comparison 3.Implementation / state of Play 3.1 Description of the current situation 4.Method 4.1 Short description of methodology 4.1.1 Sources of information 4.2 Limitations and robustness of findings 5.Analysis and answers to the evaluation questions 5.1 Effectiveness

5.1.1 Achievement of objectives and implementation the actions in eight key areas 5.1.2 Achievement of objectives and implementation of the actions for the implementation instruments 5.1.3 Mainstreaming of disability issues in EU policy and legislation 5.1.4. Success factors in implementing the EU Strategy 5.1.5 Gaps and challenges that hindered achievement of the objectives 5.1.6 Engagement of stakeholders in the Strategy’s implementation 5.2 Efficiency 5.2.1 Cost-effectiveness of the Strategy 5.2.2 Adequateness and proportionality of resources 5.3 Relevance 5.3.1 Relevance of the Strategy in addressing the needs of persons with disabilities 5.3.2 Relevance of the Strategy for its different stakeholders 5.4 Coherence 5.4.1 Internal coherence of the Strategy 5.4.2 Coherence of the Strategy with other EU policies/ actions (Europe 2020, the European Pillar of Social Rights, the European Semester, the Charter of Fundamental Rights of the European Union and the EU funding provisions) 5.4.3 Coherence of the Strategy with the UNCRPD 5.4.4 Coherence of the Strategy with the related policy measures in Member States 5.5 Added value 5.5.1 Added value of the Strategy in eliminating barriers for persons with disabilities and in implementing the UNCRPD 6.Conclusions

Annex 1: Procedural information Annex 2: Stakeholder consultation Annex 3: Intervention logic Annex 4: Methods and analytical models Annex 5: implementation status of the actions of the Strategy Annex 6: Evaluation questions Annex 7: Lists of figures and tables Glossary Term or acronym Meaning or definition DG Directorate-General: is a policy department of the European Commission DHLG Disability High Level Group EaSI Programme Employment and Social Innovation Programme EESC European Economic and Social Committee EMCO Employment Committee ERDF European Regional Development Fund ESF European Social Fund ESI Funds European Structural and Investment Funds EU European Union EU-LFS EU Labour Force Survey EU-SILC EU Statistics on Income and Living Conditions FRA Fundamental Rights Agency REC Programme Rights, Equality and Citizenship Programme SPC Social Protection Committee Strategy European disability strategy 2010-2020 Study Study supporting the evaluation of the European disability strategy (2010-2020) UNCRPD United Nations Convention on the Rights of Persons with Disabilities AT Austria BE Belgium BG Bulgaria HR Croatia CY Cyprus CZ Czechia DK Denmark EE Estonia FI Finland FR France DE Germany EL Greece HU Hungary IE Ireland IT Italy LV Latvia LT Lithuania LU Luxembourg MT Malta NL the Netherlands PL Poland PT Portugal RO Romania SK Slovakia SI Slovenia ES Spain SE Sweden UK the United Kingdom 1.Introduction 1.1 Purpose and scope The purpose of this evaluation is to review the implementation of the European disability strategy 2010-2020 (the Strategy) and to provide conclusions that can be used as a basis for future policy development. The evaluation assesses to what extent the objectives of each area of the Strategy, detailed in section 2.1.2, have been achieved and to what extent the actions for achieving these objectives have been implemented. In addition, the evaluation highlights strong points and weaknesses in the implementation of the Strategy and provides overall conclusions. The scope of the evaluation is largely focused on the actions undertaken by the EU institutions and the European Commission in particular, and only to a limited extent on actions undertaken at Member State level. This limitation has highlighted the need to address in the future also the progress at national level. As the Strategy is the policy framework for implementing the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD, the Convention) at EU level, the evaluation has also assessed how the Strategy has influenced the implementation of the Convention at EU level. The evaluation covers all five criteria set out by the Better Regulation requirements, namely effectiveness, efficiency, coherence, relevance and EU added value. This document largely relies on an external supporting study (the Study), and on input gathered via a broad stakeholder consultation process described in Annex 2.

The geographical scope of the evaluation is the EU in its pre-Brexit composition (28 Member States). The time span covered by the evaluation is November 2010 to December 2019. However, a few references to policy developments beyond this timeframe have been included in this Staff Working Document for the sake of completeness. The Strategy will end in 2020. In line with the "evaluate first" principle, which is part of the Better Regulation regulatory policy, the results of the evaluation will be used as a basis for the formulation of the Commission’s future priorities and initiatives in the field of disability.

2.Background to the intervention 2.1 Description of the intervention and its objectives 2.1.1 Need for action The Treaty on the Functioning of the European Union (TFEU) requires the EU to combat discrimination based on disability when defining and implementing its policies and activities (Article 10) and it gives it power to adopt legislation to address such discrimination (Article 19). The Charter of Fundamental Rights of the European Union prohibits discrimination on the basis of disability (Article 21) and recognises the right of persons with disabilities to independence, social and occupational integration and participation in the life of the community (Article 26). Since 1983, the Commission has supported the development of a European disability policy through a succession of action programmes. In 2003 the Commission launched a disability action plan for the period 2003-2010. While important steps were taken in this period to improve the lives of persons with disabilities in the EU, the external contractor in charge of the action plan evaluation also reported critical views of stakeholders on the adequacy of the existing policy and regulatory frameworks at the EU level to address the needs of people with disabilities. Building on the results of the action plan, the European disability strategy was adopted in 2010, while the process for the ratification by the EU of the UNCRPD was underway. Through the ratification, the EU committed to comply with the Convention’s obligations and set up the necessary coordination and implementation mechanisms for its implementation. The Strategy was conceived as the policy framework through which the EU would deliver the commitments made under the UNCRPD in line with the respective competences provided for in the Treaties. 2.1.2 The Strategy The Communication which set-out the Strategy in 2010 presented it as “a framework for action at EU level, as well as with national action to address the diverse situation of men, women and children with disabilities”. The overall purpose of the Strategy was to “promote a barrier-free Europe and to empower persons with disabilities so that they can enjoy their rights and participate fully in society and economy”. Achieving those objectives required policies and actions at the level of the EU and of the Member States, with due regard to their respective competences. The Strategy identified eight key areas for improvement with the following specific objectives: 1)Accessibility: making goods and services accessible to persons with disabilities and promoting the market of assistive devices 2)Participation: ensuring that persons with disabilities enjoy all benefits of EU citizenship, removing administrative and attitudinal barriers to full and equal participation, promoting the provision of quality community-based services 3)Equality: eradicating discrimination on the grounds of disability in the EU

4)Employment: enabling many more persons with disabilities to earn their living on the open labour market 5)Education and training: promoting inclusive education and lifelong learning for pupils and students with disabilities 6)Social protection: promoting decent living conditions for persons with disabilities 7)Health: fostering equal access to health services and related facilities for persons with disabilities 8)External action: promoting the rights of persons with disabilities within the EU external action The Strategy also included four instruments to support its overall implementation: awareness raising; financial support; statistics, data collection and monitoring; mechanisms required by the UNCRPD. The instruments, like the areas, pursue specific objectives: a)Awareness raising: raising society’s awareness of disability issues and foster greater knowledge among persons with disabilities about their rights b)Financial support: optimising the use of EU funding instruments for accessibility and non-discrimination and increasing visibility of disability-relevant funding possibilities in post-2013 programmes c)Statistics, data collection and monitoring: supplementing the collection of periodic disability-related statistics with a view to monitoring the situation of persons with disabilities d)Mechanisms required by the UNCRPD: establishing mechanisms at EU level for the implementation of the UNCRPD An annex to the Strategy included the “list of actions” to be implemented during the period 2010-2020 for achieving the Strategy’s objectives. 2.1.3 The UNCRPD The Strategy is closely linked with the UNCRPD. The Commission adopted the Strategy in November 2010, shortly before the EU ratified the Convention in December 2010. By 2018, all EU Member States had also ratified the Convention.

The UNCRPD is a legally binding human rights treaty. Consequently, at the EU level, its provisions are an integral part of the EU’s legal order and all existing and future legislation must be in line with the UNCRPD. As parties to the Convention, both the EU and its Member States are obliged to implement their obligations under the Convention according to their respective competences. However, the scope of the Convention is very broad and it covers all the aspects of the life of persons with disabilities for their full inclusion in society. The Strategy, through its eight areas and its four implementation instruments, covered part of the scope of the UNCRPD. 2.1.4 The competences of the EU The EU has only the competences conferred on it by the Treaties and may only act within the limits of its competences (principle of conferral). Based on this principle, the EU and the Member States are obliged to implement their obligations under the UNCRPD according to their respective competences. The Council Decision concerning the conclusion by the EU of the UNCRPD declared the extent of EU competences with respect to the matters governed by the Convention, and a secondary legislation was identified and listed in a declaration in annex to illustrate the extent of the area of EU competence. The Decision explains that the scope and the exercise of EU competence are, by their nature, subject to continuous development and that the EU will complete or amend the declaration, if necessary, in accordance with Article 44(1) of the UNCRPD. This division is also reflected in the scope of the Strategy which includes fields where the EU and the Member States have “shared competences”, and fields where the EU has only a “supporting competence”. In the fields falling under shared competences, both the EU and the Member States have the power to adopt legislative measures. Fields of shared competence broadly include internal market, transport, social policy, employment, equality, development cooperation and humanitarian aid. In the fields where the EU has supporting competences, the EU can only supplement, support, and coordinate the actions of the Member States. Areas where the EU has supporting competences include health, education and training. In order to comply with the principle of conferral and with the obligation for the EU to only act within the limits of its competences, the Strategy was issued in the form of a communication, so that its content, although binding for the Commission, did not directly commit other EU policy makers or the Member States. Member States were obliged to follow-up on the Strategy’s actions only when those actions have a binding nature. This was the case, for example, of the European Accessibility Act, the Web-Accessibility Directive, the Audiovisual Media Services Directive, or the European Electronic Communications Code, which were part of the Strategy’s implementation plan and, once adopted, are binding also for the Member States. As a result, the evaluation focuses on the actions taken by the EU and the Commission in particular, in relation to the Strategy and, to some extent, on actions taken at Member State level to implement EU decisions. This limitation showed the need for a broader view about national action and progress in the future. 2.1.5 Intervention logic In the years prior to the Strategy the proportion of persons with disabilities across the EU was about 16 % of the working-age population, and there was general agreement that demographic trends (i.e. ageing population) would lead to an increase in the number of persons with disabilities. Evidence showed that persons with disabilities were poorer than the average European, less likely to have a job, and they faced barriers in accessing goods and services such as education, healthcare, transport, housing and technology. The Strategy aimed to mobilise or establish several policy instruments and governance structures (inputs) for achieving its goals. This includes Commission staff time and financial resources to deliver specific actions. Specific EU level actions were devised for each of the eight areas of action and the four implementation instruments (the actions are described in a “list of actions” published in annex to the Strategy). The Strategy intended to supplement and support Member State actions. In that regard, Member States contributed toward achieving the Strategy objectives through using national resources, such as national, regional, and local funds, in combination with the EU funds and by implementing policy initiatives at national level. Implementation of specific actions of the Strategy can be observed in the form of outputs and results / impact. The key outputs entail the adoption and transposition of EU legislation on disability, the development of toolkits for the implementation of EU disability-related policies, the organisation of awareness-raising sessions and dialogue events with regard to disability rights, the pursuit of research studies on disability, and the overall mainstreaming of disability considerations in EU and national policies. The expected results and impacts of the intervention were the gradual removal of disability barriers and the improvement of the situation of persons with disabilities in the specific areas of the Strategy. Impacts and results were therefore expected at an individual level, and the increase of the capacity of the Member States to improve the lives of persons with disabilities at a system level. The achieved outcomes from these interventions were expected to generate sustainable and lasting effects in the inclusion and participation of persons with disabilities, increasing their capacity to fully enjoy their fundamental rights and freedoms. The intervention logic was reconstructed in the Study and its graphical presentation is included in Annex 3. 2.2 Baseline and points of comparison

The Strategy pursued its objectives through the implementation of a “list of actions” to be carried out and completed during the Strategy’s ten-year period. This list of actions serves as baseline for the Strategy. The extent to which the actions have been implemented is the main point of comparison to evaluate how the Strategy was implemented over time. The Strategy did not have a clear method for qualitatively assessing the progress of each action. As a result, evaluating the extent to which actions were implemented has required the definition of a specific methodology, which is reported under Section 4 and Annex 4 of this Staff Working Document.



3.Implementation / state of Play 3.1 Description of the current situation The abovementioned “list of actions” constitutes the operational implementation plan across the Strategy’s thematic areas. The implementation plan comprises 150 measures – legislation and other related policy instruments such as soft law measures, standards and research/studies – and was initially intended for the first five years of the Strategy. The mid-term review of the Strategy published in 2017 confirmed the relevance of the actions also for the remaining period of implementation. In general, the findings of the supporting Study show that 101 actions of the Strategy (67% of total) were fully implemented throughout the whole implementation period. 40 actions (27% of total) were partially implemented and 9 actions (6% of total) were not implemented. Figure 1: Implementation of the Strategy overall Source: ICF analysis Figures 2.1 and 2.2: Implementation by thematic area (number and percentage)

Source: ICF analysis The areas with the highest level of implementation were Participation, Equality and Employment. The area with the lowest level of implementation was External action. In relation to the implementation instruments, all the actions were fully or partially implemented. Only one action was not implemented for the implementation instrument of Statistics, data collection and monitoring (name of the action: “Work towards a legal basis for a health and social integration survey implementing Regulation (EC) 1338/2008 on public health statistics”). Figures 3.1 and 3.2: Implementation by implementation instrument (number and percentage) Source: ICF analysis The detailed overview with the level of implementation of each action is reported in Annex 5 of the Staff Working Document.

4.Method 4.1 Short description of methodology The evaluation of the Strategy is based on a set of evaluation questions linked to the five assessment criteria defined by the Better Regulation guidelines (effectiveness, efficiency, coherence, relevance and EU added value). These questions were broken down into sub-questions and developed as operational questions appropriate for stakeholder responses. An evaluation framework describing this process is included in the Study. In addition, the analysis of the criteria built on the intervention logic is represented graphically in Annex 3 of this Staff Working Document. In line with the Better Regulation provisions, the evaluation has first to provide answers to each evaluation question and then provide conclusions about the overall implementation of the Strategy. 4.1.1 Sources of information The Roadmap for the evaluation of the European Disability Strategy 2010-2020 was published on the European Commission ‘Have your say’ web portal from 28 September 2018 until 26 October 2018. An external and independent supporting study (“the Study”) was conducted to support the evaluation, between March and December 2019. The main objective of the Study was to evaluate the effectiveness, efficiency, relevance, coherence and EU added value of the Strategy and assess the extent to which the Strategy has reinforced the implementation of the UNCRPD. The methodological approach to the Study combined quantitative and qualitative data that have been systematically gathered and triangulated to assess the implementation of the Strategy and to formulate judgements for answering the evaluation questions and providing conclusions on the Strategy. Evidence has been gathered during the whole evaluation process through different methods and from different sources: -Desk research: analysis of existing studies, policy documents, position papers and legislative acts related to the Strategy and to EU disability policy. -Targeted consultations: structured interviews and focus groups with 182 selected stakeholders at EU and at Member State level. An inclusive research methodology has been adopted to allow participation by the widest possible numbers of stakeholders. -Online public consultation: an internet-based consultation (running from 31 July until 13 November 2019) open to all EU citizens and stakeholders was published in the Commission ‘Have your say’ web portal. 2,547 respondents took part in the consultation. 573 (22.5%) responses were from organisations, whereas 1,974 (77.5%) were from individuals.

-Online dedicated consultations: online surveys targeting organisations representing persons with disabilities and representatives of Ministries responsible for disability policy at national level. -Public events: gathering of feedback from participants to EU high-level events dedicated to disability policy and to the evaluation of the Strategy. Further information about the consultation work is included in Annex 2. The information collected through these different methods has been analysed and compared in order to test its validity and internal consistency (triangulation). The results have been consolidated and combined with analytical techniques to detect possible trends and patterns. The implementation plan of the Strategy did not include indicators or benchmarks for measuring the level of implementation of the actions or the level of achievement of its objectives. As a result, the evaluation of the Strategy required a method for determining to which extent the actions of the Strategy have been implemented and its objectives achieved. Each action of the Strategy has been analysed and assessed against a scale of possible outcomes. Actions have been assessed as: -Fully implemented -Partially implemented -Not implemented Explanations about the criteria for determining the outcomes are reported in Annex 5. The extent to which objectives were achieved is strongly determined by the level of implementation of the underlying actions. However, also other elements were used for the assessment of the objectives such as the perceived relevance of the actions, the relative state of play in 2010 and in 2019 (when statistical data is available), the feedback from stakeholders, or the influence of decisions taken by other institutions at Member State or EU level. The resulting judgements have been used to formulate answers to the evaluation questions and to draw conclusions about the implementation of the Strategy. 4.2 Limitations and robustness of findings Issues encountered during analysis: -Statistical data, and notably disaggregated data, for assessing the impact of the Strategy on the situation of persons with disabilities is not always available or updated. Nevertheless, data disaggregated by age and gender has been available on an annual basis in relation to prevalence of disability, employment, education and poverty risk rates. Health-related data has been available, also disaggregated by age and gender every several years. Where conclusions on the impact of the Strategy could not be fully supported through quantitative information, they were discussed with relevant stakeholders, including non-governmental organisations and Member States representatives, and submitted to expert advice, namely through the contractor’s network of experts, to test their robustness and reliability; -The absence of specific indicators and benchmarks for assessing the Strategy’s implementation and achievements in relation to the objectives made it necessary to develop an ex-post method for measuring the progress of the Strategy. However, there are indicators published annually on the gaps between persons with and without disabilities, in relation to the three headline targets of Europe 2020; -Some of the effects of the Strategy’s actions are to materialise only after the end of the Strategy; -Improvement in the situation of persons with disabilities can result both from actions at EU-level and at national and regional level. As the evaluation of the Strategy focused on EU-level actions, the assessment of the effectiveness of the Strategy in improving the situation of persons with disabilities cannot be directly correlated. Therefore, an estimation was provided, mainly based on the extent to which the actions of the Strategy were implemented. This assessment was also integrated with expert advice, feedback received by relevant stakeholders, and, where available, analysis of statistical data; -In relation to efficiency, the Study made efforts to estimate the costs of the Strategy and to quantify its results. However, such an estimation is difficult to assess in objective terms. Therefore, conclusions about the efficiency of the Strategy also relied on elements such as professional judgement, expert advice and stakeholder feedback.

Despite these limitations, the analytical framework and the data collected were adequate with regard to quality and breadth of representation from different categories of stakeholders. Where available data was limited, the evaluation extended its research base. Where shortcomings could not be mitigated fully, the Study relied on the contractor’s professional judgment, expertise and stakeholders’ feedback as the basis for providing assessment and conclusions. At the end of the evaluation exercise, this allowed for methodologically robust findings and conclusions. More details on the methodology adopted and on how issues were mitigated for each analytical task are reported in Annex 4.



5.Analysis and answers to the evaluation questions 5.1 Effectiveness The conclusions about the effectiveness of the Strategy and about the extent to which its overall objective, as well as objectives per key areas and implementation instruments have been achieved rely mainly on: the extent to which actions in the relevant areas have been implemented; expert advice; feedback received by relevant stakeholders; and, where available, analysis of statistical data. Overall, the Study suggests there has been good progress since 2010 in the participation of persons with disabilities in society and economic life, in the promotion and protection of their rights, and in the implementation of the UNCRPD across the EU. 56% of respondents to the public consultation carried out during the evaluation, agreed or somewhat agreed that the situation for persons with disabilities improved between 2010 and 2020 in their Member State (31% somewhat disagreed or disagreed). 46% of all respondents agreed or somewhat agreed that the situation for persons with disabilities improved over this period across the EU (11% somewhat disagreed or disagreed). The targeted stakeholder consultations in the Member States show that in the large majority of countries, the situation of persons of disabilities is seen as having improved at least to some extent over the last ten years. Table 1: Views on whether the situation for persons with disabilities improved in the Member States over the last ten years Agree Somewhat agree Neither agree nor disagree Somewhat disagree Disagree DE, DK, EE (3) AT, BE, CY, CZ, ES, FI, FR, EL, HR, IE, LT, LV, MT, PT, SK (15) BG, HU, IT, LU, NL, RO, SE, SI (8) PL (1) UK (1) Note: a) The Study national experts’ assessment is based on the information gathered from the stakeholder interviews and focus groups carried out in Member States. b) The table indicates the most common selection across all areas of action for each country; where there was no consensus among stakeholders, ‘neither agree nor disagree’ was selected. Source: Member State analysis performed by national experts in the context of the Study There is less agreement on the extent to which the Strategy helped to improve the situation for persons with disabilities. The Study’s national experts in seven Member States agreed that the Strategy has helped (BE, DE, EE, NL, PT, CZ, RO). But in ten Member States they disagreed (BG, ES, FI, SI, HU, IE, LT, MT, PL, SE) and in eleven Member States the experts expressed neither the agreement nor disagreement (AT, CY, DK, FR, EL, HR, IT, LU, LV, SK, UK). On the other hand, many EU-level stakeholders consulted during the Study, and especially the umbrella organisations representing persons with disabilities at EU level, agree that the existence of such a strategy at EU level is in itself crucial, as the adoption of a high-level EU policy document explicitly dedicated to disability has helped placing the disability agenda higher among the EU policy priorities. In terms of implementation, the Study concludes that not all actions were fully implemented, and that they contributed to a different extent to the achievement of their objectives. For example, in the area of Equality, almost all the actions were fully implemented. But the Study considered its objective as partially achieved because one of its most important actions (“Support the negotiation in Council of the draft Directive on equal treatment beyond the field of employment”) did not lead to the adoption of the Directive by the Council. Another element that limited the achievement of the Strategy is the broad scope of its overall objective. The Study suggests that for ensuring full achievement the Strategy would have required a wider and more comprehensive set of instruments and actions than those foreseen, including actions undertaken by Member States.

The following sections present in more detail the implementation of the Strategy across each of its areas and implementing instruments. Additional sections are dedicated to mainstreaming, to the identification of success as well as of hindering factors and to stakeholders’ engagement in the implementation of the Strategy. 5.1.1 Achievement of objectives and implementation the actions in eight key areas 5.1.1.1 Accessibility There has been on overall improvement in this policy area of accessibility whose objective was to ensure the accessibility of goods, services, including public services and assistive devices for persons with disabilities. 63% of actions in this area were fully implemented, including through legislation. The Study also suggests that the progress has been uneven across areas and that accessibility for persons with disabilities has been partially ensured. Accessibility is the area where the Strategy delivered its most visible legislative outputs, which reflect the level of competences of the EU: the adoption of the European Accessibility Act and of the Web Accessibility Directive, the adoption of the waterborne and bus and coach passenger rights Regulations, the provisional agreement of the Council and the Transport and Tourism Committee of the European Parliament on the proposal of re-cast of the rail passengers’ rights Regulation, the revision of the Commission Regulation on the technical specifications for interoperability relating to accessibility of the Union's rail system, the inclusion of accessibility provisions in the Audiovisual Media Services Directive, the new European Electronic Communications Code, the so-called “Marrakesh” Directive, and the inclusion of mandatory accessibility requirements for projects financed through EU funds. Regarding the problems related to compensation claims concerning damages of mobility equipment when travelling, this is addressed now in all passenger rights Regulations except for air passenger rights, where the Commission has proposed to amend the rules accordingly. The European Accessibility Act was a much-anticipated legislative action of the EU to ensure that goods and services including public services and assistive devices for people with disabilities are accessible, and it took four years to adopt it. All stakeholders considered its adoption as an important achievement of the Strategy and a positive step for improving the level of accessibility throughout the Union. Some stakeholders are critical about the voluntary approach to the application of the accessibility requirements for the built environment and see this as reducing the potential positive impact of the Act on the accessibility of goods and services by persons with disabilities. The limited progress in the field of built environment remains a challenge. This includes the scope limitations of the Accessibility Act (accessibility of the built environment is subject to voluntary adoption by the Member States) and the fact that most of actions of the Strategy related to the built environment (standardisation mandate on accessibility of the built environment, inclusion of accessibility in curricula of architect and engineers, inclusion of accessibility in the Lead Market Initiative for sustainable buildings) were not implemented within the timespan covered by the evaluation. In the field of copyright, the “Marrakesh Directive” provides for a mandatory exception to copyright as regards printed works in formats accessible to persons with disabilities. As required by its Article 9, the Commission has started the preparation of a report on disabilities and on type of works which are not covered by the Directive. The EU level targeted consultations held within the evaluation (interviews with the academic network of experts, international non-profit associations, and independent network organisations) highlighted that actions in the area of accessibility tend to focus on visible disabilities. For non-visible disabilities, such as intellectual disabilities and psychosocial disabilities in general, many of the accessibility needs have not been fully addressed by the Strategy (simplified environments, pace and complexity of information provided to the public, mental health literacy of public officials, specific awareness raising initiatives dedicated to invisible disabilities). 5.1.1.2 Participation The Strategy’s actions were directed at enabling persons with disabilities to enjoy all the benefits of citizenship, removing administrative and attitudinal barriers to full and equal participation and providing quality community-based services, including access to personal assistance. More than 80% of these actions have been fully implemented. The initiatives that most contributed to fulfilling the objective of this area are the following: -Activities in support of independent living, and notably EU funding legislation allowing the Member States to support measures for the shift from institutional to community-based care, which led to concrete results in different Member States. -Implementation of the European disability card pilot project, conceived to address the issue of lack of mutual recognition in disability status among Member States and to ensure equal access to benefits across borders for people with disabilities, mainly in the areas of culture, leisure, sport and transport. A pilot of the card was launched in February 2016 in a group of eight EU Member States By the end of 2020 the Commission will conclude the assessment on the implementation of this pilot project.

-The Inclusion and Diversity Strategy which promotes participation of young people with disabilities into Erasmus+ youth mobility projects. -Initiatives to promote participation into sports through funding for disability-specific sporting events, projects (through Erasmus+), awareness raising actions (like the BeInclusive EU sport award) or events (such as the European Day of Persons with Disabilities conference 2019 where challenges encountered by persons with disabilities in sport were thoroughly discussed). In this area it is also important to mention the June 2019 Council Conclusions on Access to sport for persons with disabilities. The majority of stakeholders consulted in the evaluation process considered that the Strategy helped improve participation of persons with disabilities in society. They also considered that the Strategy made an important contribution in supporting the process of de-institutionalisation via the EU funds, thus supporting persons with disabilities to live independently and with adequate assistance. However, the Study also suggested that the objective to achieve full participation of persons with disabilities in society was partially achieved, because, despite progress in this area, barriers to participation still persist. Among the main obstacles, the Study identified the following: -Stakeholders from organisations representing persons with intellectual disabilities and charities have expressed concerns about the limited strategic vision in Member States for the transition from institutional to community living, and specifically, the lack of assessment of the needs of persons with disabilities and of measures to ensure their social inclusion. These concerns point out that the inclusion of the ex-ante conditionalities in the context of ESI Funds may not always be sufficient to guarantee the swift transition from institutional to community-based services. Nevertheless, stakeholders acknowledge the overall benefits deriving from the ex-ante conditionalities as well as the EU efforts to ensure their application. This resulted in better funding for projects that contribute to the social inclusion of persons with disabilities. -There is still limited data collection on life conditions in residential institutions, and limited promotion of best practices on independent living. -The Strategy has limited focus on autonomy of persons with disabilities. The respect of individual autonomy is one of the general principles of the UNCRPD and it refers to the right of persons with disabilities to have reasonable life choices, to be subject to minimum interference in private life and to be legally entitled to make own decisions (including political participation), with adequate support if required. The Study points out that autonomy was not part of the Strategy’s implementation efforts despite its importance for the overall participation objective. Although legislation on legal capacity is a national competence, the EU could have done more to promote the understanding of autonomy issues by public officers, especially among the judiciary and medical professionals. -Organisations of persons with disabilities advocating for independent living underline that there is limited attention at EU level about the promotion of personal assistance through ESI Funds. They consider that funding personal assistance would be effective for improving overall participation of persons with disabilities in society. 5.1.1.3 Equality The Strategy’s objective in the area of equality was to eradicate discrimination on the ground of disability across the EU. The Study suggests that this objective, although highly desirable, is an ambitious target to be achieved during the ten year implementation period of the Strategy. The fulfilment of this objective would have required heavy changes (in terms of legislation, attitudes, social and economic conditions also at national and local level) that would have gone beyond the Strategy’s possible scope for achievement. In terms of implementation, the Strategy proposed the adoption of eleven actions in the field of equality, and over 80% of the actions have been fully implemented (more details are available in Annex 5). The shared competences of the EU in this field make it possible to adopt legally binding acts. One of the key actions under this area was “Monitoring the application and impact of Directive 2000/78/EC for improving employment of persons with disabilities”. The action was fully implemented. In 2014, the Commission presented an implementation report concluding that all Member States had taken the necessary measures to transpose the Directive into their legal orders. The report also highlighted that some Member States had faced initial difficulties in correctly transposing the provisions on reasonable accommodation. In its conclusions, the report highlights the importance of awareness raising to increase knowledge of the already existing protection and to ensure better practical implementation and application of the Directive.

Another key action under this area was to “Support the negotiation in Council of the draft Directive on equal treatment beyond the field of employment”. In 2008, the Commission presented a proposal for a horizontal Directive on equal treatment (Equal Treatment Directive), but the proposal has since then been blocked in the Council because the required unanimity has not been reached so far. As a result, despite being partially implemented, the action did not lead to the expected results and the non-adoption of the Equal Treatment Directive has left a legal gap in terms of protection from disability-based discrimination. The Equal Treatment Directive The Commission adopted the proposal for an Equal Treatment Directive in 2008, which has not yet been adopted by the Council of the European Union, composed of all EU Member States. The proposed Directive would expand protection throughout the European Union against discrimination on the grounds of religion or belief, disability, age and sexual orientation to the areas of social protection including healthcare, education, and access to and supply of goods and services including housing. Many stakeholders consider that the adoption of this Directive is essential for prohibiting discrimination on the ground of disability. The remaining actions under this area focused on awareness raising and they were fully implemented. However, the Study suggests that these measures were not sufficient for eradicating discrimination against persons with disabilities. In relation to the area of equality, the Study suggests that the ambitious formulation of its objective, the non-adoption of the Equal Treatment Directive and the limited scope of the remaining actions, led to partial achievements in eradicating discrimination based on disability in the EU. 5.1.1.4 Employment The Study suggests that the Strategy has been effective in implementing employment policy tools, but that its impact in increasing the participation of persons with disabilities in the open labour market is not clearly measurable. In the area of employment 75% of actions were fully implemented, 19% partially implemented, and 6% not implemented. The Study suggests that the actions of the Strategy in the area of employment have been effective in relation to the following issues: -Use of EU funds for supporting employment of persons with disabilities. -Awareness raising about disability rights in the field of employment and specifically in the private sector. -Putting in place diversity charters and exchanges with employers on diversity. -Improving the statistical data on the situation of persons with disabilities in the field of employment. In relation to policy tools, the study highlights that the European Pillar of Social Rights (“the Pillar”), in its principle 17 “Inclusion of persons with disabilities”, explicitly asserts the right to services that enable persons with disabilities to participate in the labour market and in society, and to a work environment adapted to their needs. In relation to statistical data, the Study highlights that the creation of the 2011 Labour Force Survey ad hoc module focusing on employment of disabled people and the imminent inclusion of a proxy variable on disability every two years in all population surveys coordinated by Eurostat are important achievements from a policy point of view. These results, combined with the analytical work of Academic Network of European Disability experts (ANED), are particularly important tools for the formulation of adequate policies and legislative initiatives in relation to disability and employment. On the other hand, the non-implementation of a specific indicator on employment of vulnerable groups by the EMCO indicators’ group appears as a major shortcoming in the evaluation. Despite these results, the stakeholders’ views on the extent to which the Strategy enabled many more persons with disabilities to earn their living on the open labour market are significantly diverging. Organisations representing persons with disabilities, business organisations and citizens responding to the public consultation tended to consider employment among the worst performing areas of the Strategy due to the persisting gaps between persons with disabilities and without disabilities: only 40% of the respondents with knowledge of the Strategy to the public consultation agreed/somewhat agreed that progress for persons with disabilities had been made in the area of employment. On the other hand, institutional stakeholders at EU and Member State level consider that the Strategy has brought positive effects in the field of employment thanks to the improvements in statistical data and awareness raising. In terms of general outcomes, there has been an increase in economic activity rates and employment rates for persons with disabilities since the adoption of the Strategy in 2010. The activity rate (age group 20-64) in the EU-28 increased from 56.1% (2010) to 62.4% (2018) and the employment rate for the same age group increased from 46% (2010) to 52% (2018). A similar trend is observed for persons without disabilities. In addition, the employment gap between people with and without disabilities has decreased only slightly over the years, from 26 percentage points in 2010 to 24.2 percentage points in 2018 in the EU 28. Thus, the Study suggests that the actions of the Strategy, which complement the activities of the Member States, have not been decisive for significantly reducing the labour market participation gap. It should also be noted that the respondents to the public consultation have identified employment as one of the five most important topics to be considered for the future policy (together with accessibility of buildings and public services, ageing and disability, independent living and inclusion in the community, children with disabilities and their families). 5.1.1.5 Education and training

The study suggests that, although the Strategy contributed to promote inclusive education and lifelong learning for pupils and students with disabilities, its impact in this area is not clearly measurable. In this area, the EU has supporting competences and no power to propose or enact fundamental changes through legislation. Therefore, the activities proposed by the Strategy were mostly focused on soft law instruments, funding, and awareness-raising (research data collection and dissemination). The actions related to funding were those with highest implementation rate, whereas those relating to awareness raising were partially implemented. In the area of Education and training 36% of actions were fully implemented, 55% were partially implemented, and 9% were not implemented. This makes Education and training one of the areas with lower implementation rates, with concerns over its effectiveness raised by the Study. There was consensus among different types of EU level stakeholders interviewed that the Strategy achieved some significant results in supporting programmes for the inclusion of children with disabilities into education, trainings for teachers, educators and staff who work with children with disabilities, as well as in raising awareness and promoting good practices. Such programmes and policies supported the actions of the Member States to implement the Strategy objectives. Stakeholders representing persons with disabilities pointed out that in relation to education the Strategy did not include specific measures for the assistance to persons with disabilities in the transition from education to the labour market. On the other hand, the Study highlighted that in terms of outcomes, educational gaps between persons with disabilities and persons without disabilities still persist. The share of early school leavers with a disability (age group 18-24) in the EU increased between 2010 and 2016 from 21.6% to 23.6%, with a decrease to 19.9% in 2018. Over the same period, the share of early school leavers with no disability fell (from 12% in 2010 to 11% in 2016 and 9.9% in 2018). The gap between persons with and without disabilities has not changed significantly over the years, slightly deteriorating from 9.6 percentage points in 2010 to 10 percentage points in 2018. Data from ANED show that educational gaps also persist among persons having completed a tertiary or equivalent education. In 2010, 22.6% of persons with disabilities as compared to 34.7% of those without disabilities (age group 30-39) completed a tertiary or equivalent education. In 2018, 32.6% of persons with disabilities completed tertiary or equivalent education as compared to 43.2% of those without disabilities. Thus, the gap between the two groups has not changed significantly throughout the years, remaining at around 12 percentage points. 5.1.1.6 Social protection For the area of social protection, the objective of the Strategy was to promote decent living conditions for persons with disabilities. The Study suggests that, although living conditions of persons with disabilities are a predominant competence of the Member States, and despite persisting gaps in social protection in relation to disability, the EU action in this field has contributed to better living conditions of persons with disabilities. Its policy actions, including the European Pillar of Social Rights, have contributed to the promotion of more inclusive social protection systems. The organisation and financing of social protection systems is mainly a responsibility of Member States and governance tools at EU level are predominantly of a soft nature. Within the scope of its competence, the EU has carried out an important range of initiatives for the promotion of decent living conditions. In terms of implementation, 67% of the actions under this area were fully implemented and 33% were partially implemented. As concerns general outcomes in the area of poverty and social exclusion, the situation of persons with disabilities has not changed substantially over the years. The gap between persons with disabilities and persons without disabilities has widened. According to Eurostat EU SILC statistics, the rate of persons with disabilities at risk of poverty and social exclusion in the EU-28 was 29.6% in 2010 (20.8% for those without disabilities) and 29.1% in 2019 (18.4% for those without disabilities). This means that over the same period, while the risk of poverty and social exclusion decreased by 2.4 percentage points for persons without disabilities, it decreased by only 0.5 percentage points for persons with disabilities. The data also show that gaps between persons without disabilities and persons with disabilities as regards the risk of poverty and social exclusion persist (8.8 percentage points in 2010 and 10.7 percentage points in 2019). Opinions of stakeholders about the success of the Strategy in promoting decent living conditions are diverging, even within the main groups of stakeholders. Overall, the Study suggests that the Strategy’s objective of this area has been partially achieved. In 2017, the European Parliament, the Council and the European Commission jointly proclaimed the European Pillar of Social Rights, an overall policy framework meant to achieve better working and living conditions in the EU. The European Pillar of Social Rights allows for a better degree of coordination, integration and improvement of social policies across the EU, and it specifically recognises the right of persons with disabilities to inclusion. The European Commission has proposed legislation to advance with the implementation of the European Pillar of Social Rights, including a Directive on work-life balance that was meanwhile adopted by the EU legislator, setting new and improving existing leave rights for parents and carers, and a Council recommendation on access to social protection for workers and the self-employed that also covers disability and invalidity benefits. As concerns financial support, the EU invested into social inclusion and related national reforms via its Funds and programmes, such as the European Social Fund (ESF and ESF+), the European Regional Development Fund, the Rights, Equality and Citizenship programme and the EU programme for Employment and Social Innovation, as well as through the Structural Reform Support programme, where persons with disabilities are amongst the target groups. These investments helped to improve the situation of persons with disabilities, as they contributed to the development of social services, community based services and social economy. These improvements are also closely linked to deinstitutionalisation, a process that requires to couple the planned closure of long-stay residential institutions with the development of individualised services, and with making general services available to persons with disabilities. 5.1.1.7 Health

Health is mainly a national competence and the EU can only complement Member State action through initiatives such as policy monitoring, mutual learning and funding. The Strategy included twelve actions to foster equal access to health services and related facilities for persons with disabilities. Throughout the period 58% of the actions under this area were fully implemented, 33% were partially implemented and 8% were not implemented. Despite these results, the Study suggests that the Strategy did not fully achieve its objectives in this area. This is mainly due to the limited scope of the actions, the limited competence of the EU in this field, the limited availability of data and information on the situation of persons with disabilities and the lack of disaggregated data, which have prevented the development of appropriate policies and their monitoring. Among the respondents to the public consultation only 38% of those with a disability agreed or somewhat agreed that the Strategy helped to improve health for persons with disabilities. Consultations with the Study national experts reach similar conclusions, with fifteen Member State reports concluding that the Strategy did not have a significant impact on improving the situation of persons with disabilities in the field of health at Member State level. Despite these considerations, the Study suggests that the Strategy helped in mainstreaming disability considerations in legislation notably on cross-border healthcare (the Patients’ rights Directive). The Strategy also supported the production of statistics, data collection and monitoring activities, notably: -The development of the 2011 EU-LFS ad-hoc module on the employment of persons with disabilities -The European Health Interview Survey -The 2012/2013 European Health and Social Integration Survey (dedicated disability survey) Data from EU-SILC indicate that there has been some improvement with regard to self-reported unmet needs for medical examination for persons with disabilities, which decreased from 7.6% in 2012 to 4.5% in 2019. As concerns persons without disabilities, it was 1.9% in 2012 and 1.1% in 2019. The study – in particular the Member States analysis – also points to the importance of EU funding to resource implementation, particularly in areas like health where the EU has limited legislative competence. 5.1.1.8 External action Overall, the actions implemented during the Strategy contributed to promote the rights of persons with disabilities within the EU external action. However, because only two of the eleven actions of the Strategy were fully implemented (all other actions were partially implemented), the evaluation suggests that the objective has been partially achieved. This seems also reflected in the results of the public consultation responses in relation to external action, which may reflect a low level of knowledge among respondents of the actions in this area of the Strategy. At international level, the inclusion of external action as an area of the Strategy, together with the ratification by the EU of the UN Convention, has raised awareness that the EU wants to engage with countries across the globe to improve the situation for persons with disabilities. There are several important actions of significance for the implementation of this thematic area, including the promotion of disability rights in the EU Action Plan on Human Rights and Democracy 2015-2019 and the publication by the European Commission of an operational guidance on the inclusion of persons with disabilities in EU-funded humanitarian aid operation. Disability considerations have been included in the 2017 European Consensus on Development as well as in the 2014 Council conclusions on a rights-based approach to development cooperation, encompassing all human rights. In terms of capacity building, the network of disability focal points in EU Delegations and Headquarters has been relaunched in October 2019, and information on disability matters has been integrated in the Rights Based Approach training addressed to the staff. The Study suggests that the EU initiatives in the field of external action follow the framework of the UNCRPD. However, the Study also suggests that there is limited evidence that EU initiatives undertaken in this field have been significantly influenced by the Strategy. A shortcoming in the field of external action is related to the lack of indicators for planning and monitoring interventions with specific reference to disability (disability markers). The absence of these markers has limited the capacity to quantify disability initiatives in external action, and the extent to which the rights of persons with disabilities were promoted. However, the new OECD transversal disability policy marker, which is in use in the Commission services of development cooperation since January 2019, will allow to follow up and assess the disability inclusion in the future. Finally, a few stakeholders active in the field of international cooperation suggested that inclusion in the Strategy of further actions could have contributed to the achievement of the objectives of the Strategy to better reflect the EU’s commitment to disability inclusion. Further actions could have included, for example, promoting the use of the Washington Short Set of Questions by partner countries as well as the refurbishing of EU institution buildings including EU Delegations in partner countries to make them accessible.

5.1.2 Achievement of objectives and implementation of the actions for the implementation instruments 5.1.2.1 Awareness raising The objective of the Strategy in this field was to raise society’s awareness of disability issues and foster greater knowledge among people with disabilities of their rights and how to exercise them. Out of the five actions included in the Strategy, four have been fully implemented and one has been partially implemented. Although further efforts are needed to promote positive and realistic images of persons with disabilities in all sectors of society, the Strategy has given a significant contribution to awareness raising, especially at EU level. The Study suggests that the Strategy has been instrumental in increasing the level of awareness about disability issues at EU institutional level, also leading to more inclusive EU policies and legislation. The two main public disability events organised by the European Commission, the Access City Award and the European Day of Persons with Disabilities have gained growing visibility and momentum among disability stakeholders. For the 2020 edition of the Access City Award, 47 cities from across the EU sent applications. During its ten years of existence, 321 cities have participated in the Access City Award. However, only 33% of respondents to the public consultation declared having knowledge about the European Access City Award (30% of individual respondents and 56% of organisations). This suggests that knowledge about the Access City Award is common among institutional stakeholders, and not only at EU-level, but still limited among the general public. The European day of Persons with Disabilities is an annual international conference gathering over 400 participants from all over the EU to discuss specific themes of importance for persons with disabilities. The conference is an important forum for discussion at EU level. It is regularly attended by Members of the College of the Commission, members of the European Parliament and representatives of EU and international institutions (such as the Fundamental Rights Agency and the United Nations), as well as umbrella organisations representing persons with disabilities at EU level, and persons with disabilities themselves, invited by the Commission. In the public consultation, 65% of respondents declared having knowledge of the European Day of Persons with Disabilities (59% of individual respondents and 85% of organisations). Major awareness raising campaigns have been organised throughout the European Union about topics related to disability. An example is the #EUvsDiscrimination campaign on combating discrimination in the workplace. One of the main strands of the campaign addressed reasonable accommodation in the workplace for persons with disabilities (videos were produced and several events were held in Member States where the employment gaps between persons with and without disabilities are the largest). Based on feedback from experts and stakeholders, the Study suggests that there is growing awareness in society about disability and about rights of persons with disabilities and that this is strongly related to the adoption by all EU Member States of the UNCRPD. The Study also suggests that in the area of awareness raising, the Strategy has been complementary to the UNCRPD and has contributed to its implementation. 5.1.2.2 Financial support The objective of the Strategy in this field was to optimise use of EU funding instruments for accessibility and non-discrimination and increase visibility of disability-relevant funding possibilities in post-2013 programmes. The Study suggests that the objective has been partially achieved. The Strategy proposed the adoption of eleven actions in the field of financial support. Over 80% of the actions have been fully implemented. All stakeholders agree on the positive effect of EU funding for the implementation of Strategy, which in some key areas such as deinstitutionalisation was essential for its progress. The Study also pointed out some weaknesses of the EU financial support system. Funding was limited and not adequate for the full implementation of the Strategy. Financial resources allocated to social issues usually did not include dedicated budget lines for disability. Stakeholders also pointed out that funding is not fully accessible for persons with disabilities due to inaccessible procedures and administrative burdens, and that there is insufficient involvement of the disability community in funding programmes.

5.1.2.3 Statistics, Data Collection and Monitoring The objective of the Strategy in this field was to supplement the collection of periodic disability-related statistics with a view to monitoring the situation of persons with disabilities. The Study suggests that the objective has been partially achieved. The Strategy proposed the adoption of thirteen actions. Over 80% of the actions proposed in this field by Strategy have been fully implemented. Prior to the development of EU-wide statistics on disability, national definitions varied, as they were primarily used for determining benefit entitlements or for specific policies. The Study highlights that the work of Eurostat on incorporating disability considerations in their data collection especially regarding the incorporation in 2021 of a 2-year proxy variable on disability in all population surveys coordinated by Eurostat is a significant step towards a more effective data collection on the situation of persons with disabilities in the EU. In addition, the work of the Fundamental Rights Agency on indicators on the types and characteristics of institutional and community-based services in the EU could provide valuable information on how to improve community-based living. However, in relation to overall indicator development and data collection, the Study suggests that there is a need for better data collection across the key priority areas of the Strategy and that statistics and data collection relating to the Strategy are insufficient, especially in relation to disaggregated data. This opinion has been expressed by several umbrella organisations representing persons with disabilities at EU level. While several important steps were taken to improve the measuring of the situation of persons with disabilities in the EU, there are still challenges in this field that have not been addressed by the Strategy. The Study suggests that the main challenges are: 1) No concrete targets for the Member States or indicators for measuring their progress when implementing disability-related policies within the European Semester; 2) No single uniform approach to measuring access to healthcare across the EU; 3) No disaggregated data on disability. 5.1.2.4 Mechanisms required by the UNCRPD The objective of the Strategy in this field is to establish a governance framework in line with Article 33 of the UN Convention on implementation and monitoring. The Study suggests that the objective has been achieved. The Strategy proposed the adoption of four actions in this field, which have been fully implemented. As a result, a mechanism for the coordination and the monitoring of the implementation of the UNCRPD has been established at EU institutional level. However, the Study also highlights that the mechanism does not include focal points at Directorate-General level within the European Commission as well as in other EU institutions. This somehow hindered the development of disability-related knowledge and the mainstreaming of disability considerations in EU legislative or policy actions. 5.1.3 Mainstreaming of disability issues in EU policy and legislation The Study shows that, overall, the Strategy achieved positive results in mainstreaming disability issues in EU policy and legislation and that one of the main achievements of the Strategy was the placement of the disability agenda higher among the EU policy priorities. At a strategic level, key EU policy initiatives such as the Europe 2020 strategy, the European Pillar of Social Rights, or the European Semester process refer to disability issues and contain significant commitments to address the needs of persons with disabilities. Disability issues are also reflected in other strategies, such as the EU Health Strategy 2008-2013, the EU Digital Strategy, the mid-term review of the Education and Training 2020 (ET2020) framework, the Roadmap to a Single European Transport Area, the EU Youth Strategy, the EU’s Strategic Engagement for Gender Equality and the 2020 Communication re-launching the European Research Area, as well as the Communication on Achieving the European Education Area by 2025 and the Digital Education Action Plan. Recent policy documents such as the EU Gender Equality Strategy 2020-2025 and the EU Action Plan against racism 2020-2025 point to the need to address intersectionalities between disability and other grounds of discrimination.

Importantly, the Strategy was also instrumental in mainstreaming disability into the European Semester and several Member States received recommendations explicitly targeting disability. At a legislative level, the Strategy promoted greater change in areas where the EU has more competences. Initiatives with disability-related provisions include the European Accessibility Act, the passengers’ rights regulations and the adoption of legislation in EU investment and structural funds regulation stating the obligation that services and infrastructure financed through EU funds should be accessible to persons with disabilities. Nevertheless, the Study also concludes that there are areas of improvement, particularly with regard to the mainstreaming of disability considerations in the field of consumer protection. The Study also suggests that, despite improved mainstreaming of disability in policy and legislation, overall awareness about the UNCRPD within the EU institutions is still limited. Lack of consideration for disability-related issues since the outset of policy initiatives has sometimes resulted in burdensome adaptions and amendments during the policy-making process or in non-inclusive policies. 5.1.4. Success factors in implementing the EU Strategy In relation to the effectiveness of the Strategy, the Study has identified the following elements as success factors for its implementation: -Use of different types of actions: the list of actions of the Strategy included a mix of different types of legislative and non-legislative initiatives, which have been complementary in achieving the Strategy’s objectives. Legislative initiatives are binding in nature but have long implementation periods. Non-legislative initiatives (such as awareness raising, exchange of best practices and peer reviews) although non-binding, tend to yield results within shorter periods. -Integration with existing policy and legislative instruments: the Strategy leveraged on existing instruments to implement and mainstream disability at EU level. oIntegration with EU funds: funding legislation for the period 2014-2020 introduced a set of pre-conditions to be met by national authorities before funding, and requiring administrative capacity for the implementation and application of the UNCRPD and of anti-discrimination law and policy in the field of EU Funds. This resulted in a strong engagement at local level for more inclusive funding, especially in the field of accessibility. oIntegration of European Pillar of Social Rights and European Semester: the inclusion of disability in these two soft policy instruments allowed to further increase the visibility of disability policy at EU level and to issue specific disability-related recommendations in the context of the European Semester, thus creating stronger coordination between EU and Member States on disability policy. -Exchange of good practices and awareness-raising: the needs of persons with disabilities are similar across all countries. The exchange of good practices allowed individuals, organisations and governments to rely on a wide array of experiences and knowledge at EU level. Awareness raising activities allowed to reach types of stakeholders who are not always fully aware of disability issues (such as employers and companies). At international level, the ratification by the EU of the UNCRPD and the inclusion of external action as an area of the Strategy have made international stakeholders aware that the EU wants to engage with countries across the globe to improve the situation of persons with disabilities. -Joint effort with civil society: the implementation period of the Strategy saw an increased level of joint work and cooperation between civil society groups and EU institutions to deliver the Strategy, both through formal institutional governance arrangements and informal activities. The joint effort resulted in positive synergies especially in the following aspects: better understanding of problems and issues at stake, development of more inclusive policies and legislation, better awareness about disability issues at institutional level. 5.1.5 Gaps and challenges that hindered achievement of the objectives

The evaluation has identified the following elements as hindering factors for the implementation of the Strategy: Design issues: -Lack of a comprehensive set of indicators and benchmarks: the Strategy had no comprehensive indicators and benchmarks to assess the degree to which its objectives were achieved. This makes it difficult to provide an objective evaluation of its progress and to set up adequate monitoring mechanisms. -No monitoring framework: the Strategy had no structured and operative framework for regularly monitoring or evaluating its implementation. A first assessment of the Strategy progress only took place in 2017 on the occasion of the mid-term review, when the Strategy was well under way. The implementation of a monitoring framework (with a dedicated baseline, data collection tools, a clear timeline and measurable objectives) would have allowed regular evaluation of its progress, early detection of delivery gaps and identification of possible mitigating actions. Such a framework, if implemented, would have also allowed the provision of regular and transparent information to external stakeholders about the progress of the Strategy. -Limited focus on non-visible disabilities and children’s rights: actions, particularly in the area of accessibility, mostly focused on visible disabilities. The needs of persons with intellectual disabilities and with non-visible disabilities in general, have been taken into account to a lesser extent. These considerations also apply to children’s rights, which were not adequately included in the Strategy. -Limited scope in relation to the UNCRPD: several stakeholders consider that the Strategy’s scope did not capture the full range of rights of persons with disabilities, and that the Strategy should be aligned with the UNCRPD. The Strategy does not cover topics such as right to life, freedom from exploitation, violence and abuse, respect for privacy, respect for home and the family, and does not address women and children with disabilities, as well as people with disabilities from a minority or with a migrant/refugee status. Some stakeholders, especially at Member State level, consider that an alignment with the UNCRPD would have made the Strategy more impactful. However, the Study also suggests that full alignment of the Strategy with the UNCRPD might have been difficult considering that many competences in the field of disability are the responsibility of Member States. Implementation issues: -Uneven knowledge of disability issues at EU institutional level: despite positive results in mainstreaming disability issues in policy and legislation, general knowledge about disability and about the UNCRPD across the European Commission as well as across other EU institutions is still uneven. The Study suggests that the absence of dedicated focal points in the Commission services has limited the understanding of crosscutting issues and, ultimately, the effectiveness of the Strategy. -Limited inclusion in policy-making process: disability considerations are not applied at all stages of the policy or the legislative procedure, while they should be considered since the early stages of the process. -Limited training: the evaluation suggests that occasional training on disability has been provided to personnel working in the EU institutions, but that the training did not result in adequate general awareness on disability and in adequate knowledge among persons directly involved in disability policy-making. -Varying capacity of Member States and Regions to implement disability policies: due to the split of competences between the EU and the Member States, a broad range of factors influenced the general outcomes and important parts of the Strategy’s impact (and achievement of the Strategy’s objectives) depended on Member States action. Following the global financial crisis and the recession, there were widespread public spending cuts, which reduced the capacity of some Member States to implement actions related to the Strategy. -Limited knowledge sharing at stakeholder level: there has been a significant volume of research and information on good practice generated since 2010 across the eight areas of action. However, coordination of relevant partners at EU level and between Member States in mutual learning has been carried out only to a limited extent. Better knowledge sharing would have maximised the impact of available information and would have created better awareness and stronger connections between policy-makers and experts.

5.1.6 Engagement of stakeholders in the Strategy’s implementation The Study suggests that Member States, EU institutions and organisations representing persons with disabilities have been adequately engaged in the Strategy’s implementation via institutional mechanisms, public events, public consultations and informal meetings. These initiatives bring together a high number of stakeholders. They facilitate the exchange of information and ideas on policies and practices, and they stimulate the creation and the consolidation of disability networks. The Study suggests that the most effective fora for engaging with stakeholders at EU level are the following: -Disability High Level Group: meeting twice a year, it involves representatives of Member States’ institutions, the Commission, the Council of Europe and civil society on issues relating to disability and aims at facilitating the exchange of information, experiences, and good practices in the areas of disability and the implementation of UNCRPD as State Parties. -Work Forum on the Implementation of the UN Convention on the Rights of Persons with Disabilities in the EU and the Member States: is an event organised annually since 2010. The Forum involves persons with disabilities through their representative organisations, focal points, coordination mechanisms, monitoring mechanisms of the UNCRPD from the Member States and the EU and relevant international bodies. It specifically focuses on the implementation of the UNCRPD through exchanges on concrete measures undertaken by the States Parties and dissemination of information. -Strategic Dialogue Meetings: these meetings are organised on a monthly basis with civil society organisations, notably the ones active in the field of disability pursuing collective interests, and aim at advancing ideas in the field of disability in the areas of employment, inclusion and social affairs. -Annual Conference for Inclusive Growth: organized once a year, it is an action-oriented platform bringing together civil society organisations and policy-makers active in the field of employment, inclusion and social affairs to discuss how to achieve truly inclusive growth. The conference systematically includes a workshop related to specific disability issues related to the main topic of the annual conference, in order to ensure that the disability angle is taken into account in the debates and conclusions. -European Day of Persons with Disabilities: annual international conference gathering over 400 participants (persons with disabilities and their families, organizations representing persons with disabilities, experts, EU officials, politicians) from all over the EU to discuss specific themes of importance for persons with disabilities and ensure awareness-raising about disability policies at the EU and Member States levels. In terms of wider participation and in line with the Better Regulation provisions, the launch of the evaluation of all major EU policy and legislative initiatives (including the launch of the Strategy, its mid-term review, its final evaluation and the launch of any initiative having impact on disability) includes a wide consultation process involving all relevant stakeholders. Furthermore, private citizens are given the opportunity to express their views through regular on-line public consultations published on the ‘Have your say’ section of the Commission website. The online public consultation launched in 2019 on the occasion of the final evaluation of the strategy saw an increased participation by citizens and organizations compared to the mid-term review of 2017 (2,547 participants in 2019 versus 1,518 participants in 2017). In 2019, 1,237 respondents were persons with disabilities or caring for a person with disabilities. In 2017 their number was 563. Consultation with all relevant stakeholders, when carried out, has proven beneficial for both the stakeholders and the Strategy by providing a constant flow of feedback, opinions and ideas about all aspects of Strategy’s implementation, with important insights for the preparation of the future disability policy. However, in terms of stakeholder engagement, the study has also identified the following shortcomings: -Civil society organisations have not always been involved throughout the whole lifecycle of disability-related initiatives, especially in their conception phase. -Current fora do not always involve stakeholders representing the interests of persons with disabilities in the workforce (such as trade unions and support organisations of workers). -Meetings of the Disability High Level Group do not provide for sufficient space for exchange of experiences, benchmarks and good practices. More information on stakeholders’ consultation activities in the context of this evaluation is available in Annex 2.

5.2 Efficiency 5.2.1 Cost-effectiveness of the Strategy An overall assessment about the cost-effectiveness of the Strategy is difficult to quantify in objective terms. The Strategy is a soft-policy instrument with no dedicated budget and its results, which concern the participation of persons with disabilities in society and economic life, cannot easily be measured in economic terms. Moreover, most of the actions and objectives of the Strategy are carried out by different actors. As a general conclusion, the evaluation found that the Strategy was designed and implemented efficiently. This conclusion is based on the analysis of the costs of the Strategy and on feedback provided by relevant stakeholders in relation to its effectiveness. The evaluation also suggests that EU funds were effective in promoting and implementing de-institutionalisation as well as in supporting accessibility and social inclusion for persons with disabilities. As for other financial resources, grants to organisations representing persons with disabilities at EU level and funds for organising public events (such as the European Day of Persons with Disabilities, the Annual Conference on Inclusive Growth or the Access City Award) have proven highly effective in stimulating debate and in raising awareness about disability at EU level. 5.2.2 Adequateness and proportionality of resources The Study suggests that the resources allocated to the Strategy were not fully adequate and proportionate. Many stakeholders expressed the view that resources were not adequate for achieving the Strategy’s objectives. This opinion was more common among persons who declared having limited knowledge of the Strategy rather than among individuals having knowledge of the Strategy and among organisations representing persons with disabilities. On a positive note, the Study suggests that the Strategy has contributed to the increase of overall resources for disability-related issues, by raising general visibility and awareness on disability. EU funds remain the main source of funding, but the lack of clear and binding links between the Strategy and the EU funds was sometimes detrimental to the proportionate allocation of resources and their use for disability-related initiatives. In fact, many EU-funded initiatives, once implemented at national level, followed a broad-based approach aimed at solving general social problems rather than focusing on specific issues. As a result, disability-specific needs were sometimes overlooked during the implementation of those initiatives. 5.3 Relevance 5.3.1 Relevance of the Strategy in addressing the needs of persons with disabilities

The evaluation suggests that the Strategy has been relevant and continues to be relevant in addressing the rights and needs of persons with disabilities and in influencing EU law and policy processes. The EU’s ratification of the UNCRPD means that the Convention is part of the EU legal order. All EU Member States have also ratified the Convention. The Strategy, as the main instrument to implement the UNCRPD at EU level, helps to ensure that EU policies and initiatives relevant for persons with disabilities are designed and implemented in line with the UNCRPD provisions. Member States are also required to present their strategies to implement the Convention within the areas for which they are responsible and competent. The European Pillar of Social Rights and the European Semester are policy instruments used to coordinate economic and social policy processes across the EU. The Strategy has been instrumental in shaping and giving practical implementation to many principles of the Pillar, and specifically to principle 17, dedicated to the inclusion of persons with disabilities. In relation to the European Semester, the Strategy has provided a policy framework for identifying actions and recommendations to be included in the Semester’s process and for pursuing the overall goal of the Europe 2020 strategy to create ‘smart, sustainable and inclusive growth'. As persons with disabilities experience significant barriers in education, employment, and social protection, the Strategy has been relevant to pursue the European 2020 headline targets relating to employment, education, poverty and social exclusion. The Study suggests that the Strategy remains relevant in addressing the needs of persons with disabilities because it guides EU work in the implementation of the UNCRPD and it ensures mainstreaming of disability across all EU policies. However, the Study also suggests that the content of the Strategy had a strong operational nature due to the emphasis on detailed and numerous implementation actions, and that the role of its policy provisions was rather limited. 5.3.2 Relevance of the Strategy for its different stakeholders The Study suggests that the Strategy was highly relevant for institutions and stakeholders at EU level, due to its role in implementing the UNCRPD at EU level, but had limited visibility at Member State and citizen’s level. EU level stakeholders also widely agree that the areas of the Strategy remain relevant also for the future (with a relatively lower score for external action, that might be due to the fact that external action in the disability area is a priori less visible and impactful for EU stakeholders). Figure 4: Relevance of the current areas of action for future disability strategy Source: ICF analysis On the other hand, key policy-makers at Member State level seem to have prevalently some familiarity or no familiarity with the Strategy, which suggests a relative influence of the Strategy at this level. The table hereunder provides a breakdown about the level of familiarity with the Strategy among policy-makers and organizations representing persons with disabilities in the Member States. Table 2: Familiarity with the Strategy in the Member States How familiar with the Strategy are the policy makers (government) in your country? Very Familiar Somewhat familiar Not familiar PT, UK BE, BG, CY, CZ, DE, DK, EE, FR, EL, HR, LU, MT, RO, SI, SK AT, ES, FI, HU, IE, IT, LT, LV, NL,PL, SE How familiar with the Strategy are organisations representing persons with disabilities in your country? Very Familiar Somewhat familiar Not familiar DK, RO AT, BE, BG, CY, CZ, DE, EE, ES, FR, EL, HR, PT, SE, SK, UK FI, HU, IE, IT, LT, LU, LV, MT, NL, PL, SI

Source: Member State analysis performed by national experts in the context of the Study 5.4 Coherence 5.4.1 Internal coherence of the Strategy The evaluation suggests that there was a good level of coherence among the eight thematic areas and the four implementation instruments from a policy design perspective as they incorporate key issues relevant to improve the situation of persons with disabilities in the EU. From a policy design perspective, the Strategy combined well actions to remove barriers and empowering persons with disabilities to participate in society. It covered the fundamental issues of accessibility, participation, and equality. Removal of barriers in these areas are pre-conditions for success of specific measures related to employment, education and training, social protection and health. In this sense, the Strategy provided a coherent, stepwise framework to address issues that prevent persons with disabilities from playing a full role in society. The implementation instruments have proven to be a valid support for implementing specific measures included in the Strategy. For example, improved statistics helped improving targeting and assessment of the impact of particular actions, and funding supported delivery of particular actions. However, the Study suggests that, from an operational perspective, the objectives are not always coherent with the related actions of the Strategy because some of them are formulated in ambitious terms. If taken literally, their achievement would have required actions with a much wider scope, funding and strength, in terms of capacities as well as of outreach potential, than those of the Strategy. This consideration particularly applies to the overall aim of the Strategy (empower people with disabilities so that they can enjoy their full rights) and to the objectives in the areas of participation (achieve full participation of people with disabilities in society by enabling them to enjoy all the benefits of EU citizenship, removing administrative and attitudinal barriers to full and equal participation, providing quality community-based services, including access to personal assistance) and equality (eradicate discrimination on grounds of disability in the EU). 5.4.2 Coherence of the Strategy with other EU policies/ actions (Europe 2020, the European Pillar of Social Rights, the European Semester, the Charter of Fundamental Rights of the European Union and the EU funding provisions) In relation to external coherence of the Strategy, it is important to distinguish between instruments that pre-date the Strategy (e.g. the Charter of Fundamental Rights) and those that were adopted after the Strategy (e.g. the European Pillar of Social Rights). Considering that the EU ratified the UNCRPD in 2010 and that the Strategy provided a clear policy framework in the same year, EU policies and actions adopted after 2010 are generally aligned with the Strategy. However, it is important to note that the Strategy was not updated after its mid-term evaluation in 2016, therefore policy developments (e.g. Agenda 2030 for Sustainable Development) or the Concluding Observations of the CRPD Committee were not incorporated in the Strategy. -Europe 2020: is the EU’s economic strategy for a smart, sustainable and inclusive growth covering the same period as the Strategy. In general terms, the degree of correlation between the two instruments is not strong. In fact the only mention of disability in Europe 2020 is under the flagship initiative European Platform against Poverty, where Member States are called to define and implement measures addressing the specific circumstances of groups at particular risk, including persons with disabilities. However, the disability angle, although not highlighted in Europe 2020, is particularly relevant from an inclusive growth point of view because persons with disabilities are usually at a higher risk of poverty, exclusion and unemployment. It can be concluded that, in relation to Europe 2020, the Strategy played an important complementary role by helping to focus on the achievement of Europe 2020 objectives from a disability point of view. -The European Pillar of Social Rights: was proclaimed in 2017 to serve as a compass for delivering new and more effective social rights for citizens. Principle 17 on inclusion of persons with disabilities states that “persons with disabilities have the right to income support that ensures living in dignity, services that enable them to participate in the labour market and in society, and a work environment adapted to their needs”. The Pillar therefore has a high degree of coherence with the Strategy and it thus provided a broader context for the implementation of the Strategy actions and for mainstreaming its impact for several areas of the Strategy (social protection, accessibility, participation, employment).

-The European Semester: is the EU’s annual cycle to monitor economic and social progress, launched in 2010. During the first years of the cycle disability issues were not frequently referenced. Some recommendations, particularly those oriented towards reform of social protection and austerity measures, have actually been detrimental to reaching the objectives of the Strategy because they led to a reduction of public expenditure. However, considerations on disability have increased in recent years and were included in country reports and in the recommendations addressed to Member States. It can be concluded that in the early years provisions of the European Semester were not coherent with the overall purpose of the Strategy and have partly hindered its implementation. However, in recent years the European Semester has increasingly aligned its provisions with the aims of the Strategy, thus providing a good level of coherence. -The Charter of Fundamental Rights of the European Union mentions disability in Article 21 on Non-discrimination and Article 26 on Integration of persons with disabilities. Article 21 prohibits discrimination on several grounds, including disability. Article 26 states that “The Union recognizes and respects the right of persons with disabilities to benefit from measures designed to ensure their independence, social and occupational integration, and participation in the life of the community”. The Strategy is coherent with the Charter, and plays a complementary role for the practical implementation of its principles. -The EU funding provisions: the implementation period of the Strategy covers two Multi-Annual Financial Frameworks (MFF), the 2007-2013 and the 2014-2020. In the current period, there are provisions on requiring that EU Funds are used to promote accessibility, non-discrimination, and respect for human rights of persons with disabilities. The European Social Fund (ESF) supports the inclusion of persons with disabilities in the areas of employment, training, social innovation, social services through specific objectives, and particularly thematic objective 9 on social inclusion. The European Regional Development Fund (ERDF) prioritizes the promotion of social inclusion, de-institutionalization and the fight against discrimination, while considering the specific needs of persons with disabilities in the area of accessibility. The Rights, Equality and Citizenship programme promotes the rights of persons with disabilities and non-discrimination through specific funding to EU level disability organizations, research, and training and awareness-raising actions. The evaluation suggests that there is a strong level of coherence between the Strategy and EU funds. 5.4.3 Coherence of the Strategy with the UNCRPD The European Disability Strategy 2010-2020 was adopted on 15 November 2010, several days before the EU acceded to the UNCRPD in December 2010. This means that technically the Strategy does not implement the UNCRPD. Nevertheless, the Convention guided the drafting process of the Strategy and policy-makers of the Commission were well aware of the UNCRPD when preparing the Strategy. As result, the Strategy is fully aligned and coherent with the principles of the UNCRPD and the eight thematic areas covered in the Strategy closely link to specific provisions of the UNCRPD. The Strategy does not cover all the areas of the Convention. Many stakeholders consider that this reduces the level of coherence between the two policy tools. But many aspects of disability policy are, to a large extent, of Member States competence and the Strategy’s scope focuses on areas where EU action proves more effective. Coverage of the full scope of the Convention would have required a broader scope of the strategy with the coverage of actions and policies for which the Member States are primarily responsible. 5.4.4 Coherence of the Strategy with the related policy measures in Member States In general, national priority measures were coherent with EU level actions under the eight thematic areas of the Strategy. There were some differences among areas, with the highest level of coherence in the area of Accessibility and the lowest level of coherence in the area of Social protection. Figure 5: Alignment between national priority measures and the areas of action of the Strategy Source: ICF analysis of public consultation Specific statement: The national priority measures of your Member State are in line with the 8 areas of action of the Strategy

In the area of Accessibility, consistency between the Strategy’s objectives and the policy measures at Member State level was reinforced through the adoption of binding legislative acts such as the Web Accessibility Directive, the European Accessibility Act, the passengers’ rights regulations and the EU funds regulations. On the other hand, in relation to social protection, the economic policies adopted by the Member States during and after the financial crisis have generally reduced public spending, thus also reducing expenditure for social protection. This resulted in limited coherence between the objective of the Strategy in the area of social protection and the actions implemented at Member State level in this field. The evaluation points out that the most influential policy framework for Member States’ disability policy is the UNCRPD. The overall coherence between Member States’ policies and the Strategy is due to their adherence to the principles of the UNCRPD. The table hereunder reflects the most common responses from Member State reports across each area of action. Table 3: Examples of Member State policies and comparison with the objectives of the Strategy Areas of Action In what way are policy objectives coherent with the Strategy? In what ways do trends in Member States differ from the Strategy’s objectives? What are the most influential policy frameworks? Accessibility National accessibility measures adopted based on European Directives such as the European Accessibility Act and Web Accessibility Directive. Accessibility not fully achieved in accordance with EU legal standards; Member State reports mention lack of access to transport services, buildings, housing and lack of universal design. UNCRPD, the European Accessibility Act and the Web Accessibility Directive. Some reports also mention national disability strategies and domestic laws on accessibility. Participation Programmes for transition from institutional to community-based care. As well as, national initiatives and legislation promoting participation in elections, cultural activities, public administration and employment. Insufficient development of community-based services and persistence of institutionalisation. Equal participation has not been achieved e.g. low labour market participation, shortage of personal assistance services and limited agenda for independent living. UNCRPD and national acts/legislation related to equal rights and participation. Equality National anti-discrimination and equal rights legislation covering persons with disabilities. Persons with disabilities deprived of legal capacity under guardianship systems. Discrimination towards