COMMISSION STAFF WORKING DOCUMENT EVALUATION of the European Disability Strategy 2010-2020
Date: 2020-11-20
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU strategy, UN convention, discrimination based on disability, education, employment policy, equal treatment, independence of people with disabilities, integration of people with disabilities, organisation of health care, social security

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.11.2020  SWD(2020) 289 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the European Disability Strategy 2010-2020 {SWD(2020) 291 final}  
 
 
TABLE OF CONTENTS 

1. 

INTRODUCTION ................................................................................................................................ 5 

1.1 

Purpose and scope ......................................................................................................................... 5 

2. 

BACKGROUND TO THE INTERVENTION ..................................................................................... 7 

2.1 

Description of the intervention and its objectives ......................................................................... 7 

2.1.1 

2.1.2 

2.1.3 

2.1.4 

2.1.5 

Need for action ..................................................................................................................... 7 

The Strategy ......................................................................................................................... 8 

The UNCRPD ....................................................................................................................... 9 

The competences of the EU .................................................................................................. 9 

Intervention logic ............................................................................................................... 11 

2.2 

Baseline and points of comparison .............................................................................................. 12 

3. 

IMPLEMENTATION / STATE OF PLAY ........................................................................................ 13 

3.1 

Description of the current situation ............................................................................................. 13 

4.  METHOD ........................................................................................................................................... 17 

4.1 

Short description of methodology ............................................................................................... 17 

4.1.1 

Sources of information ....................................................................................................... 17 

4.2 

Limitations  and robustness of findings....................................................................................... 19 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS .......................................... 20 

5.1 

Effectiveness ............................................................................................................................... 20 

5.1.1 

Achievement of objectives and implementation the actions in eight key areas .................. 21 

5.1.2 
instruments ........................................................................................................................................... 34 

Achievement of objectives and implementation of the actions for the implementation 

5.1.3 

Mainstreaming of disability issues in EU policy and legislation ........................................ 37 

5.1.4. 

Success factors in implementing the EU Strategy .............................................................. 39 

5.1.5 

5.1.6 

Gaps and challenges that hindered achievement of the objectives ..................................... 40 

Engagement of stakeholders in the Strategy’s implementation .......................................... 41 

5.2 

Efficiency .................................................................................................................................... 43 

5.2.1 

5.2.2 

Cost-effectiveness of the Strategy ...................................................................................... 43 

Adequateness and proportionality of resources .................................................................. 44 

5.3 

Relevance .................................................................................................................................... 44 

5.3.1 

5.3.2 

Relevance of the Strategy in addressing the needs of persons with disabilities ................. 44 

Relevance of the Strategy for its different stakeholders ..................................................... 45 

5.4 

Coherence .................................................................................................................................... 47 

5.4.1 

Internal coherence of the Strategy ...................................................................................... 47 

Coherence of the Strategy with other EU policies/ actions (Europe 2020, the European 

5.4.2 
Pillar of Social Rights, the European Semester, the Charter of Fundamental Rights of the European 
Union and the EU funding provisions) ................................................................................................ 47 

5.4.3 

Coherence of the Strategy with the UNCRPD .................................................................... 49 

1 

 
 
5.4.4 

Coherence of the Strategy with the related policy measures in Member States ................. 50 

5.5 

Added value ................................................................................................................................ 53 

5.5.1 
implementing the UNCRPD ................................................................................................................ 53 

Added value of the Strategy in eliminating barriers for persons with disabilities and in 

6. 

CONCLUSIONS ................................................................................................................................. 55 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 59 

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 61 

ANNEX 3: INTERVENTION LOGIC ......................................................................................................... 72 

ANNEX 4: METHODS AND ANALYTICAL MODELS .......................................................................... 73 

ANNEX 5: IMPLEMENTATION STATUS OF THE ACTIONS OF THE STRATEGY .......................... 79 

ANNEX 6: EVALUATION QUESTIONS .................................................................................................. 91 

ANNEX 7: LISTS OF FIGURES AND TABLES ....................................................................................... 93 

2 

 
Glossary 

Term or acronym 

Meaning or definition 

DG 

DHLG 

Directorate-General: is a policy department of the European Commission 

Disability High Level Group 

EaSI Programme 

Employment and Social Innovation Programme 

EESC 

EMCO 

ERDF 

ESF 

European Economic and Social Committee 

Employment Committee 

European Regional Development Fund 

European Social Fund 

ESI Funds 

European Structural and Investment Funds 

EU 

EU-LFS 

EU-SILC 

FRA 

European Union 

EU Labour Force Survey 

EU Statistics on Income and Living Conditions 

Fundamental Rights Agency 

REC Programme 

Rights, Equality and Citizenship Programme 

SPC 

Strategy 

Study 

Social Protection Committee 

European disability strategy 2010-2020 

Study supporting the evaluation of the European disability strategy (2010-
2020)  

UNCRPD 

United Nations Convention on the Rights of Persons with Disabilities 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia  

Denmark 

Estonia 

3 

 
 
 
FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

the Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

the United Kingdom 

4 

 
1.  INTRODUCTION 

1.1  PURPOSE AND SCOPE 

The purpose of this evaluation is to review the implementation of the European disability 
strategy 2010-20201 (the Strategy) and to provide conclusions that can be used as a basis 
for future policy development2. 

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)3 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 study4 (the Study), and on input 
gathered via a broad stakeholder consultation process described in Annex 2. 

1 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM%3A2010%3A0636%3AFIN%3Aen%3APDF  

2 The purpose of an evaluation Staff Working Document is described in detail in the Commission’s Better 
Regulation Guidelines  (Tool #49  the  evaluation  Staff Working Document).  The guidelines  state  that 
“the conclusions of the Staff Working Document should be written in such a way that policy makers 
can use them as a basis for future policy development but should not make any commitment for future 
action or direction of action”. As a result, an evaluation Staff Working Document includes conclusions 
about  the  performance  of  the  initiative  being  evaluated,  but  it  does  not  contain  recommendations  or 
suggestions on future options or measures. 

3

https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-

disabilities.html 

4 Study supporting the evaluation of the European disability strategy (2010-2020), ICF consortium for the 

European Commission, 2019 

5 

 
 
 
                                                            
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 
completeness5. 

The Strategy will end in 2020. In line with the "evaluate first" principle, which is part of 
the Better Regulation6 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. 

5 This  exercise  might  not  have  been  exhaustive  and  it  does  not  prejudge  in  any  case  the  implementation 

assessment conducted within the evaluation. 

6 Better Regulation Guidelines, SWD (2017) 350 

6 

 
 
                                                            
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) 7 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 Union8 
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 programmes9. In 2003 the Commission launched a 
disability action plan for the period 2003-201010. 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 disabilities11. 

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. 

7 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A12012E%2FTXT 

8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012P/TXT 

9 Community Social Action Programme on the Social Integration of Handicapped People, 1983-88, (1981); 
HELIOS I  (Second)  Community  Social  Action  Programme  for  Disabled  People  (1988)  OJ  L104/38; 
HELIOS II (Third) Community Action Programme to Assist Disabled People (1993) OJ L56/30 

10 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2003:0650:FIN:EN:PDF  

11 p.7 of the evaluation report 

7 

 
 
 
                                                            
2.1.2  The Strategy 

The  Communication12 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 

12 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52010DC0636&from=EN 

8 

 
 
 
 
 
 
 
 
 
                                                            
b)  Financial  support:  optimising 

instruments  for 
accessibility  and  non-discrimination  and  increasing  visibility  of  disability-
relevant funding possibilities in post-2013 programmes 

the  use  of  EU  funding 

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”13 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 competences14 (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 UNCRPD15 declared 
the extent of EU competences with respect to the matters governed by the Convention16, 

13 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52010SC1324&from=EN  

14 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3Aai0020  

15  Council  decision  concerning  the  conclusion,  by  the  European  Community,  of  the  United  Nations 
Convention  on  the  Rights  of  Persons  with  Disabilities  (2010/48/EC);  https://eur-lex.europa.eu/legal-
content/FR/TXT/?uri=uriserv:OJ.L_.2010.023.01.0035.01.ENG 

16 Declaration concerning the competence of the European Community with regard to matters governed by 

the United Nations Convention on the Rights of Persons with Disabilities 

9 

 
 
 
                                                            
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  Act17,  the  Web-
Accessibility  Directive18,  the  Audiovisual  Media  Services  Directive19,  or  the  European 
Electronic  Communications  Code20,  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. 

17 Directive  (EU)  2019/882  of  the  European  Parliament  and  of  the  Council  of  17  April  2019  on  the 
https://eur-lex.europa.eu/legal-

requirements 

services; 

and 

accessibility 
products 
content/EN/TXT/?uri=CELEX%3A32019L0882 

for 

18 Directive  (EU)  2016/2102  of  the  European  Parliament  and  of  the  Council  of  26  October  2016  on  the 
accessibility  of  the  websites  and  mobile  applications  of  public  sector  bodies;  https://eur-
lex.europa.eu/eli/dir/2016/2102/oj 

19  Directive  (EU)  2018/1808  of  the  European  Parliament  and  of  the  Council  of  14  November  2018 
amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation 
or  administrative  action  in  Member  States  concerning  the  provision  of  audiovisual  media  services 
(Audiovisual  Media  Services  Directive) 
in  view  of  changing  market  realities;  https://eur-
lex.europa.eu/eli/dir/2018/1808/oj  

20  Directive  (EU)  2018/1972  of  the  European  Parliament  and  of  the  Council  of  11  December  2018 
https://eur-

Electronic  Communications  Code 

(Recast); 

establishing 
the 
lex.europa.eu/eli/dir/2018/1972/oj  

European 

10 

 
                                                            
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 population21, and there was general agreement that 
demographic trends (i.e. ageing population) would lead to an increase in the number of 
persons  with  disabilities22.  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 technology23. 

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”24 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.  

21 Results  of  the  annual  surveys  from  2006  through  2008  of  the  Eurostat  Statistics  on  Income,  Social 
Inclusion and Living Conditions (SILC) and evidence from the 2002 Eurostat ad hoc disability module 
of the Labour Force Survey (LFS AHM). 

22 Commission Staff Working Document SEC(2010) 1323 final accompanying the communication on the 

European disability strategy 2010-2020 – p. 6. 

23 Commission Staff Working Document SEC(2010) 1323 final accompanying the communication on the 

European disability strategy 2010-2020 – Section 1. 

24 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SEC:2010:1324:FIN:en:PDF  

11 

 
                                                            
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. 

12 

 
 
 
 
3.  IMPLEMENTATION / STATE OF PLAY 

3.1  DESCRIPTION OF THE CURRENT SITUATION  

The  abovementioned  “list  of  actions”25 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 26 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  

Implementation of the Strategy's actions 

101  
([VALUE]) 

40  
([VALUE]) 

9 
([VALUE]) 

0%

20%

40%

60%

80%

100%

Fully Implemented

Partially Implemented

Not Implemented

Source: ICF analysis 

Overall
67%

27%

6%

25 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52010SC1324&from=EN 

26 http://ec.europa.eu/social/BlobServlet?docId=16995&langId=en 

13 

 
 
 
 
 
 
 
 
                                                            
 
Figures 2.1 and 2.2: Implementation by thematic area (number and percentage)  

Implementation of the Strategy's actions  
(number) 

1. Accessibility

2. Participation

3. Equality

9 

17 

6 

4 

22 

2 

4 

1 

4. Employment

12 

3 

1 

5. Education and Training

6. Social Protection

6 

1 

4 

4 

2 

7. Health

7 

4 

1 

8. External Action

2 

9 

0

5

10

15

20

25

30

8.
External
Action

7.
Health

6. Social
Protecti
on

Fully Implemented

Partially Implemented

2

9

Not Implemented

7

4

1

4

2

5.
Educati
on and
Training
4

6

1

4.
Employ
ment

3.
Equality

2.
Particip
ation

1.
Accessib
ility

9

2

12

3

1

22

4

1

17

6

4

Implementation of the Strategy's actions  (%) 

1. Accessibility

2. Participation

3. Equality

4. Employment

63% 

22% 

15% 

81% 

82% 

75% 

15% 

4% 

18% 

19% 

6% 

5. Education and Training

36% 

55% 

9% 

6. Social Protection

7. Health

67% 

58% 

8. External Action

18% 

0%

20%

40%

33% 

33% 

8% 

82% 

60%

80%

100%

8.
External
Action

7.
Health

6. Social
Protecti
on

Implemented

Partially Implemented

Not Implemented

18%

82%

0%

58%

33%

8%

67%

33%

0%

5.
Educati
on and
Training
36%

55%

9%

4.
Employ
ment

3.
Equality

2.
Particip
ation

1.
Accessib
ility

75%

19%

6%

82%

18%

0%

81%

15%

4%

63%

22%

15%

Source: ICF analysis 

14 

 
 
 
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) 

Implementation of the Strategy's actions  (number) 

A. Awareness-Raising

4 

1 

B. Financial Support

6 

1 

C. Statistics, Data Collection
and Monitoring

D. Mechanisms required by
the UNCRPD

10 

2 

1 

4 

2

0

4

6

8

10

12

14

D. Mechanisms
required by the
UNCRPD

C. Statistics,
Data Collection
and Monitoring

B. Financial
Support

A. Awareness-
Raising

Fully Implemented

4

Partially Implemented

Not Implemented

10

2

1

6

1

4

1

15 

 
 
Implementation of the Strategy's actions  
(%) 

A. Awareness-Raising

B. Financial Support

C. Statistics, Data Collection
and Monitoring

D. Mechanisms required by
the UNCRPD

80% 

20% 

86% 

14% 

77% 

15% 

8% 

100% 

0%

20%

40%

60%

80%

100%

D. Mechanisms
required by the
UNCRPD

C. Statistics,
Data Collection
and Monitoring

B. Financial
Support

A. Awareness-
Raising

Implemented

Partially Implemented

Not Implemented

100%

0%

0%

77%

15%

8%

86%

14%

0%

80%

20%

0%

Source: ICF analysis 

The  detailed  overview  with  the  level  of  implementation  of  each  action  is  reported  in 
Annex 5 of the Staff Working Document. 

16 

 
 
 
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 Study27. 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 provisions28, the evaluation has first to provide answers 
to  each  evaluation  question  and 
the  overall 
implementation of the Strategy. 

then  provide  conclusions  about 

4.1.1  Sources of information 

The  Roadmap  for  the  evaluation  of  the  European  Disability  Strategy  2010-202029 was 
published on the European Commission ‘Have your say’ web portal30 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. 

27   Annex 1 of the Study supporting the evaluation of the European Disability Strategy (2010-2020), ICF 
consortium  for  the  European  Commission,  2019,  provides  details  on  the  evaluation  framework  that 
was used to answer the evaluation questions. 

28 https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines-evaluation-fitness-checks.pdf  

29 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1929-European-Disability-

Strategy-2010-2020-evaluation 

30

 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1929-European-Disability-

Strategy-2010-2020-evaluation 

17 

 
 
                                                            
-  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 

representing  persons  with  disabilities  and 
responsible for disability policy at national level. 

targeting  organisations 
representatives  of  Ministries 

-  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: 

18 

 
 
-  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. 

19 

 
 
 
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 

20 

 
 
 
  
 
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 foreseen31, 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 

31 More details over gaps and challenges hindering achievement of objectives are provided in Section 5.1.5 

21 

 
 
 
 
                                                            
Accessibility  Act 32  and  of  the  Web  Accessibility  Directive 33 ,  the  adoption  of  the 
waterborne and bus and coach passenger rights Regulations34, 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  Regulation35,  the  revision  of  the 
Commission  Regulation  on  the  technical  specifications  for  interoperability  relating  to 
accessibility of the Union's rail system36, the inclusion of accessibility provisions in the 
Audiovisual  Media  Services  Directive37,  the  new  European  Electronic  Communications 
Code 38 ,  the  so-called  “Marrakesh”  Directive 39 ,  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 

32 Directive  (EU)  2019/882  of  the  European  Parliament  and  of  the  Council  of  17  April  2019  on  the 
accessibility  requirements  for  products  and  services  (Text  with  EEA  relevance);  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882 

33 Directive  (EU)  2016/2102  of  the  European  Parliament  and  of  the  Council  of  26  October  2016  on  the 
accessibility of the websites and mobile applications of public sector bodies (Text with EEA relevance 
); https://eur-lex.europa.eu/eli/dir/2016/2102/oj 

34 Regulation  (EU)  No  1177/2010  of  the  European  Parliament  and  of  the  Council  of  24  November  2010 
concerning  the  rights  of  passengers  when  travelling  by  sea  and  inland  waterway  and  amending 
Regulation  (EC)  No  2006/2004  (Text  with  EEA  relevance);  https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX%3A32010R1177.  Regulation  (EU)  No  181/2011  of  the  European 
Parliament  and  of  the  Council  of  16  February  2011  concerning  the  rights  of  passengers  in  bus  and 
coach transport and amending Regulation (EC) No 2006/2004 (Text with EEA relevance); https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=celex:32011R0181 

35 Proposal for a regulation of the European Parliament and  of the Council on rail passengers’ rights and 
obligations (recast); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017PC0548 

36 Commission  Regulation  (EU)  No  1300/2014  of  18  November  2014  on  the  technical  specifications  for 
interoperability  relating  to  accessibility  of  the  Union's  rail  system  for  persons  with  disabilities  and 
persons  with  reduced  mobility  (Text  with  EEA  relevance);  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.L_.2014.356.01.0110.01.ENG 

37  Directive  (EU)  2018/1808  of  the  European  Parliament  and  of  the  Council  of  14  November  2018 
amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation 
or  administrative  action  in  Member  States  concerning  the  provision  of  audiovisual  media  services 
in  view  of  changing  market  realities;  https://eur-
(Audiovisual  Media  Services  Directive) 
lex.europa.eu/eli/dir/2018/1808/oj 

38  Directive  (EU)  2018/1972  of  the  European  Parliament  and  of  the  Council  of  11  December  2018 
establishing  the  European  Electronic  Communications  Code  (Recast)  (Text  with  EEA  relevance); 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2018.321.01.0036.01.ENG 

39 Directive (EU) 2017/1564 on certain permitted uses of certain works and other subject matter protected 
by copyright and related rights for the benefit of persons who are blind, visually impaired or otherwise 
print-disabled;  https://eur-lex.europa.eu/eli/dir/2017/1564/oj.  The  Directive  is  implementing  the 
“Marrakesh  Treaty  to  Facilitate  Access  to  Published  Works  for  Persons  Who  Are  Blind,  Visually 
Impaired,  or  Otherwise  Print  Disabled”,  which  aims  to  facilitate  access  to  print  works  in  formats 
adapted  for  persons  who  are  blind,  visually  impaired  or  otherwise  print  disabled.  The  Marrakesh 
Treaty,  to  which  the  EU  is  party,  is  an  international  copyright  treaty  administered  by  the  World 
Intellectual Property Organisation (WIPO). 

22 

 
                                                            
 
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 accordingly40. 

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 evaluation41. 

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 

40 See  Art.  17  of  Regulation  (EU)  No  181/2011  for  bus  and  coach,  Art.  15  of  Regulation  (EU)  No 
1177/2010 for sea and inland waterways, Art. 25 of Regulation (EC) 1371/2007 for rail (which will be 
further strengthened by the new recast rules, see above). In relation to air, the Commission proposed in 
2013  that  the  liability  of  air  carriers  with  regard  to  mobility  equipment  will  be  increased  up  to  the 
actual value of the equipment (see COM(2013)130 final, draft Article 6a of the amended Regulation 
(EC)  No  2027/97;  https://eur-lex.europa.eu/procedure/EN/2013_72).  The  procedure  is  still  ongoing 
and the proposal is a priority pending file in the Commission Work Programme 2021 (see COM(2020) 
690  final,  Annex  III  number  5;  https://ec.europa.eu/info/publications/2021-commission-work-
programme-key-documents_en) 

41 However,  progress  was  registered  more  recently  in  relation  to  the  adoption  of  European  Accessibility 
Standard EN 17210 linked to Standardisation Mandate 420 on accessibility to the built environment. 
The  European  Committee  for  Standardisation  has  announced  the  ratification  of  the  standard  for  30 
November  2020  and 
is  available  at 
https://standards.cen.eu/dyn/www/f?p=204:110:0::::FSP_PROJECT,FSP_LANG_ID:65077,25&cs=1
B1F504D7DCF7711690E22BAE7CED456A 
https://www.cencenelec.eu/standards/Topics/Accessibility/Pages/Builtenvironment.aspx 

its  publication  for  January  2021.  More 

information 

and 

23 

 
                                                            
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 legislation42 
allowing the Member States to support measures for the shift from institutional to 
community-based care43, which led to concrete results in different Member States. 

- 

Implementation  of  the  European  disability  card44 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 States45 
By  the  end  of  2020  the  Commission  will  conclude  the  assessment  on  the 
implementation of this pilot project. 

-  The  Inclusion  and  Diversity  Strategy46 which  promotes  participation  of  young 

people with disabilities into Erasmus+ youth mobility projects. 

42 Regulation (EU) No 1303/2013 of the European Parliament and of the Council of 17 December 2013 
laying down common provisions on the European Regional Development Fund, the European Social Fund, 
the Cohesion Fund, the European Agricultural Fund for Rural Development and the European Maritime 
and Fisheries Fund and laying down general provisions on the European Regional Development Fund, the 
European Social Fund, the Cohesion Fund and the European Maritime and Fisheries Fund and repealing 
Council Regulation (EC) No 1083/2006; https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=celex%3A32013R1303 

43 Ex-ante conditionality 9.1 on the existence and the implementation of a national strategic policy 
framework for poverty reduction aiming at the active inclusion of people excluded from the labour market 
in the light of the Employment Guidelines covering the measures for the shift from institutional to 
community- based care; General ex-ante conditionality No 3 on the existence of administrative capacity for 
the implementation and application of the United Nations Convention on the rights of persons with 
disabilities (UNCRPD) in the field of ESI Funds in accordance with Council Decision 2010/48/EC. 

44 https://ec.europa.eu/social/main.jsp?catId=1139 

45 Belgium, Cyprus, Estonia, Finland, Italy, Malta, Romania and Slovenia 

46 https://ec.europa.eu/assets/eac/youth/library/reports/inclusion-diversity-strategy_en.pdf 

24 

 
 
 
 
 
 
                                                            
- 

Initiatives  to  promote  participation  into  sports  through  funding  for  disability-
specific sporting events,  projects (through Erasmus+47), awareness raising actions 
(like the BeInclusive EU sport award48) or events (such as the European Day of 
Persons  with  Disabilities  conference  2019 49  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 disabilities50. 

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 

47 https://ec.europa.eu/programmes/erasmus-

plus/projects_en#search/project/keyword=disabilities&matchAllCountries=false  

48 https://ec.europa.eu/sport/about/initiatives/beinclusive_en 

49 https://ec.europa.eu/social/main.jsp?langId=en&catId=88&eventsId=1487&furtherEvents=yes 

50 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019XG0607(03)  

25 

 
 
 
                                                            
implementation  efforts  despite 

support  if  required.  The  Study  points  out  that  autonomy  was  not  part  of  the 
the  overall 
Strategy’s 
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. 

importance  for 

its 

-  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/EC51 for improving employment of persons  with  disabilities”. The 
action  was  fully  implemented.  In  2014,  the  Commission  presented  an  implementation 
report52 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. 

51 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32000L0078 

52 REPORT  FROM  THE  COMMISSION  TO  THE  EUROPEAN  PARLIAMENT  AND  THE  COUNCIL 
Joint  Report  on  the  application  of  Council Directive  2000/43/EC  of  29  June  2000  implementing  the 
principle  of  equal  treatment  between  persons  irrespective  of racial  or ethnic origin (‘Racial  Equality 
Directive’)  and  of  Council  Directive  2000/78/EC  of  27  November  2000  establishing  a  general 
framework  for  equal  treatment  in  employment  and  occupation  (‘Employment  Equality  Directive’) 
COM/2014/02 final; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52014DC0002 

26 

 
 
 
 
                                                            
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  proposal53 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. 

53 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52008PC0426&from=DA 

27 

 
 
 
 
                                                            
 
-  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 Rights54 
(“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 55 ad  hoc  module  focusing  on  employment  of  disabled  people 56 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) 57,  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 

54

https://ec.europa.eu/commission/priorities/deeper-and-fairer-economic-and-monetary-union/european-

pillar-social-rights/european-pillar-social-rights-20-principles_en 

55 https://ec.europa.eu/eurostat/web/lfs/overview 

56 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32010R0317 

57 ANED (https://www.disability-europe.net/) was created by the European Commission in December 2007 
to  support  policy  development  through  studies,  analysis,  research  and  publications.  It  has  been 
replaced by the European Disability Expertise project in 2020. 

28 

 
                                                            
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 28.58  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 

58 Eurostat EU SILC data analysed by ANED. 

29 

 
 
 
                                                            
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 2018.59 

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)60. 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 

59 Eurostat EU SILC data analysed by ANED 

60 https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=hlth_dpe010&lang=en 

30 

 
 
 
                                                            
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 
proclaimed61 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 balance62 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-employed63 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+)64, the European Regional Development Fund, the Rights, Equality and Citizenship 
programme65 and the EU programme for Employment and Social Innovation66, as well as 
through the Structural Reform Support programme67, 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 

61

 https://ec.europa.eu/commission/sites/beta-political/files/social-summit-european-pillar-social-rights-

booklet_en.pdf 

62 Directive (EU) 2019/1158 of the European Parliament and of the Council of 20 June 2019 on work-life 
balance  for  parents  and  carers  and  repealing  Council  Directive  2010/18/EU;  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.188.01.0079.01.ENG 

63 Council Recommendation of 8 November 2019 on access to social protection for workers and the self-
employed 2019/C 387/01 ST/12753/2019/INIT; https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2019.387.01.0001.01.ENG&toc=OJ:C:2019:387:TOC 

64 https://ec.europa.eu/esf/home.jsp 

65 https://ec.europa.eu/justice/grants1/programmes-2014-2020/rec/index_en.htm 

66 https://ec.europa.eu/social/main.jsp?catId=1081 

67  https://ec.europa.eu/info/funding-tenders/funding-opportunities/funding-programmes/overview-funding-

programmes/structural-reform-support-programme-srsp_en 

31 

 
                                                            
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. 

these  considerations, 

Despite 
in 
the  Study  suggests 
mainstreaming disability considerations in legislation notably on cross-border healthcare 
(the Patients’ rights Directive68). The Strategy also supported the production of statistics, 
data collection and monitoring activities, notably:  

the  Strategy  helped 

that 

-  The  development  of  the  2011  EU-LFS69 ad-hoc  module  on  the  employment  of 

persons with disabilities70 

-  The European Health Interview Survey71 
-  The  2012/2013  European  Health  and  Social  Integration  Survey  (dedicated 

disability survey) 72 

68 Directive 2011/24/EU of the European Parliament and of the Council of 9 March 2011 on the application 
https://eur-lex.europa.eu/legal-

cross-border 

healthcare; 

patients’ 

of 
rights 
content/EN/TXT/?uri=celex%3A32011L0024 

in 

69 https://ec.europa.eu/eurostat/web/lfs/overview 

70 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32010R0317 

71 https://ec.europa.eu/eurostat/web/microdata/european-health-interview-survey 

72 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Disability_statistics 

32 

 
 
 
                                                            
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 2019.73 

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 74  and  the  publication  by  the  European 
Commission  of  an  operational  guidance  on  the  inclusion  of  persons  with  disabilities  in 
EU-funded humanitarian aid operation75. Disability considerations have been included in 
the  2017  European  Consensus  on  Development 76  as  well  as  in  the  2014  Council 
conclusions  on  a  rights-based  approach  to  development  cooperation,  encompassing  all 
human rights77. 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.  

73 EUROSTAT table [HLTH_DH030], dataset based on EU-SILC;  

74 https://ec.europa.eu/anti-trafficking/eu-policy/action-plan-human-rights-and-democracy-2015-2019_en 

75  DG  ECHO  Operational  Guidance  -  The  Inclusion  of  Persons  with  Disabilities  in  EU-funded 

Humanitarian Aid Operations 

76 https://ec.europa.eu/international-partnerships/european-consensus-development_en 

77 http://register.consilium.europa.eu/doc/srv?l=EN&f=ST%209489%202014%20INIT 

33 

 
  
 
                                                            
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 
marker78, 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 Questions79 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. 

78 https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=DCD/DAC/STAT(2018)39/R

EV1&docLanguage=En 

79 https://www.washingtongroup-disability.com/question-sets/wg-short-set-on-functioning-wg-ss/ 

34 

 
 
 
 
                                                            
The  two  main  public  disability  events  organised  by  the  European  Commission,  the 
Access  City  Award80 and  the  European  Day  of  Persons  with  Disabilities81 have  gained 
growing visibility and momentum among disability stakeholders. 

For  the  2020  edition  of  the  Access  City  Award82,  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 campaign83 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. 

80 ec.europa.eu/social/accesscityaward 

81  European Day of Persons with Disabilities 2019: 

https://ec.europa.eu/social/main.jsp?langId=en&catId=88&eventsId=1487&furtherEvents=yes  

82 https://ec.europa.eu/social/main.jsp?langId=en&catId=1141&eventsId=1442&furtherEvents=yes 

83 https://ec.europa.eu/social/euvsdiscrimination 

35 

 
                                                            
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 Eurostat84 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. 

84 Eurostat  population  surveys:  Labour  Force  Survey  (LFS),  Statistics  on  Income  and  Living  Conditions 
(SILC), European Health Interview Survey (EHIS), Adult Education Survey (AES), Information and 
Communication  Technologies  survey  (ICT),  Time  Use  Survey  (TUS),  Household  Budget  Survey 
(HBS) 

36 

 
 
 
 
                                                            
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  3385 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  strategy86,  the 
European Pillar of Social Rights87, or the European Semester process88 refer to disability 

85

86

 https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-

disabilities/article-33-national-implementation-and-monitoring.html 

https://ec.europa.eu/eu2020/pdf/COMPLET%20EN%20BARROSO%20%20%20007%20-

%20Europe%202020%20-%20EN%20version.pdf 

37 

 
 
 
 
 
                                                            
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 89 ,  the  EU  Digital  Strategy 90 ,  the  mid-term  review  of  the  Education  and 
Training  2020  (ET2020)  framework 91,  the  Roadmap  to  a  Single  European  Transport 
Area92,  the  EU  Youth  Strategy93,  the  EU’s  Strategic  Engagement  for  Gender  Equality94 
and the 2020 Communication re-launching the European Research Area95, as well as the 
Communication  on  Achieving  the  European  Education  Area  by  202596 and  the  Digital 
Education  Action  Plan 97.  Recent  policy  documents  such  as  the  EU  Gender  Equality 
Strategy  2020-202598 and  the  EU  Action  Plan  against  racism  2020-202599 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 

87

 https://ec.europa.eu/commission/priorities/deeper-and-fairer-economic-and-monetary-union/european-
pillar-social-rights/european-pillar-social-rights-20-principles_en 

88 The European Semester is a cycle of economic and fiscal policy coordination within the EU. It is part of 
the  European  Union's  economic  governance  framework.  The  cycle  takes  place  for  a  6-month  period 
from the beginning of each year, hence its name - the 'semester'. During the European Semester, the 
Member States align their budgetary and economic policies with the objectives and rules agreed at the 
EU level. 

89 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52007DC0630 

90 https://ec.europa.eu/digital-single-market/en/content/european-digital-strategy 

91 https://op.europa.eu/en/publication-detail/-/publication/8e5d0991-82ed-11e5-b8b7-01aa75ed71a1 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52012XG0308%2801%29 

and 

92 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52011DC0144 

93 https://ec.europa.eu/youth/policy/youth-strategy_en 

94 https://ec.europa.eu/anti-trafficking/eu-policy/strategic-engagement-gender-equality-2016-2019_en 

95 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2020:628:FIN 

96 https://ec.europa.eu/education/resources-and-tools/document-library/eea-communication-sept2020_en 

97

 https://ec.europa.eu/education/sites/education/files/document-library-docs/deap-communication-

sept2020_en.pdf 

98 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0152 

99

 https://ec.europa.eu/info/sites/info/files/a_union_of_equality_eu_action_plan_against_racism_2020_-

2025_en.pdf 

38 

 
                                                                                                                                                                                 
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. 

o  Integration 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. 

o  Integration  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 

39 

 
 
 
 
 
 
(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, 

40 

 
 
 
 
 
 
 
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 

41 

 
 
 
 
 
 
 
The  Study  suggests  that  Member  States,  EU  institutions  and  organisations  representing 
the  Strategy’s 
persons  with  disabilities  have  been  adequately  engaged 
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. 

in 

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 

42 

 
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. 

43 

 
 
 
 
 
 
 
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 

44 

 
 
 
 
 
 
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 
disabilities100.  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). 

100 The principle states that “People 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”. 

45 

 
 
 
                                                            
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  

46 

 
 
 
 
 
 
 
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 

47 

 
 
 
 
 
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, 

48 

 
 
 
 
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. 

49 

 
 
 
 
 
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 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

accessibili
ty

participati
on

equality

employm
ent

education
and
training

social
protection

health

external
action

Don't know (%)

Disagree (%)

Somewhat disagree (%)

Neither agree nor disagree (%)

Somewhat agree (%)

Agree (%)

7%

18%

14%

10%

33%

18%

8%

20%

15%

14%

29%

14%

8%

21%

16%

15%

27%

12%

8%

24%

19%

15%

24%

10%

9%

20%

16%

14%

29%

13%

9%

23%

17%

14%

26%

11%

9%

20%

16%

17%

27%

12%

31%

17%

10%

21%

16%

6%

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. 

50 

 
 
 
 
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. 

National anti-
discrimination and 
equal rights 
legislation covering 
persons with 
disabilities.  

Equality 

Employment  National policies for 

increasing 
participation of 
persons with 
disabilities in the 
open labour market 

UNCRPD and national 
acts/legislation related 
to equal rights and 
participation.  

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.  

Persons with disabilities 
deprived of legal 
capacity under 
guardianship systems. 
Discrimination towards 
people with disabilities 
has not been 
eradicated. 

UNCRPD, European 
anti-discrimination 
legislation (e.g. 
Directive 2000/78/EC) 
and the Strategy. A few 
countries mentioned 
national policies for 
equal opportunities for 
persons with 
disabilities.  

Failure to substantially 
increase the 
employment rate of 
persons with disabilities 
and lack of transition 
mechanisms from 

UNCRPD, Directive 
2000/78/EC, UN 
Committee 
recommendations and 
specific national 
employment policies.  

51 

 
  
 
 
  
Areas of 
Action 

Education 
and Training 

In what way are 
policy objectives 
coherent with the 
Strategy? 

including reforms in 
national legislation 
supporting 
employment of 
persons with 
disabilities and use of 
European Social Fund 
for employment of 
persons with 
disabilities. 

National policies and 
legislation promoting 
inclusive education 
and life-long 
learning.  

Social 
Protection 

Health 

National policies and 
legislation improving 
the benefits system 
(access to and 
adequacy of 
pensions, social 
security) for persons 
with disabilities and 
poverty reduction 
measures. 

National policies and 
legislation for 
improved 
accessibility of 
healthcare for 
persons with 
disabilities.  

What are the most 
influential policy 
frameworks? 

UNCRPD and specific 
national legislation and 
strategies.  

UNCRPD, budget cuts in 
Member States that 
have impacted services 
for persons with 
disabilities (typically 
those linked to austerity 
measures)  

EU legislation and 
national legislation and 
strategies.  

UNCRPD and national 
health strategies.  

In what ways do 
trends in Member 
States differ from the 
Strategy’s 
objectives? 
education to 
employment. Lack of 
statistics on the labour 
market situation for 
persons with 
disabilities. 

In some Member 
States, national policy 
does not adequately 
promote integration in 
the school system. Gaps 
in inclusive education 
such as low 
participation, lack of 
statistics on 
participation, limited 
teacher training and 
lack of support for life-
long learning. 

Insufficient levels of 
social protection, 
territorial disparities in 
level of protection, low 
coverage and lack of 
data/monitoring.  

Lack of priority or 
measures to ensure 
adequate access to 
health care services. As 
well as, lack of training 
of health care staff, 
persisting territorial 
differences and lack of 
data/monitoring. 

Source: Member State analysis performed by national experts in the context of the Study  

52 

 
 
5.5  ADDED VALUE  

5.5.1  Added  value  of  the  Strategy  in  eliminating  barriers  for  persons  with 

disabilities and in implementing the UNCRPD 

The  evaluation  suggests  that  the  Strategy  provided  added  value  in  helping  to  eliminate 
barriers for persons with disabilities and in helping to implement the UNCRPD  

Stakeholders from the Disability High Level Group and from organizations representing 
persons  with  disabilities  largely  agree  that  the  Strategy  has  delivered  added  value  in 
implementing the UNCRPD. 

Figure  6:  Extent  to  which  the  Strategy  has  delivered  added  value  in  implementing  the 
UNCRPD 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Disagree

Somewhat  disagree

Neither agree nor disagree

Somewhat agree

Agree

4% 
8% 

38% 

50% 

DHLG

0%

4%

8%

38%

50%

3% 
8% 
9% 

40% 

40% 

ONGs

3%

8%

9%

40%

40%

Source:  DG  EMPL  survey  of  Disability  High  Level  Group  (DHLG)  and  Non-
Governmental Organisations (NGOs) 

Specific statement: The Strategy has delivered added value in helping eliminate barriers 
for persons with disabilities and in helping implement  the UNCRPD compared to what 
would have been achieved without it. 

In  fact,  the  ratification  of  the  Convention  by  the  EU  and  its  Member  States  created 
momentum  for  a  more  ambitious  and  effective  disability  policy,  and  the  absence  of  a 
strategic framework on disability would have left the decisions regarding implementation 
of the UNCRPD to the agendas of single services, with possible negative effects in terms 
of internal coherence. 

53 

 
 
 
 
 
As  a  result,  the  main  added  value  of  the  Strategy  was  to  provide  coherence  to  the 
implementation of the UNCRPD at EU level. 

At  Member  State  level,  the  evaluation  suggests  that  the  Strategy  had  a  more  limited 
effect,  mostly  due  to  the  limited  competences  of  the  EU  in  a  number  of  policy  fields 
relevant to disability (for instance health and education and training) and to the limited 
knowledge of the Strategy by national policy-makers. 

An  exception  to  this  is  the  European  Semester,  a  process  whereby  individual  Member 
States  receive  recommendations  on  economic  and  social  measures  to  be  implemented. 
During  the  last  years,  a  growing  number  of  recommendations  regarding  disability  has 
been included in the recommendations addressed to Member States. On top of the actions 
put in place by the Member States to implement the recommendations, an important side 
effect of these recommendations was the promotion of policy debate about disability and 
about the  UNCRPD in the Member States. 

Overall,  it  is  not  easy  to  quantify  to  what  extent  the  Strategy  has  translated  into 
significant impact in the elimination of barriers for persons with disabilities. The lack of 
disaggregated  data  on  disability  and  the  long-term  effect  of  some  of  the  Strategy’s 
actions make it difficult to assess progress in the situation of persons with disabilities. 

However, based on the feedback received by stakeholders and on the results of the public 
consultation, it appears that the majority of stakeholders agrees that EU action has helped 
to improve the situation of persons with disabilities in the last ten years.  

Figure 7: Role of EU initiatives in improving the situation of persons with disabilities in 
the last ten years 

45%

40%

35%

30%

25%

20%

15%

10%

5%

0%

in your Member State

throughout the European Union

worldwide

Agree

14%

15%

6%

Somewhat
agree

Neither
agree nor
disagree

Somewhat
disagree

Disagree

Don't know

38%

37%

18%

15%

16%

22%

13%

7%

8%

14%

4%

8%

5%

20%

38%

Source: ICF analysis of public consultation 

Specific  statement:  Overall,  EU  initiatives  have  helped  to  improve  the  situation  of 
persons with disabilities in the last ten years 

54 

 
 
 
6.  CONCLUSIONS 

The  objective  of  this  evaluation  was  to  review  the  implementation  of  the  European 
disability  strategy  2010-2020  and  to  assess  to  which  extent  the  Strategy  translated  into 
sound policies and planned changes, as well as the way it influenced implementation of 
the UNCRPD at EU level. 

The evaluation covered the effectiveness, efficiency, relevance, coherence and EU added 
value of the Strategy. These criteria were examined in an external study, and built upon 
by  the  information  gathered  through  consultation  activities,  including  an  open  public 
consultation, targeted consultations and interviews with a range of relevant stakeholders 
and various other secondary sources. 

Overall conclusion 

The  evaluation  concludes  that  the  Strategy  made  a  significant  contribution  to  the 
implementation  of  the  UNCRPD  at  EU  level  and  to  the  implementation  of  several 
important legislative and policy instruments in the field of disability. 

However, not  all the actions of the Strategy were fully implemented,  and its objectives 
were partially achieved. 

Main achievements 

The Strategy had a  positive  impact  on  overall  disability  policy, as it contributed to a 
change towards a human rights-based approach in this area. The existence of a high-level 
EU policy document in this field significantly contributed to placing the disability agenda 
higher among the EU policy priorities and it opened the EU institutional space to persons 
with disabilities. 

Being the tool for implementing the UNCRPD at EU level, the Strategy has supported 
the  implementation  of  the  Convention  by  translating  its  principles  into  practical 
objectives and actions. 

During  its  10  year  implementation  period,  the  Strategy  was  a  driver  for  including 
disability in EU legislation and policy. The influence of the Strategy on legislative and 
policy instruments was particularly visible in the areas of accessibility and passengers’ 
rights,  with  the  adoption  of  the  European  Accessibility  Act,  the  Web  Accessibility 
Directive and legislation on the Rights of Passengers with Reduced Mobility. 

There  was  also  visible  impact  through  EU  funding  in  the  area  of  support  to  de-
institutionalisation, as well as of accessibility, support for social inclusion and promotion 
of  the  rights  of  persons  with  disabilities.  Key  outputs  included  awareness  raising  and 
civil  dialogue  events  contributing  to  the  promotion  of  the  rights  of  persons  with 
disabilities. 

55 

 
 
 
 
level.  Examples  of  disability  mainstreaming 

The  Strategy  was  a  driver  for  helping  in  mainstreaming  disability  issues  at  EU 
include  development 
institutional 
cooperation,  standardisation,  State  Aid,  copyright  legislation,  education  programmes. 
Disability  was  also  mainstreamed  throughout  the  principles  of  the  European  Pillar  of 
Social  Rights  and  the  disability-related  Country  Specific  Recommendations  under  the 
European  Semester,  thus  supporting  Member  States  in  applying  the  principles  of  the 
UNCRPD at national level. 

The  Strategy,  through  the  establishment  of  the  Mechanisms  required  by  the  UNCRPD, 
made an important contribution to ensuring the involvement of persons with disabilities 
and  their  representative  organisations  in  the  EU  decision-making.  The  resulting 
exchange of feedback, opinions and ideas about disability policy contributed to a better 
understanding  of  problems  and  issues  at  stake,  the  development  of  more  inclusive 
policies and legislation, and an increased awareness about disability issues at institutional 
level. 

Main shortcomings 

The  main  shortcoming  of  the  Strategy  is  related  to  aspects  of  its  design.  The  Strategy, 
since  its  conception,  did  not  include  a  comprehensive  set  of  benchmarks  and 
indicators  for  measuring  the  extent  to  which  its  actions  were  carried-out  and  its 
objectives  achieved.  It  was  also  missing  an  operative  framework  for  regularly 
monitoring  its  implementation. The absence of those two elements, together with the 
limited  availability  of  regularly  collected  and  disaggregated  data  in  all  areas  of 
disability, prevented the regular evaluation of the Strategy’s progress, the early detection 
of delivery gaps and the identification of possible mitigating actions. Such a framework, 
if  implemented,  would  have  also  allowed  the  provision  of  regular  information  to  all 
involved stakeholders and its absence is one of the reasons for the partial achievement of 
the Strategy’s objectives. 

Despite the cross-cutting nature of disability policy and the ratification of the UNCRPD 
by  the  EU,  knowledge  of  disability  issues  across  the  EU  institutions  remained 
uneven.  Despite  the  European  Commission’s  role  as  focal  point  for  implementing  the 
UNCRPD  at  EU  level,  awareness  of  the  UNCRPD  and  of  the  needs  of  persons  with 
disabilities are not equally present across its different services; similar considerations on 
the  need  to  improve  knowledge  and  awareness  around  disability  can  be  made  for  the 
other  EU  institutions.  As  a  result,  UNCRPD  provisions  and  needs  of  persons  with 
disabilities were not always fully taken into account in the EU policy-making processes. 

Actions,  particularly  in  the  area  of  accessibility,  mostly  focused  on  visible  disabilities. 
The  needs  of persons  with  intellectual  disabilities,  and  with  invisible  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. 

Overall,  the  Strategy  achieved  partial  results  in  implementing  the  foreseen  actions 
and  in  reaching  the  set  objectives.  Only  two  thirds  of  the  actions  were  fully 
implemented,  and  the  majority  of  the  objectives  for  the  areas  of  the  Strategy  were  not 
fully achieved. The main reasons identified in this respect are: 

56 

 
 
-  The  lack  of  a  framework  for  regularly  monitoring  the  Strategy’s  progress 
prevented  a  regular  review  of  implementation  and  the  adoption  of  corrective 
actions. 

-  Some of the actions, although implemented, did not bring the expected results. 
-  Some of the objectives, especially in the areas of equality, were rather ambitious, 
notably  because  they  were  supported  by  actions  that  were  not  always  sufficient 
for their achievement. 

-  Some  of  the  EU  actions  were  conceived  to  supplement  and  support  Member 
States action and part of the Strategy’s impact (and achievement of the Strategy’s 
objectives) depended on Member States. However, following the global financial 
crisis and the recession there were widespread public spending cuts that reduced 
the capacity of some Member States to implement actions related to the Strategy. 
-  The  financial  resources  available  at  EU  level  for  disability-related  actions  were 

- 

not adequate and proportionate. 
In spite of the different benefits of EU funding, 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,  initiatives  having  a  clear  purpose  (such  as,  for  example, 
funding de-institutionalisation) were more effective in addressing disability issues 
than those focusing on general social issues. 

Lessons learned 

Realistic  objectives  supported  by  adequate  actions:  the  Strategy  included  certain 
ambitious objectives which were not always supported by equally ambitious actions. This 
sometimes  resulted  in  implementation  gaps  between  the  objectives  of  the  Strategy  and 
the achieved results. Objectives and actions should thus be better aligned. 

Measurable  policy  indicators:  it  is  necessary  to  ensure  a  comprehensive  set  of 
quantitative indicators, of a clear timeline and of a monitoring mechanism for measuring 
progress  of  the  Strategy  in  order  to  create  a  momentum  for  addressing  delays  and 
weaknesses in the course of the implementation of the Strategy. 

Statistics  and  data  collection:  a  comprehensive  framework  of  statistic  indicators 
covering all the key priority areas of the Strategy is needed to identify gaps, to measure 
progress in the situation of persons with disabilities in the EU and to set clear targets for 
the Strategy. In  general  terms, EU-wide  disaggregated data on persons  with  disabilities 
would  be  an  important  tool  for  monitoring  and  evaluating  European  policies  aimed  at 
improving the situation of persons with disabilities. 

Disability  knowledge:  knowledge  by  policymakers  at  EU  institutional  level  about 
disability  issues  and  about  the  UNCRPD  has  to  be  equally  present  across  services. 
Unequal knowledge proved to be an obstacle for inclusive and efficient policymaking. 

Involvement  of  persons  with  disabilities:  consulting  and  involving  persons  with 
disabilities  (and  notably  organisations  representing  persons  with  disabilities)  from  the 
start of any legislative and policy initiative relating to persons with disabilities is a key 
element for delivering effective and inclusive policy making. 

57 

 
 
Progress  at  national  level:  a  comprehensive  overview  and  monitoring  of  progress 
regarding  the  situation  of  persons  with  disabilities  requires  an  evaluation  of  EU-level 
action  as  well  as  of  national-level  action.  Limitation  of  the  evaluation  of  the  current 
strategy  to  EU-level  action  had  consequences  for  the  implementation  results  of  the 
Strategy. This element will have to be taken into account in future policy decisions. 

58 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

DG  Employment,  Social  Affairs  and  Inclusion  (DG  EMPL)  is  the  lead  DG  for  the 
evaluation  of  the  Council  Recommendation  on  the  European  Disability  Strategy  2010-
2020. The initiative was published in Decide on 03 September 2018 with the reference 
PLAN/2018/3426101. 

2.  ORGANISATION AND TIMING 

The  evaluation  started  on  28  September  2018  with  the  publication  of  the  Evaluation 
Roadmap102 and has been carried out with the support of the Inter Service Group chaired 
by  DG  EMPL  to  which  the  following  DGs  were  invited:  AGRI,  BUDG,  CNECT, 
COMM, COMP, DEVCO, DGT, EAC, ECFIN, ECHO, EMPL, ENV, ESTAT, FISMA, 
GROW, HOME, HR, IAS, JRC, JUST, MOVE, NEAR, OP, REGIO, RTD, SANTE, SG, 
SJ, TAXUD and TRADE. 

The group met or was consulted through written consultation five times.  

Here below are the key steps of the evaluation: 

-  13/09/2018 - evaluation roadmap and terms of reference for the external study  
-  17/06/2019 - inception meeting for the external study  
-  17/10/2019 - draft interim report of the external study  
-  18/11/2019 - interim report of the external study   
-  19/03/2020 - written consultation on the draft final report of the external study  
-  05/08/2020 - draft SWD 
-  09/09/2020  -  written  consultation  on  the  draft  final  report  of  the  external  study 

and on the draft SWD 

-  15/10/2020 – inter-service consultation on the draft SWD 
-  20/11/2020 – publication of the SWD 

101

102

 https://intragate.ec.europa.eu/decide/sep/index-compressed.html?Zebra_v3.14.7.15803-2020-04-

16T15:23:39.817+02:00#/overview-screen/view=dossier-details&planning-id=SPECIFIC-DOSSIER-
2018-36357 

 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1929-European-Disability-

Strategy-2010-2020-evaluation 

59 

 
 
 
                                                            
 
 
3.  EXCEPTIONS TO THE BETTER REGULATION GUIDELINES 

The  consultations  on  the  draft  final  report  of  the  external  study  and  on  the  draft  Staff 
Working Document were carried out by written procedure over email due to coronavirus 
lockdown. 

4.  EVIDENCE, SOURCES AND QUALITY 

Expertise  internal  and  external  to  the  European  Commission  was  used  to  ensure  good 
quality of the evaluation and related Staff Working Document. The main sources of the 
evaluation include:  

  External study carried out by ICF consortium. The study has been conducted in 
line with the Request of Services and the agreed inception report. It includes all 
agreed  components  and  is  based  on  relevant  qualitative  and  quantitative  data 
although  less  information  and  evidence  on  effectiveness  was  included  than 
expected.  The  analysis  and  conclusions  are  sound  while  methodology  and 
limitations are clearly outlined. Conclusions and recommendations are relevant. 
  An internal questionnaire by DG EMPL on the European disability strategy 2010-

2020 addressing NGOs at EU level 

  An internal questionnaire by DG EMPL on the European disability strategy 2010-

2020 addressing representatives of Member States at EU level 

  Studies/toolkits  produced  by  the  Academic  Network  of  European  Disability 

Experts (ANED)103 

  Reports from the European Days of Persons with Disabilities 2019104 
  Opinion from the European Economic and Social Committee on Shaping the EU 

agenda for disability rights 2020-2030105 

  Motion  for  a  resolution  of  the  European  Parliament  on  the  European  Disability 

Strategy post‑ 2020106 

  European Union Statistics on Income and living conditions – EU SILC107 

103 https://www.disability-europe.net/ 

104 https://ec.europa.eu/social/main.jsp?langId=en&catId=88&eventsId=1487&furtherEvents=yes 

105

https://www.eesc.europa.eu/en/our-work/opinions-information-reports/opinions/shaping-eu-agenda-

disability-rights-2020-2030-contribution-european-economic-and-social-committee-own-initiative-
opinion 

106 https://www.europarl.europa.eu/doceo/document/B-9-2020-0123_EN.html 

107 https://ec.europa.eu/eurostat/web/income-and-living-conditions 

60 

 
 
 
 
                                                            
ANNEX 2: STAKEHOLDER CONSULTATION 

This annex presents an overview of the consultation work conducted for the evaluation of 
the  European  Disability  Strategy  2010-2020.  Most  of  the  consultation  activities  were 
carried out by an external contractor108 on behalf of DG Employment, Social Affairs and 
Inclusion (DG EMPL).  

Prior  to  the  evaluation,  an  Evaluation  Roadmap 109  was  published  for  consultation 
between  29  August  and  26  October  2018.  The  13  respondents  to  the  consultation 
included  10  non-governmental  organisations,  2  business  associations,  and  1  private 
citizen. 

The feedback received on the Roadmap suggested that:  

-  EU  Disability  Strategy  should  recognise  there  are  different  forms  of  disability 
which impact on citizens in various ways, requiring varied and personalised forms 
of intervention and support; 

-  Persons with disabilities should be involved in the evaluation and they should be 

consulted in the drafting of the online consultation; 

-  Targeted consultation should offer ensure full accessibility in terms of languages 
as  well  as  of  disability-related  needs,  in  order  to  reach  a  larger  number  of 
respondents; 
In  terms  of  proposals  for  a  new  European  Disability  Strategy,  the  role  of  the 
social  economy  in  integrating  persons  with  disabilities  into  society  and  the 
economy should be promoted.  

- 

These  aspects  were  considered  in  the  design  and  delivery  of  the  evaluation.  The 
consultation activities undertaken during the evaluation were the following: 

-  A public consultation published on the European Commission’s ‘Have your say’ 

portal and open to all EU citizens and organisations; 

-  Semi-structured  interviews  with  EU  stakeholders,  selected  by  the  contractor  in 
cooperation  with  Commission  services.  This  included  the  following  types  of 
stakeholders:  European  Institutions,  UNCRPD  Coordination  Mechanisms  and 
Monitoring  entities,  Organisations  representing  persons  with  disabilities,  Non-
governmental  organisations,  Social  partners,  Academia  and  education,  Service 
providers/ private business representatives, and Equality and human rights bodies; 
-  Semi-structured  interviews  with  Member  State  stakeholders  and  focus  groups 

with Member State stakeholders. 

108 ICF consortium  for the European Commission, 2019 

109

 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1929-European-Disability-

Strategy-2010-2020-evaluation  

61 

 
 
 
                                                            
1.  TARGET GROUPS AND CONSULTATION UNDERTAKEN FOR THE EVALUATION 

Three different target groups were established for the evaluation:  

1.  The general public 
2.  EU level stakeholders 
3.  Member State level stakeholders 

Each  method  targeted  specific  stakeholders  to  collect  particular  forms  of  data.  An 
overview  of  the  target  groups,  consultation  methods,  and  those  consulted  is  provided 
below in Figure 1. 

Figure 1: Consultation methods and their target groups 

Source: ICF analysis 

2.  PUBLIC CONSULTATION  

The public consultation was launched on 31 July 2019 and was closed on 13 November 
2019.  It  was  hosted  on  the  European  Commission  website.    The  public  consultation 
collected  views  from  a  wide  range  of  respondents  (including  stakeholder  organisations 
and interested citizens living in the EU) on their perceptions of the European Disability 
Strategy, its implementation to date, and their opinions on important future priorities in 
disability policy.  

62 

 
 
 
 
The  questionnaire  was  developed  based  on  discussions  with  DG  EMPL  and  pertinent 
Commission services to ensure that the public consultation would meet the requirements 
of the evaluation and provide the European Commission with a useful evidence base on 
which to base further actions in the disability policy area.  

To disseminate the public consultation, the contractor worked with Member State experts 
to promote the public consultation to key stakeholders and their networks at both EU and 
Member  State  levels.  In  addition,  the  contractor  worked  with  the  European  Disability 
Forum  (EDF),  an  umbrella  organisation  of  persons  with  disabilities,  to  promote  the 
public consultation. This was done through the creation of social media posts in different 
EU languages and by sending these out through the EDF social media channels. 

Figure 2: Public consultation – respondents per country of origin 

Source: ICF analysis of public consultation 

A  total  of  2,547  responses  were  submitted  from  all  EU  Member  States.  Respondents 
institutions,  Business  and  Consumer  organisations, 
included  Academic/research 
Environmental  organisations,  Non-governmental  organisations 
(NGOs),  Public 
authorities,  Trade  unions  and  other  forms  of  stakeholders.  A  total  of  573  (22.5%) 
responses  were  from  organisations,  whereas  1974  (77.5%)  responses  came  from 
individuals.  Two  versions  of  the  questionnaire,  a  standard  version  and  an  easy-to-read 
version, were published, each accessible in all 24 official EU languages. 

In addition to the responses received to the public consultation questionnaire, a total of 
107 position papers were received. Among the position papers, 37 were in English and 
70 were in other EU languages. A process for examining each of these documents was 
followed, with the documents analysed by a native speaker to determine their relevance 
to  each  evaluation  criterion.  Of  the  one  hundred  and  seven  documents  were  submitted, 
forty-nine contained relevant information for the evaluation. Key point summaries were 
prepared for useful documents that could be incorporated into the evaluation’s evidence 
base.  

63 

 
 
 
 
RESULTS FROM THE PUBLIC CONSULTATION 

Effectiveness 

The  public  consultation  provided  some  useful  data  with  which  to  understand  overall 
progress for persons with disabilities and the contribution of the Strategy: 

-  Overall,  56%  of  respondents  agreed  or  somewhat  agreed  that  the  situation  for 
persons with disabilities improved over the past 10 years in their Member State, 
with 52% of respondents agreeing or somewhat agreeing that the contribution of 
the Strategy helped in this improvement. 

-  Among  persons  with  a  disability  52%  agreed  or  somewhat  agreed  that  the 
situation  for  persons  with  disabilities  improved  in  the  past  10  years  in  their 
Member State, 48% agreed or somewhat agreed that the Strategy  contributed to 
improving the situation. 

-  74% of organisations and 51% of individuals agreed or somewhat agreed that the 
situation of persons with disabilities improved over the past 10 years in their MS. 
63% of organisations and 47% of individuals somewhat agreed or agreed that the 
Strategy has helped to improve the situation for persons with disabilities in their 
MS. 

-  Of  those  stating  they  had  knowledge  of  the  Strategy  33%  agreed  or  somewhat 
agreed that the situation for persons with disabilities had improved over the last 
10  years  in  their  Member  State,  52%  of  such  respondents  agreed  or  somewhat 
agreed  that  the  Strategy  helped  to  improve  the  situation  for  persons  with 
disabilities.  

The table overleaf summarises the effectiveness results from the public consultation for 
different areas of the Strategy. Key points which emerge from this analysis: 

-  The area of accessibility (66%), followed by participation (55%), education and 
training (54%), and equality (51%) are the areas where most respondents identify 
that  greatest  progress  has  been  made  in  improving  the  lives  of  persons  with 
disabilities. 

-  The areas of employment (40%) and health (41%) are the areas of action where 
lowest  levels  of  progress  for  persons  with  disabilities  were  observed  by  survey 
respondents. In the area of health 46% of persons with disabilities disagreed there 
had been improvement, with 5% stating the same in the area of Employment. 
-  For each area of action, a greater number of respondents with no disability agree 
or somewhat agree that there has been progress for persons with disabilities than 
those with a disability. 

Table 1: Public consultation - effectiveness results for the different areas of the Strategy 

Area 

Opinion 

Respondents 
with 
knowledge 
of 
Strategy 

the 

Respondents 
with 
disabilities 

Respondents 
without 
disabilities 

Organisations   Individuals  

64 

 
 
Area 

Opinion 

Respondents 
with 
knowledge 
of 
Strategy 

the 

Respondents 
with 
disabilities 

Respondents 
without 
disabilities 

Organisations   Individuals  

/ 
Agree 
Somewhat agree  

66% 

63% 

74% 

50% 

48% 

Accessibility 

Somewhat 
disagree 
disagree 

/ 

22% 

25% 

12% 

37% 

40% 

/ 
Agree 
Somewhat agree  

55% 

51% 

69% 

46% 

40% 

Participation 

Somewhat 
disagree 
disagree 

/ 

28% 

19% 

15% 

38% 

43% 

/ 
Agree 
Somewhat agree  

51% 

47% 

65% 

45% 

42% 

Equality 

Somewhat 
disagree 
disagree 

/ 

33% 

37% 

16% 

33% 

44% 

/ 
Agree 
Somewhat agree  

40% 

37% 

52% 

39% 

38% 

Employment 

Somewhat 
disagree 
disagree 

/ 

41% 

45% 

26% 

39% 

44% 

Agree 
/ 
Somewhat agree  

54% 

53% 

60% 

43% 

46% 

Education 
and Training 

Somewhat 
disagree 
disagree 

/ 

30% 

33% 

21% 

41% 

39% 

Agree 
/ 
Somewhat agree  

48% 

44% 

64% 

47% 

39% 

Social 
Protection 

Somewhat 
disagree 
disagree 

/ 

35% 

40% 

14% 

33% 

45% 

65 

 
Area 

Opinion 

Respondents 
with 
knowledge 
of 
Strategy 

the 

Respondents 
with 
disabilities 

Respondents 
without 
disabilities 

Organisations   Individuals  

/ 
Agree 
Somewhat agree  

41% 

38% 

53% 

37% 

32% 

Health 

Somewhat 
disagree 
disagree 

/ 

41% 

46% 

22% 

41% 

52% 

Source: ICF analysis of public consultation 

Efficiency  

Views expressed through the public consultation relating to extent to which the resources 
provided for the Strategy were adequate were somewhat mixed: 

-  An  average  of  22%  of  respondents  with  knowledge  of  the  Strategy  agreed  that 
funding  for  each  area  of  action  was  adequate  (39%  disagreed  or  somewhat 
disagreed).  The proportion of respondents who “agreed” or “somewhat agreed” 
that  the  resources  were  adequate  varied  between  15%  (for  the  area  of  external 
action) and 26% (for the area of accessibility).  

-  The proportion of respondents that did not agree that funding for the Strategy was 
adequate ranged from 28% (for the area of action “external action”) and 44% (for 
the area of employment). 

-  Respondents with disabilities or those caring for someone with a disability were 
more likely to disagree that the Strategy was adequately resourced than those with 
no disability. Additionally, a higher share of organisations than individuals agreed 
that the Strategy was adequately resourced. 

Coherence 

In relation to the coherence of the Strategy with measures established in Member States, 
data analysis of public consultation responses shows that:  

-  Around  40%  of  the  respondents  agree,  or  somewhat  agree  that  the  national 
priority  measures  of  their  country  are  in  line  with  the  8  areas  of  action  of  the 
EDS. This view was most frequently expressed by organisations (50%) and least 
frequently by individuals (30%) and those with disabilities (35%). 

-  When looking at the different areas of action of the Strategy there is significant 
difference in the views of survey respondents between the areas of the Strategy: 
- 

In the specific area of accessibility, a greater share of respondents (51%) than 
for  other  areas  of  the  Strategy  agreed/somewhat  agreed  that  there  was 
alignment between national policy and the Strategy. 

-  Of  those  respondents  that  disagreed/somewhat  disagreed  that  national 
priorities were aligned with the Strategy (36% on average), the most common 

66 

 
 
 
areas  of  the  Strategy that  were  identified  as  lacking  coherence  with  national 
policy were: employment (43%) and social protection (40%). 

Relevance 

Analysis of the responses from the public consultation found that the thematic areas of 
the Strategy are still considered relevant for the future. Around 66% of the respondents of 
the public consultation found 7 of the 8 areas of the Strategy still relevant for the future, 
whereas 55% considered external action also relevant. 

Added value  

From the public consultation, the following findings emerge from this analysis:  

-  At Member State level, 52% of respondents agreed or somewhat agreed that the 
Strategy  had  helped  to  improve  the  situation  for  persons  with  disabilities, 
compared to 53% who stated the same for the effect of the Strategy at EU level. 
-  Relatively few respondents stated that the Strategy had not helped to improve the 
situation  of  persons  with  disabilities  (27%  stated  they  somewhat  disagreed  or 
disagreed it had at Member State level, compared to 11% answering the same in 
relation to throughout the EU). 
Interestingly, there were a high level of respondents stating that they do not know 
whether  the  Strategy  had  helped  to  improve  the  situation  for  persons  with 
disabilities at EU level (20%) and worldwide (38%). 

- 

Important topics 

Respondents were  also  asked to  express their views about the  most  important  topics in 
the area of disability. Accessibility, ageing, independent living, children with disabilities 
and employment were considered the most important. 

67 

 
Figure 3: Public consultation – important topics identified by respondents 

Source: ICF analysis of public consultation 

EU stakeholder interviews 

Consultations  with  EU  stakeholders  took  place  in  the  form  of  interviews  and  occurred 
face-to-face  and  via  telephone  to  accommodate  availability  and  preference  of 
interviewees.  Interviews  were  conducted  from  September  2019  to  December  2019  and 
lasted between 45 to 90 minutes.  

These  interviews  with  EU  stakeholders  helped  further  develop  findings  of  the  desk 
research and allowed stakeholders to provide evidence to answer the research questions.  

68 

 
 
 
The  semi-structured  interviews  used  a  topic  guide  covering  key  issues  to  inform  the 
evaluation  framework.  Individual  questions  were  formulated  to  assess  the  relevance, 
effectiveness, efficiency, coherence and added value of the European Disability Strategy, 
to  understand  the  current  situation  of  people  with  disabilities  in  the  EU  and  to  gather 
opinions  on  the  future  direction  of  EU  disability  strategy.  Interview  questions  were 
tailored according to the type of stakeholder consulted. 

Twenty  semi-structured  interviews  were  conducted  with  EU-level  stakeholders.  An 
initial list of relevant stakeholders was identified through desk research and refined based 
on  suggestions  from  the  Inter  Service  Steering  Group  established  by  the  European 
Commission to oversee the evaluation.  

The  semi-structured  interviews  included  17  organisations,  10  of  which  are  directly 
involved  in  addressing  the  needs  of  persons  with  disabilities  in  general  or  aiming  to 
support the needs of persons with specific types of disabilities. In general, one individual 
was interviewed per organisation. However, two individuals were interviewed from the 
European Disability Forum and three individuals from the European Union Agency for 
Fundamental Rights (FRA).    

The table below outlines the interviews undertaken with EU stakeholders 

Table 2: EU-level stakeholders interviewed 

Stakeholder types  

Stakeholder organisation  

European Commission Institutions 

European Ombudsman 

UNCRPD Coordination Mechanisms 
and Monitoring entities 

European Agency for Special Needs and Inclusive 
Education 

Disabled Persons’ Organisations 
(DPOs) 

Autism Europe 

Inclusion Europe (AISBL) 

European Union of the Deaf 

Mental Health Europe 

Disabled Peoples' International Europe 

European Platform for Rehabilitation 

Non-governmental organisation 
(NGO) 

European Disability Forum 

Social partners  

European Federation of Public Service Unions (EPSU) 

Academia and education 

Federation of European Social Employers (FESE) 

The Academic Network of European Disability Experts 
(ANED) 

Service providers/ private business 
representatives 

European Association of Service providers for Persons 
with Disabilities (EASPD) 

Community of European Railway and Infrastructure 
Companies 

Social Services Europe 

Equality and human rights bodies 

European Network of Equality Bodies (EQUINET) 

European Union Agency for Fundamental Rights (FRA) 

Source: ICF analysis 

69 

 
3.  MEMBER STATE STAKEHOLDER INTERVIEWS AND FOCUS GROUPS 

A network of disability experts from each Member State was established by the team of 
the  external  contractor  to  conduct  national  level  consultation,  including  desk  research, 
stakeholder interviews and focus groups. Focus groups were generally organised through 
national councils for persons with disabilities (or similar organisations in Member States 
where  such  organisations  do  not  currently  exist).  Member  State  experts  also  conducted 
semi-structured  interviews  face  to  face  and  via  telephone.  Both  interviews  and  focus 
groups  were  conducted  between  September  2019  and  December  2019,  with  national 
representatives and key stakeholders for persons with disabilities, to supplement evidence 
gathered through desk review.  

The stakeholder  consultations at Member State level aimed to  build on the information 
gathered  through  desk  review.  More  specifically,  to  gather  further  information  and 
opinions  on  the  progress  of  implementation  in  specific  areas  of  action,  particularly 
focusing on national level actions motivated by the Strategy. 

Outputs  from  these  activities  (i.e.  desk  review,  semi-structured  interviews  and  focus 
groups)  were  recorded  by  Member  State  experts  in  a  standardised  country  report 
template. The interviews and focus groups adhered to a topic guide focused on assessing 
the extent of change in Member State in the issues covered by the Strategy since 2010, 
particularly relating to Accessibility, Participation, Equality, Employment, Education and 
training, Social protection and Health. In addition, the topic guide included questions to 
understand  drivers  of  change  in  national  disability  policy  and  changes  attributed  to  the 
European Disability Strategy. 

A  total  of  162  interviews  and  18  focus  groups  were  conducted  with  Member  State 
stakeholders.  

4. 

ISSUES ENCOUNTERED AND ACTIONS TAKEN DURING THE CONSULTATIONS  

Throughout  the  course  of  the  evaluation  some  challenges  emerged  in  relation  to  the 
consultation methods. This section describes the issues and the actions taken by the team 
of the external contractor for each of the consultation activities. 

Public consultation  

-  During the public consultation, there were particular access issues that inhibited 
the  ability  of  respondents  to  answer  questions.  These  included  language 
defaulting to EN after some filter questions. Some stakeholders reported that the 
requirement to register prior to completing the public consultation deterred them 
from taking part to the consultation. In addition, stakeholders reported technical 
issues such as being unable to fill-out certain required fields, which deterred them 
from submitting their response. In order to mitigate the issue, the mandatory on-
line authentication was de-activated. 

-  Low  response  rate  in  some  Member  States.  This  issue  was  mitigated  by 
contacting  the  relevant  Member  State  experts  and  urging  them  to  encourage 
stakeholders  to  complete  the  public  consultation  and  publicise  it  through  their 
networks. 

70 

 
 
EU stakeholder interviews 

Some  stakeholders  mentioned  they  had  taken  part  in  the  public  consultation  and  felt 
additional involvement through interviews was redundant. Moreover, stakeholders cited 
that  they  have  been  extensively  involved  in  the  previous  evaluation  and  felt  further 
involvement  would  provide  no  added  value.  These  issues  were  flagged  to  DG  EMPL 
immediately  and  a  clear  communication  channel  (via  email,  telephone  and  face-to-face 
meetings) was maintained to ensure timely response, to effectively identify and approach 
other relevant EU-level interviewees.  

Member State stakeholder interviews and focus groups  

Member State experts pointed to several issues that hindered their research activities. The 
timing of the evaluation was cited as an issue as Member State experts found it difficult 
to secure interviews or focus groups with stakeholders during the summer holiday period. 
In addition, some national experts mentioned that stakeholders were initially hesitant to 
take part assuming that their identity would be disclosed. This issue was easily mitigated 
by assuring both Member State experts and relevant stakeholders that their identity will 
be kept anonymous. To fit in which the schedule of interviewees the interviews were kept 
as succinct as possible, with interviewees also permitted to provide written information if 
that was there preferred method. In addition, some stakeholders refused to participate due 
to  issues  related  to  accessibility  (e.g.  not  wanting  to  travel  long  distance  or  not  having 
access  to  accessible  technology  to  participate  in  the  interview  or  focus  group).  The 
Member  State  experts  who  raised  such  issues  were  provided  additional  resources  (i.e. 
cost  of  renting  accessible  venues  and  travel  costs)  to  hold  focus  groups  in  accessible 
venues  and  hold  interviews  face  to  face  in  locations  easily  accessible  for  interviewees, 
though this was only required in three cases.  

5.  LESSONS FOR FUTURE CONSULTATIONS  

- 

In  order  to  identify  and  prevent  accessibility  difficulties  and  technical  issues, 
extensive  piloting  of  the  public  consultation  questions  should  be  conducted 
involving  Disabled  Persons  Organisations  and  other  relevant  stakeholders.  This 
could  be  done  through,  for  example,  a  soft  launch  where  a  small  sample  of 
stakeholders receives an invitation to complete the public consultation before it is 
made openly available.  

-  To ensure the public consultation reaches as wide as possible an audience and to 
obtain  a  good  response  rate,  efforts  can  be  taken  to  extensively  promote  the 
public  consultation  prior  to  publication.  This  consultation  was  promoted  after 
through established social media platforms of stakeholder organisations that were 
familiar to persons with disabilities such as Facebook, LinkedIn, and Twitter 

71 

 
 
ANNEX 3: INTERVENTION LOGIC 

72 

 
 
 
ANNEX 4: METHODS AND ANALYTICAL MODELS 

This annex describes the methodology used to undertake the evaluation. It firstly outlines 
the way in which an inclusive research methodology  was applied in the evaluation and 
how  analysis  was  conducted.  The  section  then  provides  a  brief  description  of  the 
approach  taken  for  each  of  the  four  main  research  tasks  included  in  the  evaluation, 
identifying specific issues and the way in which they were mitigated. 

The research adopted an inclusive methodology 

The  evaluation  required  a  range  of  consultations  with  different  types  of  stakeholders 
operating  at  both  EU  and  Member  State  level.  This  involved  EU  level  stakeholder 
interviews, Member State level consultation (interviews and focus groups), and e-surveys 
such  as  a  public  consultation  (the  consultation  was  published  on  the  European 
Commission’s  ‘Have  your  say’  portal).  On-line  surveys  were  also  undertaken  among 
Non-governmental  organisations  (ONGs)  and  Member  State  representatives  on  the 
Disability High Level Group (DHLG). 

When  undertaking  these  consultations  it  was  important  to  ensure  that  a  wide  range  of 
persons with disabilities and stakeholder groups had the opportunity to provide input into 
the evaluation. An inclusive research methodology for enabling consultees to participate 
through  forms  of  consultation  that  were  appropriate  for  them  was  delivered  in  the 
following ways:  

-  When  arranging  and  conducting  EU  level  and  Member  State  level  interviews, 
plain language was used to describing the purpose and requirements of consultees 
in all forms of consultation. 

-  For  interviews,  consultees  were  offered  the  opportunity  to  provide  input 
according  to  the  most  suitable  method  (e.g.  in  written  format,  via  skype  call, 
telephone, teleconference, or face-to-face interview). 

-  Where  focus  groups  were  conducted  in  Member  States, 

involved 
organisations  representing  persons  with  disabilities  to  discuss  the  Strategy  and 
future  EU  disability  strategy.  Focus  group  attendees  were  provided  with 
information  prior  to  focus  groups.  This  information  outlined  the  purpose  of  the 
study and the key issues to be discussed during the focus group. 

they 

-  Prior to focus groups, an assessment of participant requirements was undertaken 
by  Member  State  experts  to  understand  accommodation  and  participant 
requirements. This involved assessing the need for, and organising sign language 
and/or  hearing  loop  facilities.  Where  appropriate,  consultees  in  Member  States 
were  also  offered  the  opportunity  to  participate  in  the  evaluation  through 
providing  written  answers  or  comments  on  the  evidence  assembled  by  Member 
State experts. 

73 

 
 
 
-  The public consultation included an easy-to-read version of the questions, having 
a  limited  number  of  questions  expressed  in  simple  terms  to  enable  as  many 
persons as possible to answer the questions.  

An evaluation framework was used to guide research and analysis  

An  evaluation  framework  was  established  during  the  inception  stage  of  the  evaluation. 
The  framework  used  the  individual  evaluation  questions  to  develop  specific  judgement 
criteria  used  to  answer  the  research  questions,  it  then  identified  relevant  evidence  and 
indicators (qualitative and quantitative) that would be required to make these judgements. 
The framework then identified specific research tasks and methods that would be used to 
generate the required evidence.    

For  each  of  the  research  questions  a  similar  process  of  triangulation  was  followed  in 
order  to  combine  the  results  from  different  sources  and  analytical  techniques.  The  first 
step  in  the  process  of  analysis  was  to  analyse  the  relevant  information  collected  from 
each research tasks/source (document review, public consultation, member state research, 
EU level interviews).  

- 

Individual sources of information were then analysed and organised by evaluation 
question so that they could be compared, and analysis of emerging messages and 
trends was undertaken. 

-  At  the  same  time  an  assessment  of  the  clarity  of  each  evidence  base  was 
undertaken,  though  mitigating  measures  to  address  this  were  taken  during  the 
fieldwork stage, for example: 

-  encouraging more respondents to the public consultation, 
-  approaching  more  interviewees  in  the  MS  research  and  EU  level 

interviews when needed, 

-  undertaking further document review  

-  Comparison of trends and patterns to understand the extent to which data sources 
produce  similar  findings  has  been  undertaken  to  produce  a  set  of  emerging 
messages  from  the  data  analysis.  Additionally,  the  extent  to  which  diverging 
messages emerged between sources and types of stakeholders has been examined. 
-  The  final  step  was  to  develop  answers  to  research  questions  and  to  produce 
conclusions  and  recommendations  linked  to  the  evidence  base.  The  answers  to 
research questions and the conclusions and recommendations has been discussed 
with disability experts included in the research team and the ISG. 

This process was important for this evaluation due to the range of sources of information 
needed  to  be  included  in  the  analysis  (for  example,  views  of  persons  with  disabilities; 
documents  such  as  reports,  analysis,  and  legal  instruments;  consultations  with 
stakeholders at EU and Member State level). 

There were a number of issues during the research, which required mitigating action to 
ensure  that  the  evidence  was  as  reliable  as  possible  and  the  findings  transparent  and 
robust. These are outlined below for different research tasks. They included, difficulty in 
engaging  with  key  stakeholders;  analytical  challenges  related  to  the  design  of  the 
Strategy, its objectives and actions; limited information upon which to base assessment 
of  the  Strategy’s  achievements  and  influence;  and,  different  levels  of  specificity  in  the 
available evidence.  

74 

 
 
Specific research tasks, issues encountered and mitigating measures 

Task  1:  Mapping  the  progress  of  objectives  and  key  actions  of  the  European 

Disability Strategy  

The  aim  of  this  task  was  to  assess  the  progress  in  delivering  EU  level  actions  and  to 
identify  the  extent  to  which  the  Strategy  supported  and  supplemented  Member  State 
actions.  The  research  has  been  undertaken  through  both  desk  research  and  targeted 
consultations. At EU level this involved extensive desk review and interviews with key 
stakeholders  and  consultation  with  the  Inter-Service  Steering  Group  to  ensure  that  the 
evidence  gathered  during  the  mapping  exercise  was  accurate.  At  Member  State  level, 
detailed desk research, interviews, and focus groups were undertaken. 

The results of the mapping are contained in Annex 5. The results of the mapping inform 
the  answers  to  various  evaluation  questions  and  are  the  used  as  evidence  to  answer 
research questions. 

Issues encountered and mitigating measures 

The following issues emerged, with mitigation measures put in place during the research 
process: 

- 

It was not always clear from desk review and consultations the degree to which 
progress  had  been  made  for  some  of  the  actions,  because  many  of  the  actions 
were not specific and measurable. This was addressed through consultation with 
ISG  members  and  further  targeted  consultations  with  EU  level  stakeholders 
assisted  in  gaining  clarification  on  factual  matters  related  to  implementation.  It 
was not, however, possible to gain comprehensive information on the impact of 
EU  level  actions.  In  part,  this  is  because  impact  may  depend  on  timeliness  and 
comprehensiveness of Member State level implementation. 

- 

-  Dependencies  between  different  actions  of  the  Strategy  are  not  always  explicit, 
and  it  is  not  possible  to  provide  robust  evidence  of  the  long-term  impact  of 
delivery or non-delivery of particular actions on other actions. 
In general, there is a lack of data to understand the impact of the actions and clear 
attribution of those impacts to the Strategy. The reasons for this are: some actions 
began prior to the publication of the Strategy; many actions are also influenced by 
other  policy  drivers;  impact  depends  on  implementation  at  Member  State  level 
and/or impact is likely to be measurable over the longer term. These issues could 
not be fully mitigated; therefore, the evaluation uses the assembled evidence base 
to provide an overall assessment of the Strategy. 

Task 2: public consultation  

The public consultation collected feedback from a wide range of respondents (including 
stakeholder organisations and interested citizens) on their perceptions of the Strategy, its 
implementation  to  date,  and  their  opinions  on  important  future  priorities  in  disability 
policy. It ran from 31 July to 13 November 2019. The overall number of responses was 
2,547; this is significantly higher than the previous public consultation undertaken for the 
mid-term evaluation of the EU Disability Strategy, which received 1,518 responses. 

75 

 
The  external  contractor  worked  with  DG  EMPL  to  develop  the  questions  and  question 
formats  for  the  public  consultation  so  that  it  would  align  with  the  requirements  of  the 
evaluation. An important priority for  DG EMPL was to  publish  the public  consultation 
before the summer so that the consultation could be completed and analysed prior to the 
European Day of Persons with Disabilities at the end of 28-29 November 2019.  

The  external  contractor  worked  with  the  European  Disability  Forum  (EDF)  to  promote 
the public consultation through their social media. To make this as engaging as possible, 
the  external  contractor  created  social  media  posts  in  different  EU  languages,  with  the 
purpose of encouraging as many responses as possible from members of the public. The 
European Commission also encouraged non-governmental organisations to publicise the 
public consultation. 

A  process  for  examining  each  of  these  documents  was  followed,  with  the  documents 
analysed to determine their relevance to each evaluation criterion. A total number of one 
hundred  and  seven  documents  were  submitted,  forty-nine  of  which  contained  relevant 
information for the evaluation. 

Issues encountered and mitigating measures 

There were some initial issues related to respondents accessing the public onsultation that 
were encountered immediately following its launch. These included: 

-  The language defaulting to English after the initial language filter questions and 

some respondents not being able to enter data into some of the fields.  

-  A more significant issue reported by respondents was that they could not respond 
to the public consultation without an EU login. This requirement was removed by 
the  European  Commission.  This  requirement  is  a  mandatory  feature  of  public 
consultations  undertaken  by  the  European  Commission  and  this  exception 
required approval by the Chief Operating Officer of the Commission. 

-  The  public  consultation  was  launched  during  the  summer  and  was  initially 
attended  by  low  number  of  respondents.  As  described  above,  the  external 
contractor  worked  with  Member  State  experts  and  with  the  European  Disability 
Forum (EDF) to promote the public consultation as widely as possible.  

Task 3: Targeted consultations   

DG  EMPL  undertook  targeted  consultations  held  with  non-governmental  organisations 
(strategic  dialogue)  and  MS  representatives  (Disability  High  Level  Group)  prior  to  the 
external  contractor.  These  consultations  were  conducted  using  the  EU  survey  tool, 
analysis  of  findings  from  these  consultations  are  included  in  the  evidence  base  used  to 
answer the study questions.   

The external  contractor  undertook  targeted consultations at both  EU and Member  State 
level.  Additionally,  focus  groups  were  arranged  where  possible  through  National 
Councils  for  Persons  with  Disabilities  or  similar  organisations.  At  EU  level, 
consultations were undertaken through semi-structured interviews. 

The purpose of these consultations was to deepen the evidence base assembled through 
the desk research. The consultations provided an opportunity to also gather stakeholder 

76 

 
opinions  regarding  the  overall  impact  of  the  Strategy  and  their  views  on  what  future 
disability strategy should prioritise.  

2,547  participants  took  part  in  the  public  consultation  and  182  interviews  were 
undertaken for the study (20 at EU level and 162 and Member State level). Several types 
of organisations were interviewed at Member State level. A full list of interviewees and 
focus group participants is included in the Synopsis Report.  

Issues encountered and mitigating measures 

Consultations were undertaken through Member State experts who provided the external 
contractor with bi-weekly progress reports. This enabled any issues encountered during 
the  consultation  to  be  understood  and  dealt  with  in  a  timely  manner.  Common  issues 
encountered during the Member State research were: 

-  a low level of knowledge of the Strategy and its content; 
- 

lack  of  time  to  participate  in  interviews  (initially  interviewees  were  approached 
over the summer period); and  

-  ensuring  interviews  (and  subsequent  Member  State  reports)  remained  on  topic 
and did not focus on highly context specific issues that were beyond the scope of 
the evaluation.  

Issues encountered during the consultations at EU level were: 

- 

Interviewees stating that they had a lack of time to conduct interviews and stating 
that  they  felt  able  to  contribute  to  evaluation  of  the  Strategy  because  they  had 
communicated their views to the Commission. 

-  Some potential interviewees were reluctant to take part in interviews when they 
felt  they  did  not  have  the  knowledge  to  discuss  each  of  the  Strategy’s  areas  of 
action. 

-  A  belief  among  some  stakeholders  that  it  was  not  appropriate  for  them  to 
participate in the evaluation (for example, where they were engaged in design and 
delivery of the Strategy or in separate evaluation activity). 

To  mitigate  this,  interviews  were  focused  only  on  areas  that  interviewees  were 
comfortable  expressing  an  opinion  and/or  alternate  interviewees  were  agreed  with  DG 
EMPL. 

Task 4: Analysis by evaluation criterion  

This task consisted of analysis of the available evidence generated through the research 
undertaken  in  order  to  answer  research  questions  for  each  evaluation  criterion.  This 
followed the following process: 

-  Evidence  was  organised  by  research  activity  (document  review,  public 
consultation,  stakeholder  interviews,  Member  State  research).  Evidence  was 
further broken down by evaluation criterion (effectiveness, efficiency, coherence, 
relevance and EU added value). 

-  To develop and test the emerging findings from the study, the external contractor 
presented selected analysis along with emerging conclusions at the European Day 
of Persons with Disabilities in Brussels in November 2019. 

77 

 
-  Analysis and synthesis of the evidence for each individual research question was 
undertaken  to  determine  the  answers  to  each.  Answers  to  study  questions  were 
then tested through consultation with experts and presented in this report. 

-  A summary of strengths, weaknesses, opportunities, and threats (SWOT) analysis 

was produced for the study. 

Issues encountered and mitigating measures 

A number of factors made evaluating the Strategy actions a challenging exercise. This is 
partly  due  to  the  nature  of  the  objectives  and  actions  included  in  the  Strategy,  for 
example: 

-  There  are  no  clear  performance  measures  for  the  objectives  established  for  the 

overall performance of the Strategy of for its areas of action. 

-  Typically,  the  EU  level  actions  included  in  the  Strategy  do  not  include  explicit 

time-bound targets for their delivery 

-  Observing the effects of many actions is likely to take many years as they rely on 
removal  of  barriers/increased  access,  which  may  take  a  longer  period  for 
corresponding  up-take  to  produce  the  desired  results.  For  example,  establishing 
legal instruments requires subsequent transposition and effective implementation 
at Member State level, there may be a similar time-lag for established tools and 
codes of conduct. 

78 

 
 
 
ANNEX 5: IMPLEMENTATION STATUS OF THE ACTIONS OF THE 
STRATEGY 

This annex includes an overview of the extent to which actions have been implemented 
during  the  Strategy.  The  information  gathered  during  the  evaluation  has  been  used  to 
assess  the  extent  to  which  actions  of  the  Strategy  were  implemented  based  on  some 
judgment criteria reported in the table hereunder. 

Each action has been associated with one of the following three categories:  

-  F  =  Fully  implemented:  are  actions  adopted  without  major  delays  and  in 
accordance with the objectives set out in their inception. This category also includes 
actions  that  were  less  ambitious  than  their  original  objectives  suggested,  but  were 
adopted in a timely manner and actions that were not adopted in a timely manner 
(had some delays), but were matching or surpassing their original objectives. 

-  P  =  Partially  implemented:    actions  not  adopted  timely,  did  not  match  their 
original objectives and were not implemented as they were envisaged. This category 
also includes recurrent actions that were implemented only once. 

-  N  =  Not  implemented:  actions  that  have  not  been  adopted  by  the  end  of  the 

evaluation. 

Table 3: Judgement criteria about the implementation of the actions 

Judgement of 
level of 
implementatio
n 

Judgement of 
level of 
implementatio
n 

Time 
considerations
:  

Adoption 
considerations 

Status of 
actions Put in 
practice 

Fully 
Implemented: 

Evidence that 
the actions were 
adopted in a 
timely manner  

Evidence that 
the actions were 
adopted in a 
timely manner  

Partially implemented: 

Evidence of 
some delays   

Evidence of 
some delays   

Actions were as 
envisaged / a 
little less 
ambitious than 
envisaged 

Adopted as 
envisaged or 
more ambitious 

Actions less 
ambitious than 
envisaged 

Actions put in 
practice / 
recurrent action 
in place as 
planned  

Not 
implemented as 
envisaged / 
recurrent 
actions not 
operating as 
planned 

Not implemented: 

No adoption 

Not applicable 

Not applicable 

Source: ICF analysis 

79 

 
 
 
 
 
 
 
EU level actions associated with Accessibility 

The  accessibility  area  of  action  aimed  to  make  goods  and  services  accessible  to  people  with 
disabilities and promote the market of assistive devices. The implementation status of EU level 
actions is outlined in the table below. 

Table 4: implementation of actions in the area of accessibility 

Actions linked to the adoption of the European Accessibility Act 

A cost benefit analysis and data collection study in preparation for the possible development 
of a European Accessibility Act 

Consultation  with  Member  States  and  other  stakeholders  on  a  possible 
Accessibility Act’ 

‘European 

Prepare a European Accessibility Act setting out a general accessibility framework in relation 
to goods and services including public services 

Explore  the  possibility  to  complete  the  legal  framework  addressing  rights  of  persons  with 
reduced mobility by covering all relevant modes of transport 

Finalise  negotiations  in  Council  on  proposal  for  Regulations  on  the  Rights  of  persons  with 
reduced mobility travelling by bus and coach , sea and internal waterways 

Report on the application on the Regulations on the Rights of persons with reduced mobility 
travelling by air 

Address problems related to compensation claims concerning damages of mobility equipment 
when travelling 

Address accessibility of transport infrastructures through accessibility Mandate 420 

Address accessibility to the built environment 

Implementation of the Urban Mobility Action Plan 

Promote accessibility of the built environment as part of the sustainable construction area of 
the "lead market initiative" 

Implement Standardisation Mandate 420 on accessibility to the built environment 

Exploit the opportunities provided by the Galileo system supporting pilot projects related to 
disabilities 

Make  full  use  of  all  existing  legal  instruments  and  address  disability  matters  in  their 
revisions  following  the  UN  Convention  in  the  area  of  Information  Society  in  line  with  the 
Digital Agenda for Europe 

F 

F 

F 

F 

F 

P 

N 

F 

N 

N 

F 

Implement  the  disability  related  provisions  of  the  electronic  Communication  Directives  and 
the Audio-visual Media Service Directive, considering their recent revisions 

P 

Systematically  evaluate  accessibility  in  revisions  of  legislation  undertaken  under  the  Digital  P 

80 

 
 
 
 
 
 
Agenda, following the CRPD 

Promote dialogue between users and industry leading to voluntary agreements in the areas 
of: copyright & digital television 

Based on a review of options, make proposals by 2011 that will make sure that public sector 
websites (and websites providing basic services to the public) are fully accessible by 2015. 

Develop  accessibility  standards  to  ICT  for  their  use  in  public  procurement  in  the  context  of 
Mandate 376 

Support  research  on  new  technologies  addressing  assistive  technology  and  accessible 
mainstream solutions 

Mainstream accessibility following Design for all in relevant mainstream standards through a 
standardisation Mandate 

Support the inclusion of accessibility and design for all in general curricula for architects and 
engineers to prevent barriers when exercising their professions 

Study the Assistive technology market with a view to improve its functioning 

Raise  awareness  on  accessibility  through  the  establishment  of  an  European  award  of 
accessible cities 

Exploit international dialogues in particular ongoing EU-US dialogue on accessibility standards 
to bring coherence to the markets and build economies of scale 

Follow-up  to  a  planned  Green  paper  on  modernisation  of  EU  public  procurement  rules  and 
explore the possibility of fostering the use of public procurement to improve accessibility by 
developing obligations for public authorities using accessibility standards 

Explore possible measures to improve the accessibility of goods and services in Europe using 
internal market instruments 

Consider relevant disability issues, where possible, within the context of the follow-up to the 
Commission Report  "Towards more efficient and fairer retail services in the Internal Market 
for 2010" and within the context of the e-commerce activities 

Improve  application  of  Article  16  of  the  Structural  funds  general  regulation  to  progress  on 
accessibility 

Take  into  consideration,  in  projects  run  by  the  EU  Joint  Research  Centre,  technical  aspects 
related to usability by all, including people with disabilities 

Support  independent  living  of  persons  with  disabilities  and  older  persons  under  the 
innovation partnership "Active and healthy ageing" of the Innovation Union flagship initiative 

F 

F 

F 

F 

N 

F 

F 

P 

F 

P 

F 

F 

P 

F 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

81 

 
 
 
 
EU level actions associated with Participation 

The participation area of action aimed to: ensure that people with disabilities enjoy all benefits 
of EU citizenship, remove barriers to equal participation in public life and leisure activities, and 
promote the  provision  of quality  community-based services.  The implementation  status  of  EU 
level actions is outlined in the table below. 

Table 5: implementation of actions in the area of participation 

Address  the  obstacles  that  persons  with  disabilities  face  in  exercising  their  rights  as 
individuals, consumers, students and professionals, and political actors 

Study the implications of a mutual recognition of disability cards and related entitlements 

Support  Member  States'  efforts  to  ensure  that  women  and  men  with  disabilities  can  fully 
exercise  their  electoral  rights  by  developing  and  disseminating  standards  on  accessible 
election facilities and campaign material 

F 

F 

Raise awareness among MS of the need to improve accessibility of courts and police buildings  N 

Promote the dissemination of good practices regarding training of public officials on receiving 
and informing persons with disabilities 

Raise  awareness  among  MS  on  the  need  for  proper  assistance  regarding  access  to  legal 
documents and procedures 

Explore ways of facilitating the use of sign language in dealing with the EU institutions 

Monitor  the  proper  implementation  of  article  82(2)  of  the  TFEU  (rights  of  individuals  in 
criminal procedure) relative to interpretation and translation in criminal proceedings on the 
specific issue of interpretation in sign language 

Ensure  inclusion  of  concerns  of  person  with  disabilities  in  initiatives  aimed  to  address 
consumer rights in Europe, in particular with regard to access to services of general economic 
interest 

Address problems related to intra-EU mobility 

Promote dialogue among Member States in the Disability High Level Group on the portability 
of rights such as the right to personal assistance 

Encourage the participation of the EU Member States to the 2000 Hague Convention on the 
International  Protection  of  Adults  and  evaluate  its  application,  foreseen  in  the  Stockholm 
Action Plan, with the view to assess the need for additional proposals as regards vulnerable 
adults 

Identify obstacles encountered by persons with disabilities in the exercise of their rights as EU 
citizens, in particular regarding the right to free movement and residence 

Enhance the use of the European model of disability parking card 

F 

F 

F 

F 

F 

F 

P 

F 

82 

 
 
 
 
 
Raise  awareness  of  the  European  model  of  disability  parking  card  and  combat  its  abuse  by 
producing and disseminating information material for national and local authorities 

F 

Explore opportunities of new technological solutions, for example by funding pilot projects on 
the development of electronic parking cards and control systems 

F 

Enhance  Member  States'  efforts  towards  the  transition  from  institutional  to  community 
based care 

Develop and disseminate a quality framework for community-based services that is inclusive 
of  person  with  disabilities  building  on  the  quality  framework  for  Social  services  of  general 
interest 

Promote the  exchange of  good practices  among  Member  States  in the Disability High Level 
Group on personal assistance funding schemes 

F 

F 

Optimise  the  use  of  Structural  Funds  and  the  Rural  Development  Fund  to  support  the 
development of community-based services 

Identify  good  practice  of  the  use  of  Structural  Funds  and  the  Rural  Development  Fund  in 
relation with the principle of independent and community living 

P 

Develop a training module for European Commission geographical Desk officers (and national 
administrations)  dealing  with  Structural  Funds  and  the  Rural  Development  Fund  on  the 
UNCRPD and common basic principles on deinstitutionalisation 

Develop  a  toolkit  for  managing  authorities  on  how  to  use  Structural  Funds  and  the  Rural 
Development Fund to support the development of community-based services 

Report on Member States' compliance with article 16 of Structural funds general regulation 

Improve the knowledge base on the situation of people with disabilities living in residential 
institutions 

Collect data on the number, size and life conditions of residential institutions 

Study  on  existing  legal  and  administrative  rules  which  directly  or  indirectly  promote 
institutionalisation with recommendations on how to remove them 

Promote the participation of people with disabilities in sports 

Develop  and  disseminate  standards  for  accessibility  of  sports,  leisure,  and  recreation 
organisations, activities, events and venues 

Promote the participation of people with disabilities in European sport events as well as the 
organisation of disability-specific events including Special Olympics 

Include a priority on Social inclusion through and in sport, with a particular regard to persons 
with disabilities, in the future Commission policy and incentive measures in the field of sport 

Promote the access of people with disabilities to cultural materials and events 

F 

F 

F 

P 

P 

F 

F 

F 

83 

 
 
 
 
 
 
Foster the cross-border transfer of copyright works in accessible format 

Ensure accessibility of the interface and contents of Europeana – the European public digital 
library – for persons with disabilities 

Ensure  that  accessibility  criteria  are  taken  into  account  in  the  context  of  the  "European 
Capitals of Culture" award 

F 

F 

F 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with Equality 

The  equality  area  of  action  aimed  to  combat  discrimination  based  on  disability  and  promote 
equal opportunities. The implementation status of EU level actions is outlined in the table below 

Table 6: implementation of actions in the area of equality 

Promote and protect the inherent dignity of persons with disabilities, combat all forms of 
discrimination on the basis of disability, and ensure that persons with disabilities enjoy, on 
an equal basis with others, all fundamental rights and freedom 

Support  the  negotiation  in  Council  of  the  proposal  for  the  Directive  on  equal  treatment 
beyond the field of employment 

Monitoring the application and impact of Directive 2000/78 EC for improving employment of 
persons with disabilities 

Promote the attention to disability matters in equality bodies notably through Equinet 

Provide  guidance  on  reasonable  accommodation  for  people  with  disabilities  addressing 
employers and service providers 

Promote exchange of good practices on legal capacity 

Raise awareness among trade unions on the concept of reasonable accommodation 

Use  of  existing  Progress  programme  (until  December  2013)  to  support  national  activities 
aiming at combating discrimination and promoting equality 

Address disability issues in awareness raising seminars in the areas of non-discrimination and 
equality targeted at civil society organisations 

Address  disability  discrimination  in  annual  calls  for  proposals  aiming  at  supporting  national 
authorities in their fight against discrimination and promotion of equality 

Introduce a disability specific focus in the "What can Social Europe do for you" campaign 

P 

F 

F 

F 

F 

P 

F 

F 

F 

F 

Address disability discrimination in the "For Diversity Against Discrimination campaign", e.g.  F 

84 

 
 
 
 
 
through Diversity days, Journalist award, leaflet, video spot, stand at conferences 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with Employment 

The employment area of action aimed to increase the participation of people with disabilities in 
the labour market, where they are currently under-represented. The implementation status of 
EU level actions is outlined in the table below 

Table 7: implementation of actions in the area of employment 

Increase knowledge of employment situation of people with disabilities, identify challenges, 
propose remedies  

Use 2011 LFS ad hoc module to produce information materials 

Enhance cooperation with relevant third organisations 

Explore a stronger focus on women and men with disabilities  

Optimise the use of the new strategy for jobs and growth, ‘Europe 2020’, for the benefit of 
people with disabilities  

Ensure annual Europe 2020 assessment considers people with disabilities 

Preparation of disability indicator in EMCO indicator subgroup 

Make use of ESIF to promote labour market integration of people with disabilities and other 
vulnerable groups 

Focus  on  what  people  can  do  and  persuade  potential  employers  through  convincing 
arguments and support to people with disabilities  

Involve social partners at the EU level  

When reviewing European employment legislation ensure compliance with UNCPRD 

Encourage employers to commit to diversity policies 

Highlight the scope for action Member States enjoy through the GBER 

Encourage social entrepreneurship with concrete actions in a ‘Social Business Initiative’ 

Give  special  attention  to  the  difficulties  of young  people  with  disabilities  in  the  transition 
from education to employment and  address intra-job mobility,  including those working  in 
sheltered workshops (access to and retention in employment) 

Involvement in PES at the EU level  

F 

F 

F 

P 

N 

F 

P 

P 

F 

F 

F 

F 

85 

 
 
 
 
 
 
 
Identify and promote effective support structures  

Address  the  issue  of  quality  of  jobs,  such  as  salaries,  working  hours  and  career 
advancement of people with disabilities  

Promote labour market relevant training to people with disabilities 

Foster possibilities of self-employment opportunities for people with disabilities 

Fight  prevailing  disability  benefit  cultures  and  help  to  integrate  persons  with  partial  work 
capacity into the labour market, further develop ALMPs and tackle benefit traps 

Examine national ALMPs and publish good practices 

F 

F 

F 

F 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with Education and training 

The  education  and  training  area  of  action  aimed  to  promote  inclusive  education  and  lifelong 
learning for students and pupils with disabilities. Equal access to quality education and lifelong 
learning enable disabled people to participate fully in society and improve their quality of life. 
The implementation status of EU level actions is outlined in the table below. 

Table 8: implementation of actions in the area of education and training 

Increase knowledge on education levels and opportunities of people with disabilities 

Promote  peer  reviews  on  the  different  definitions  at  Member  State  level  of  inclusive 
education  through  the  support  of  the  Network  of  Experts  on  the  Social  Sciences  of 
Education and Training (NESSE) 

Support the work of the European Agency for Development in Special Needs Education to 
facilitate  the  collection,  processing  and  transfer  of  European  level  and  country  specific 
information on education of people with disabilities 

Collect  data  on  access  and  participation  of  persons  with  high  dependency  needs  in  the 
education system 

Improve e-skills of persons with disabilities 

P 

P 

P 

F 

Support  policy  developments  towards  the  goal  of  inclusive  and  quality  education  and 
training within the framework of the Youth on the move initiative 

Promote  the  exchange  of  good  practice  on  inclusive  education  and  lifelong  learning  for 
students  and  pupils  with  disabilities  within  the  strategic  framework  for  European 
cooperation in education and training ET 2020 

F 

Raise disability matters in the context of the OMC on education, with due attention to the  P 

86 

 
 
 
 
 
 
 
specific needs of women and men with disabilities 

Disseminate  research,  information,  and  guidance  materials  on  the  application  of  the 
reasonable accommodation principle in education and training 

P 

Monitor  recent  developments  regarding  national  and/or  Europe-wide  Curricula  for 
professionals in the built environment, transport and ICT on Design for all to improve their 
knowledge,  skills  and  competences  on  accessibility  and  encourage  the  development  of  a 
European Curriculum 

N 

Increase the mobility of people with disabilities through enhancing their participation in 
the Lifelong Learning Programme and the Youth in Action Programme 

Ensure  that  relevant  calls  for  proposals  under  the  Lifelong  Learning  programme  include 
accessibility and reasonable accommodation criteria 

Maintain  the  priority  given  to  young  people  with  fewer  opportunities  (including  young 
people with disabilities) in the implementation of the Youth in Action Programme 

F 

F 

Promote life long learning of people with disabilities working in the police or justice systems  P 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with Social protection  

The social protection area of action aimed to promote decent living conditions, combat poverty, 
and  social  exclusion.  The  implementation  status  of  EU  level  actions  is  outlined  in  the  table 
below. 

Table 9: implementation of actions in the area of social protection 

Optimise the use of the European Platform against Poverty and the ESF 

Promote cooperation, peer review and good practice exchange on disability issues, with due 
attention to gender differences 

Promote the design and implementation of social innovation programmes for persons with 
disabilities 

Reduce social exclusion by targeted support of concrete actions through the ESF under the 
framework of the European Platform against poverty 

Assess the adequacy of social protection systems with respect to people with disabilities 

Ensure  that  disability-specific  issues  are  covered  in  any  revisions  of  legislation  concerning 
pensions and benefits portability 

Follow  up  the  Green  Paper  on  pensions  to  take  into  account  disability-relevant  aspects, 
organise exchange of good practices among MS 

P 

F 

F 

P 

F 

87 

 
 
 
 
 
 
Encourage  Member  States  to  address  in  the  SPSI  the  situation  of  persons  with  disabilities 
and to take measures to compensate the financial impact of disabilities 

F 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with Health  

The  health  area  of  action  aimed  to  promote  equal  access  to  health  services  and  related 
facilities. The implementation status of EU level actions is outlined in the table below 

Table 10: implementation of actions in the area of health 

Support policy developments to improve equal access to healthcare 

Develop  indicators  to  monitor  quality  and  accessibility  of  health  care  services  for  women 
and men with disabilities involving the service users’ perspective 

Promote  equal  access  to  health  care  systems  and  raise  awareness  among  persons  with 
disabilities of their rights of access 

Raise disability awareness and specific knowledge among health professionals, considering 
the specific needs of female and male patients 

Support  policy  developments  to  improve  quality  of  healthcare  and  rehabilitation  for 
people with disabilities 

Explore the possibility of including disability information in the e-health medical records and 
ensure their accessibility for persons with disabilities 

Develop accessibility standards for medical equipment 

Support  research  on  healthcare  provision  to  women  and  men  with  disabilities  through 
health work programmes in FP7 and FP8 

Exploit  the  potential  of  new  telemedicine  services  such  as  online  medical  consultations, 
improved emergency, care and portable devices for persons with disabilities 

Promote  modern  mental  health  services  and  long-term  care  facilities  through  the  current 
European Pact for Mental Health and Well-being 

Promote training of health professionals on disability matters through the ESF 

Promote  actions  in  the  field  of  health  and  safety  at  work  to  reduce  risks  of  disability 
during working life 

Examine  follow  up  of  the  specific  action  taken  by  Member  States  to  improve  the 
rehabilitation and reintegration of workers excluded from the workplace for a long period of 
time because of an accident at work, an occupational illness or a disability in the mid-term 
review of the EU Strategy on Health and Safety at Work 2007-2012 

P 

P 

P 

F 

P 

F 

F 

F 

N 

F 

88 

 
 
 
 
 
 
Report  on  the  implementation  of  the  European  social  partners'  framework  agreement  on 
work-related stress 

Explore the possibility to address the needs of people acquiring a disability while working at 
sea, particularly in the context of the revision of financial instruments 

Address the issue of prevention of disabilities including work related disabilities for reasons 
of mental disabilities 

F 

F 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

EU level actions associated with External Action 

The external action area of action aimed to promote the rights of people with disabilities in the 
EU enlargement and international development programmes. The implementation status of EU 
level actions is outlined in the table below 

Table 11: implementation of actions in the area of external action 

Promote  the  rights  of  people  with  disabilities  within  a  broader  non-discriminatory 
including  the  enlargement  process  and 
approach 
development programmes, taking due account of the common EU and Member States' 
approach to development 

in  the  EU  external  action, 

Ensure that the specific needs of persons with disabilities, including those who are 
disabled as a consequence of natural and man-made disasters, are properly assessed and 
addressed in the area of emergency and humanitarian aid outside the EU 

Highlight disability where appropriate as a human rights issue in the EU human rights 
dialogues with third countries, based on the principles of the CRPD 

Ensure that EU development cooperation reaches persons with disabilities, both through 
projects/programmes specifically targeting persons with disabilities and by improving the 
mainstreaming of disability concerns 

Enhance coherence and complementarity between the EU approach to persons with 
disabilities and EU assistance to survivors of landmine and explosive remnants of war 
during armed conflict and its aftermath 

Support the national efforts of partner countries for the signature, ratification and 
implementation of the CRPD 

Support where appropriate the institutional strengthening of Disabled Peoples' 
Organisations in partner countries and organisations dealing with disability and 
development 

Consolidate the network of disability focal points in EU Delegations and at Headquarters, 
and increase the awareness of EU staff on 

P 

F 

P 

P 

P 

P 

P 

89 

 
 
 
 
disability matters 

Promote that infrastructure financed in the framework of EU development projects 
meets the accessibility requirements of people 
with disabilities. 

Update the Guidance Note on Disability and Development to be in line with the UN 
Convention on the Rights of Person with Disabilities 

Ensure that progress is made by candidate and potential candidate countries on 
promoting the rights of persons with disabilities and that 
accession funds are used to improve their situation 

Encourage European Neighbourhood Policy partner countries to protect the rights of 
persons with disabilities; mainstream disability-related issues through policy dialogue and 
exchange of experience; and explore possibilities for financial assistance under the 
European Neighbourhood Policy and Partnership Instrument 

P 

F 

P 

P 

Key: 

F 

Fully Implemented 

P 

Partially implemented 

N 

Not implemented 

Source: ICF analysis 

90 

 
 
 
 
ANNEX 6: EVALUATION QUESTIONS 

Effectiveness 

-  To what extent have the objectives set out in the Strategy been achieved overall 

and for each main area of action and for the implementation instruments? 

-  To  what  extent  have  the  actions  defined  under  the  EU  Disability  Strategy  been 
implemented at the EU level for each main area of action and the implementation 
instruments? 

-  To what extent did the EU Disability Strategy mainstream disability issues in EU 

policy and legislation? 

-  To what extent did the EU Disability Strategy contribute to the implementation of 
the  UN  Convention  and  in  setting  up  governance  frameworks  both  at  EU  level 
and within the EU institutions (mechanisms under article 33 of the CRPD)? 

-  What have been success factors in implementing the EU Strategy? Why? 

-  What  have  been  possible  gaps  or  challenges  that  have  hindered  achievement  of 

objectives? 

-  To  what  extent  have  stakeholders  been  actively  engaged  in  the  strategy’s 

implementation and how have they been affected? 

Efficiency 

-  To what extent has the EU Disability Strategy been cost effective? 

-  To what extent were the resources (and especially EU funding and national match 
funding) across the areas of action at the EU level adequate and proportionate? 

Relevance 

-  To  what  extent  have  the  EU  Disability  Strategy  policy  process  and  objectives 
been  instrumental  –  and  continue  to  be  relevant  considering  evolving  policy 
context  (in  view  of  the  CRPD,  European  Pillar  of  Social  Rights  and  European 
Semester) in addressing the needs of persons with disabilities? 

-  To  what  extent  is  the  EU  Disability  Strategy  (still)  relevant  for  its  different 

stakeholders, including European citizens in general? 

Coherence 

-  To  what  extent  is  the  EU  Disability  Strategy  coherent  internally,  i.e.  how  do 
selected  thematic  areas  and  implementation  instruments  of  the  Strategy  work 
together? 

-  To  what  extent  is  the  EU  Disability  Strategy  coherent  with  the  EU  policies/ 
actions, notably Europe 2020, the European Pillar of Social Rights, the European 
Semester, the Charter of Fundamental Rights of the European Union and the EU 

91 

 
  
 
 
 
 
 
 
 
 
funding  provisions?  To  what  extent  was  disability  mainstreamed  in  those 
policies/actions? 

-  To what extent is the EU Disability Strategy coherent with the CRPD? 

-  To  what  extent  have  the  EU  level  actions  for  each  area  been  coherent  with  the 

related policy measures in Member States? 

Added value 

-  What  is  the  added  value  of  the  EU  strategy  in  eliminating  barriers  for  persons 
with  disabilities  and  in  implementing  the  CRPD  compared  to  what  is  likely  to 
have been achieved both at the EU level (including by institutions) and MS levels 
in its absence?  

92 

 
 
 
 
 
ANNEX 7: LISTS OF FIGURES AND TABLES 

Figures included in the main document 

Figure 1: Implementation of the Strategy overall 

Figures 2.1 and 2.2: Implementation by thematic area (number and percentage) 

Figures  3.1  and  3.2:  Implementation  by  implementation  instrument  (number  and 
percentage) 

Figure 4: Relevance of the current areas of action for future disability strategy 

Figure 5:  Alignment  between  national  priority measures and the areas of  action  of  the 
Strategy 

Figure  6:  Extent  to  which  the  Strategy  has  delivered  added  value  in  implementing  the 
UNCRPD 

Figure 7: Role of EU initiatives in improving the situation of persons with disabilities in 
the last ten years 

Tables included in the main document 

Table  1:  Views  on  whether  the  situation  for  persons  with  disabilities  improved  in  the 
Member States over the last ten years 

Table 2: Familiarity with the Strategy in the Member States 

Table  3: Examples  of Member State policies  and comparison with the objectives of  the 
Strategy 

Figures included in the annexes 

Figure 1: Consultation methods and their target groups 

Figure 2: Public consultation – respondents per country of origin 

Figure 3: Public consultation – important topics identified by respondents 

Tables included in the annexes 

Table 1: Public consultation - effectiveness results for the different areas of the Strategy 

Table 2: EU-level stakeholders interviewed 

Table 3: Judgement criteria about the implementation of the actions 

Table 4: implementation of actions in the area of accessibility 

Table 5: implementation of actions in the area of participation 

93 

 
 
 
 
Table 6: implementation of actions in the area of equality 

Table 7: implementation of actions in the area of employment 

Table 8: implementation of actions in the area of education and training 

Table 9: implementation of actions in the area of social protection 

Table 10: implementation of actions in the area of health 

Table 11: implementation of actions in the area of external action 

94