Study on the EU Regulatory Framework for Passenger Rights . Part A, Evaluation of Regulation (EC) No 1107/2006 on the rights of persons with disabilities and with reduced mobility when travelling by air : stakeholder consultation report.
Date: 2021-09-21
Institutions: Directorate-General for Mobility and Transport
Subjects: EU Member State, European Economic Area, United Kingdom, air transport, anti-discriminatory measure, bus, carriage of passengers, carrier, consumer information, consumer protection, contract of carriage, disabled person, facilities for people with disabilities, ground handling, indemnification, inland waterway transport, maritime transport, passenger rights, public transport, rail transport, regulation (EU), road transport, transport regulations, transport safety, traveller

Study on the EU Framework 
for Passenger Rights 

Part A - Evaluation of Regulation (EC) No 1107/2006 on 
the rights of persons with disabilities and with reduced 
mobility when travelling by air 

Written by Steer 
June – 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Mobility and Transport 

Directorate B - Investment, innovative & sustainable transport 

Unit B.5 - Social aspects, passenger rights & equal opportunities 

Contact: move-pr-evaluation-studies@ec.europa.eu 

European Commission 

B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Evaluation of Regulation (EC) 
No 1107/2006 on the rights of 
persons with disabilities and 
with reduced mobility when 
travelling by air 

Stakeholder Consultation Report 

Directorate-General for Mobility and Transport 
Specific Contract n° MOVE/B5/2019 - 279 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Stakeholder Consultation Report 
February 2021 

Study on the EU framework for 
passenger rights                               
PART A - Evaluation of 
Regulation (EC) No 1107/2006 
on the rights of persons with 
disabilities and with reduced 
mobility when travelling by air 

DG MOVE, European Commission 
Our ref: 23772601 
Client ref: MOVE B5/2019 - 279 

 
 
 
 
 
 
 
 
 
Stakeholder Consultation Report 
February 2021 

Study on the EU framework for 
passenger rights                               
PART A - Evaluation of Regulation (EC) 
No 1107/2006 on the rights of 
persons with disabilities and with 
reduced mobility when travelling by 
air 

Prepared by: 

Prepared for: 

Steer 
28-32 Upper Ground 
London SE1 9PD 

+44 20 7910 5000 
www.steergroup.com 

DG MOVE, European Commission 
Directorate E – Aviation  
Avenue du Bourget 1 
1140 Brussels (Evere) 
Belgium 
Client ref:  MOVE B5/2019 - 279 
Our ref:  23772601 

Steer has prepared this material for DG MOVE, European Commission. This material may only be used within the 
context and scope for which Steer has prepared it and may not be relied upon in part or whole by any third party 
or be used for any other purpose. Any person choosing to use any part of this material without the express and 
written permission of Steer shall be deemed to confirm their agreement to indemnify Steer for all loss or damage 
resulting therefrom. Steer has prepared this material using professional practices and procedures using 
information available to it at the time and as such any new information could alter the validity of the results and 
conclusions made. 

 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Contents 

1 

Introduction .............................................................................................................. 1 

Overview ............................................................................................................................. 1 

2 

Methodology of the consultation .............................................................................. 2 

Approach to targeted stakeholder engagement ................................................................ 2 

3 

Results of the consultation .............................................. Error! Bookmark not defined. 

Results of the targeted consultation .................................... Error! Bookmark not defined. 

Open Public Consultation results ..................................................................................... 33 

Figures 

Figure 2.1: Stakeholder engagement strategy ............................................................................. 3 

Figure 2.2: Stakeholder management framework ........................................................................ 4 

Figure 2.3: Number of questionnaires received ........................................................................... 8 

Figure 2.4: Breakdown of OPC respondents: Country of origin ................................................. 20 

Figure 2.5: Breakdown of OPC respondents: organisation type ................................................ 21 

Figure 2.6: Breakdown of OPC respondents: organisation size.................................................. 21 

Tables 

Table 2.1: Stakeholder methods, approach and target audience ................................................ 2 

Table 2.2: Stakeholder consultation timeline ............................................................................... 4 

Table 2.3: NEB stakeholder engagement ..................................................................................... 9 

Table 2.4: Airline stakeholder engagement (industry associations and representatives in grey)
 .................................................................................................................................................... 10 

Table 2.5: Airline stakeholder engagement (industry associations and representatives in grey)
 .................................................................................................................................................... 11 

Table 2.6: Passenger/PRM representative organisation stakeholder engagement ................... 13 

Table 2.7: European Consumer Centre stakeholder engagement ............................................. 14 

Table 2.8: ADR stakeholder engagement ................................................................................... 15 

Table 2.9: ‘Other’ stakeholder engagement ............................................................................... 16 

Table 2.10: Pilot interviews ........................................................................................................ 17 

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Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Table 2.11: Stakeholder consultation interviews ....................................................................... 17 

Table 2.12: Workshop attendees................................................................................................ 18 

Table 2.13: OPC responses received ........................................................................................... 19 

Table 2.14: Written contributions received through the Open Public Consultation ................. 22 

Table 3.1: Areas of agreement across stakeholder groups ........................................................ 32 

Table 3.2: Areas of disagreement across stakeholder groups .................................................... 33 

Appendices 

A 

B 

C 

Analytical results of the OPC 

GDPR notice 

Targeted questionnaires   

D  Workshop agenda 

E 

Workshop summary 

37 

73 

79 

112 

114 

February 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

1 

1.1 

Introduction 
Overview 

This report presents an overview and analysis of the consultation activities that were 
conducted by Steer in the course of the evaluation of Regulation (EC) No. 1107/2006 
(henceforth, ‘the Regulation’) on the rights of persons with disabilities and reduced mobility 
when travelling by air.  

Scope of the engagement with stakeholders 

1.2 

The engagement with stakeholders was designed to be focussed on the following scope: 

  Geographic scope: The 27 EU Member States were targeted as well as 4 non-EU countries 

 

(United Kingdom, Switzerland, Iceland and Norway). 
Technical scope: the work was focussed on the relevance, effectiveness, efficiency, 
coherence, and EU-added value of the Regulation. 

Objectives of the engagement with stakeholders 

1.3 

In order to gain an understanding of the issues that have arisen since the implementation of 
the Regulation, in agreement with the European Commission we defined a programme of field 
research that was conducive to the following objectives: 

 

Ensure a process which provides the opportunity for stakeholders to provide information 
and data that contributed to the findings of the study;   

  Collect stakeholder views on the outcomes, results and impact of the Regulation; 
  Collect data from stakeholders to ensure cross-referencing of information and address 

any information gaps identified;  

  Discuss issues arising with the application of the Regulation and any possible 
shortcomings, redundancies, overlaps, inefficiencies or inconsistencies; 

  Obtain information in order to answer the evaluation questions from the Terms of 

Reference; and 

  Collect stakeholder views on whether the Regulation is still fit for purpose and any 

suggested good practices or amendments.  

1.4 

This report is organised as follows: 

  Chapter 2 on the methodology used for the targeted stakeholder consultation; and 
  Chapter 3 on results of the stakeholder engagement. 

1.5 

Appendix A presents the analytical results from the Open Public Consultation (OPC).  

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Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

2  Methodology of the consultation 

Approach and strategy 

Choice of engagement methods 

2.1 

In order for the consultation process to be as effective as possible, different channels to 
engage with stakeholders were used: 

Table 2.1: Stakeholder methods, approach and target audience 

Method 

Pilot interviews 

Approach 

Telephone meetings 

Targeted interviews 

Face to face and telephone interview 
with at least 26 participants 

Targeted questionnaires to 
industry  

Issuing of questionnaires for each key 
stakeholder groups 

Target audience and purpose 

4 key stakeholders to help shape 
the methodology of the work 
programme  

Key industry stakeholders’, 
national enforcement bodies 
(NEBs) and passenger 
representatives’ views and 
provision of data and documents 

Key industry stakeholders’, 
national enforcement bodies 
(NEBs) and passenger 
representatives’ views and 
provision of data and documents 

Open Public Consultation 

Data collected by Commission and 
analysed by Consultant 

General public 

Stakeholder workshop 

Online workshop organised and led by 
Consultant with Commission and 
industry stakeholders 

Key industry stakeholders’, 
national enforcement bodies 
(NEBs) and passenger 
representatives’ views on 
implementation, enforcement and 
good practices 

2.2 

The figure below shows how we engaged with each group of stakeholders identified in order 
to maximise the benefits of the field research for the study.  

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Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Figure 2.1: Stakeholder engagement strategy 

Source: Steer 

2.3 

With reference to Figure 2.1 above: 

 

Selected stakeholders (including from all relevant stakeholder groups and chosen in 
collaboration with the Commission) were invited to complete a targeted questionnaire 
and to attend an interview and the stakeholder workshop with the project team. 
–  We examined questionnaire responses as soon as they were received. 
– 

Selected stakeholders were then invited to interview, allowing the project team to 
focus the interview on points of most relevance to the stakeholder concerned. 

  Other stakeholders were invited to complete a targeted questionnaire.  

–  We examined questionnaire responses as soon as they were received.  
–  Based on this analysis, we invited some additional stakeholders to have a targeted 

interview, where we thought their contribution would enhance the study. 
  Other stakeholders (e.g. the general public) who would not otherwise be consulted via a 
representative organisation were able to express their views through the Open Public 
Consultation.  

2.4 

‘Selected stakeholders’ were chosen in collaboration with the Commission as to ensure the 
diversity (geographic, sectoral, etc.) and representativeness of the stakeholders interviewed. 
The quality of a stakeholders’ questionnaire response, or the uniqueness of any views 
expressed therein, also contributed towards whether they were selected for interview. 

2.5 

In addition, we considered the following on a case-by-case basis: 

  Offering stakeholders who were unwilling to complete a questionnaire the possibility to 
complete an interview instead (this occurred for IAG and Lufthansa Group, although IAG 
were unavailable for interview); and 

  Where agreeing times for an interview proved difficult, some meetings were arranged 

before the submission of a questionnaire response.  

Communication with stakeholders 

2.6 

One member of the project team managed the stakeholder communication, under the close 
supervision of the Project Manager. They managed all communications from Steer with 
stakeholders and completed a daily log to track the progress of the consultation with each of 
the 245 stakeholders consulted. This enabled the team to, inter alia, keep track of 
questionnaires sent and received, and interviews requested, agreed, scheduled and 

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completed. This was reviewed each week, with follow-up emails/calls made to progress the 
interview programme as required. A small number of the most important stakeholders were 
directly engaged by the Project Manager. This included but was not limited to the 
International Air Transport Association (IATA), Airlines for Europe (A4E), Airports Council 
International (ACI) Europe and European Disability Forum (EDF). 

2.7 

We ensured that all stakeholders consulted were aware of how to contact the project team – 
contact details of the consultation lead (email and telephone number) were provided in all 
correspondence and provided at the top of each questionnaire. 

Figure 2.2: Stakeholder management framework 

Source: Steer 

Engagement timeline 

2.8 

The stakeholder consultation timeline is illustrated in Error! Reference source not 
found.Error! Reference source not found. below.  

Questionnaires were distributed to 245 stakeholders between 28 May and 10 June with an 
initial due date of 24 July for National Enforcement Bodies (NEBs) and 7 August for all other 
stakeholders. Some extensions were granted on a case by case basis (to 15 September for 
IATA and A4E due to the impacts of COVID-19). In parallel, selected stakeholders were 
contacted to arrange an interview. A workshop was then conducted with selected 
stakeholders on 10 November. 

Table 2.2: Stakeholder consultation timeline 

Mar-
20 

Apr-
20 

May-
20 

Jun-20 

Jul-20 

Aug-
20 

Sep-
20 

Oct-
20 

Nov-
20 

Dec-
20 

Piloting 

Introductory 
emails sent 
Questionnaires 
distributed 
Questionnaires 
received 

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Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Bilateral 
interviews 
Workshop 

Steer analysis 

2.9 

2.10 

2.11 

2.12 

2.13 

2.14 

Following the release of questionnaires to stakeholders, stakeholders were initially assigned a 
response deadline of 10 weeks. NEBs were initially given 8 weeks. Nevertheless, more time 
was issued to stakeholders when requested as to encourage participation, particularly in light 
of COVID-19 (see below).  

Initially, stakeholders were approached with an introductory e-mail which explained the 
objectives and the timeline of the study, with the Commission’s Letter of Introduction 
attached. This e-mail sought to: 

Provide them with the necessary background to the study; 

 
  Determine whether the point of contact was the correct one for the organisation and to 

direct us to one if this were not the case; 

  Confirm the organisation’s willingness to participate; and  
  Notify them of the deadline for receiving their questionnaire response.  

Questionnaires were also released to all stakeholders alongside a copy of the Commission’s 
GDPR privacy notice (see Annex B). For all stakeholders, we followed-up on multiple occasions 
via e-mail and telephone before the deadline to ensure that the questionnaire had not been 
forgotten or that no issues had arisen. On receiving each questionnaire, we confirmed receipt 
with and also thanked stakeholders for their contributions.  

Confidentiality 

To ensure that confidentiality of responses was observed all stakeholders were requested to 
highlight issues they wished to remain confidential in their questionnaire responses. In face to 
face meetings the issue of confidentiality was also raised at the beginning of the meeting so 
that stakeholders knew to highlight whether particular points were confidential or not.  

GDPR 

A GDPR notice (see Annex B) was circulated to stakeholders alongside the questionnaire. This 
notice was agreed with the Commission before being circulated.  

Impact of COVID-19  

As a result of the disruption associated with COVID-19, in many cases, stakeholders - notably 
airlines, airports and NEBs - found it difficult to allocate the resources required to return 
responses in a timely fashion. This was primarily due to: 

 

  Headcount and working-time reductions: in many cases our original contacts were either 
not reachable, or they had taken on other responsibilities, reducing their capacity to take 
part in the consultation process; 
Increased remote working: lack of access to work phone numbers and, for smaller 
organisations (e.g. some passenger representatives and some NEBs), switchboards and 
central receptions were occasionally unoccupied, complicating follow-up efforts; and 
Shifting stakeholder priorities: for example, some airlines (e.g. Finnair and Icelandair), and 
airports (e.g. London City and Helsinki) withdrew their consent to participate.  

 

February 2021 | 5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.15 

Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Steer made concerted efforts to adapt the consultation to the everchanging situation as to 
ensure high levels of engagement, such as by remaining in frequent contact and encouraging 
participation before deadlines. We offered significant flexibility to stakeholders from whom 
we were expecting a response, extending deadlines from late July through to early November 
on a case by case basis. Notably, following discussions with A4E, IATA and the Commission the 
deadline for IATA and A4E members was extended from 7th August 2020 to 15th September 
2020. We continued to contact stakeholders after deadlines had lapsed which enabled us to 
collect additional responses. Furthermore, we liaised closely with IATA and A4E especially, 
who were able to update us on how their members were coping with the pandemic, and if 
IATA and A4E expected members to have the capacity to respond. We successfully secured 
input from Lufthansa Group in this critical period by offering to record their views in an 
interview in lieu of a questionnaire response. Similarly, ACI were also particularly informative 
when approached directly by the project manager. Finally, in situations where staff were 
furloughed or no longer reachable, where possible we attempted to reach out to alternate 
contacts. Overall, the success of this approach is evidenced by the near-total lack of expected 
responses which are still outstanding.  

Engagement methods 

Questionnaires 

2.16 

The targeted stakeholder questionnaires (see Annex C) were designed to obtain detailed and 
precise views from the industry, as well as data and policy views. Each questionnaire consisted 
of a large number of questions which covered a wide range of topics within each evaluation 
question. In light of this, we created an accessible version of the questionnaires using 
Microsoft Forms.1 One PRM representative organisation requested this. In one other case, we 
translated the questionnaire into Spanish by a native speaker. Stakeholders were encouraged 
to contact us should they have any questions on the questionnaire. Support was available in 
English, French, German, Greek, Polish and Spanish. 

Scoping of objectives 

2.17 

Questionnaires and interviews were necessary for the following tasks: 

  Analysis of the evaluation baseline;  
  Development of the case studies;  
  Development of the country-fiches;  
  Conclusions on the overall assessment and answering of the evaluation questions. 

2.18 

We used a number of distinct questionnaires tailored to each key stakeholder group. Seven 
sets of questionnaires were developed aimed at addressing the following evaluation topics: 
relevance, effectiveness, cost efficiency, coherence and, EU added value. One questionnaire 
was designed for each of the following: NEBs, airports, EU airlines, non-EU airlines, passenger 
and PRM representatives, ADRs and ECCs, and ‘other’ stakeholders outside of the 
aforementioned groups. 

1 The accessible questionnaire can be viewed using the following link: 
https://forms.office.com/Pages/ResponsePage.aspx?id=MuTqwdHEtEGZjN4S1J95EwykD33bywVPtDYA_
XQg5btUQlNPSDlaTUE4SkJSUUFBTEpUWk5OQzhBMS4u 

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rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Identified limitations 

2.19 

It was recognised that the questionnaires were lengthy and would be time consuming for 
stakeholders to complete comprehensively. Therefore, stakeholders’ interest in the Regulation 
would dictate the level and quality to which they were completed. For some stakeholders 
(particularly consumer groups), the air travel market is only a small subset of their 
organisation and thus their exposure to and knowledge of the Regulation was insubstantial.  

Interviews 

2.20 

A total of 26 interviews, ranging from 1 to 1.5 hours in length each, were conducted with 
selected stakeholders:  

 
 
 

Two pilot interviews were carried out during the project inception; 
20 interviews were conducted as part of the evaluation of Regulation 1107/2006; and 
Four additional interviews were conducted where other passenger rights Regulations 
were also discussed (181/2011 on the rights of passengers travelling by bus and coach, 
and/or 1177/2010 on the rights of passengers travelling by sea and inland waterways) as 
stakeholders had relevant expertise across all three evaluation areas.  

Candidates for interviews were selected to ensure representativeness and diversity of the 
sample, in collaboration with the Commission.  

No specific interview guides were developed as Steer relied on the questionnaires to provide 
guidance for the interviews. Where the interviewee requested to see the questions in advance 
of the interview, Steer prepared ad-hoc question lists reflecting the written questionnaire sent 
back (if relevant) and/or specific questions tailored for the organisation to be interviewed. 

2.21 

2.22 

2.23 

The pilot interviews led to minor changes to the draft questionnaires.  

Workshop 

A full-day participatory workshop with selected stakeholders was conducted on 10 November 
2020 to collect views from attendees on issues pertinent to the evaluation. The discussion was 
centred around three themes: 1) pre-notification, 2) safety, and 3) ensuring the Regulation 
remains fit for purpose. These are described in greater detail in the agenda note which was 
circulated to stakeholders in advance (see Annex D). The workshop was led and organised by 
Steer, with the European Commission also in attendance. In total, 28 organisations attended 
the workshop (see p.18).  

Stakeholders were subdivided into three groups, each moderated by a member of the Steer 
project team and supervised by a member of the European Commission. This allowed each 
theme to be discussed by each group individually for approximately 45 minutes before each 
group subsequently fed back to all participants in a 15-minute plenary session. Each 
moderator was briefed extensively in advance by the project manager through briefing notes 
and bilateral discussions to ensure all moderators had a detailed understanding of the key 
issues and stakeholders’ expected positions.  

The workshop was conducted entirely virtually via a Zoom teleconference. To mitigate the 
risks of this novel approach, a practice run was conducted with the Commission in advance to 
identify and resolve potential challenges. A dedicated member of the project team was also 
assigned to manage the technical aspects of the workshop and respond immediately to any 
technical challenges which may arise. The success of the approach taken by the project team is 
reflected by the feedback received by stakeholders upon conclusion of the workshop. 

2.24 

2.25 

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Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Open Public Consultation 

2.26 

The Commission launched a public consultation for the evaluation of the Regulation and the 
collection of good practices. The objective of this was to collect the views of the general public 
and the stakeholders. The OPC opened on 3 July 2020 and closed on 23 October 2020. 

Level of engagement 

Targeted stakeholder consultation 

2.27 

2.28 

The figure below presents an overview of the number of stakeholder responses received for 
this study. 107 responses were received in total. Individual stakeholder groups are discussed in 
more detail in the corresponding sections below. 

Selected stakeholders within the targeted consultation were chosen in close collaboration 
with the Commission to ensure the desired diversity (geographic, sectoral, etc.). In this study, 
this diversity was maintained within the majority of stakeholder groups, but as stakeholders 
are only invited to participate, and not requested to do so, the outcome is not always as 
balanced as desired. With this in mind, meaningful engagement with the trade associations is 
always a priority as they can share the views of their members in all their diversity. Further 
details on representation within stakeholder groups can be found below. 

Figure 2.3: Number of questionnaires received 

Source: Steer analysis 

Questionnaires 

National Enforcement Bodies 

2.29 

Overall, most countries surveyed (29/31) submitted some form of response. Of the two 
countries (LU, SI) to not respond, Luxembourg stated that they lacked the resources required 
to respond, whilst Slovenia did not respond due to a lack of experience with the Regulation. 

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Table 2.3: NEB stakeholder engagement 

MS 

Organisation 

SPF Mobilité & Transport 

Bulgarian CAA  

Czech CAA 

Danish Transport Authority  

German CAA (LBA) 

Status  

Response received 

Response received 

Response received 

Response received 

Response received 

Consumer Protection and Technical Regulatory Authority 

Response received 

Commission for Aviation Regulation 

Hellenic CAA 

Spanish CAA (AESA) 

French CAA (DGAC) 

Croatian CAA 

Italian CAA (ENAC) 

Department of Civil Aviation 

Latvian CAA 

Lithuanian Transport Safety Administration 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Luxembourgish Civil Aviation Directorate 

Declined to participate 

Equal Treatment Authority 

Response received 

Malta Competition and Consumer Affairs Authority 

Response received 

Transport and Environment Inspectorate (ILT) 

Passenger Rights Agency (APF_ 

Polish CAA 

Portuguese CAA (ANAC) 

National Authority for People with Disabilities 

Slovenian CAA 

Slovak Trade Inspectorate 

Slovak Ministry of Transport 

Finnish Transport Safety Agency (Traficom)  

Swedish Transport Agency 

Swedish Consumer Agency 

National Board for Consumer Disputes 

UK CAA  

Icelandic Transport Authority 

Norwegian CAA 

Federal Office of Civil Aviation FOCA 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

No engagement 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

SK 

FI 

SE 

SE 

SE 

UK 

IS 

NO 

CH 

Airlines 

2.30 

It was far more challenging to engage airlines in the stakeholder consultation process due to 
the effects of COVID-19 throughout the consultation. In total, 17 responses were successfully 
collected from this group from a mix of low cost and flag carrier airlines. These are detailed in 

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the table below, greyed rows represent associations. We worked closely with A4E and IATA to 
encourage participation and mitigated other challenges as described on paragraph 2.15.  

Table 2.4: Airline stakeholder engagement (industry associations and representatives in grey) 

MS 

N/A 

N/A 

N/A 

N/A 

NL 

CH 

UK 

Organisation 

Airlines for Europe (A4E) 

Airlines International 
Representation in Europe (AIRE) 

International Air Transport 
Association (IATA) 

European Regions Airline 
Association (ERAA) 

KLM 

Swiss 

easyJet 

N/A 

Air Serbia 

ES 

HU 

LV 

DE 

NO 

PT 

Binter 

Wizzair 

Air Baltic 

TUI 

Wideroe 

Azores Airlines 

UK/ES 

IAG 

TU 

N/A 

N/A 

PT 

FI 

IS 

NO 

RO 

DE 

ES 

FR 

IE 

UK 

BG 

DE 

EL 

IT 

PL 

RO 

Corendon 

WestJet 

United 

EuroAtlantic Airways 

Finnair 

Icelandair 

Norwegian 

BlueAir 

Lufthansa 

Albastar 

Air France 

Ryanair 

Jet2 

Bulgaria Air 

Condor 

Aegean 

Alitalia 

LOT 

TAROM 

Status  

Response received 

Response received 

Response received 

Questionnaires received from members only. 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

No engagement 

Declined to participate due to impact of COVID-19. 

Declined to participate due to impact of COVID-19. 

Declined to participate due to impact of COVID-19. 

Declined to participate due to impact of COVID-19. 

Interview only 

Interview only 

Response received 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

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Organisation 

Air Europa 

Air Malta 

Croatia Airlines 

TAP Air Portugal 

Loganair 

Luxair 

ASL Airlines 

Volotea 

Czech Airlines 

Wamos Air 

APG airlines 

Status  

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

Scandanavian Airlines Service (SAS) 

No engagement 

MS 

ES 

MT 

HR 

PT 

UK 

LU 

FR 

ES 

CZ 

ES 

FR 

DK 

Airports 

2.31 

It was as challenging to engage airport stakeholders, again due to the impacts of COVID-19.  
Nevertheless, we successfully secured 19 responses. We worked closely with ACI to encourage 
participation and mitigated other challenges as described on paragraph 2.15. 

Table 2.5: Airline stakeholder engagement (industry associations and representatives in grey) 

Organisation 

Status  

Airport Council International (ACI)-Europe 

Response received 

MS 

N/A 

CH 

CY 

CZ 

DE 

DK 

ES 

FR 

IE 

IE 

IS 

IT 

IT 

IT 

LT 

LV 

NL 

UK 

UK 

Zurich 

Larnaka 

Prague Airport 

Fraport 

Copenhagen Airports 

Aena  

Groupe ADP 

Dublin 

Shannon 

Keflavik International 

Fiumicino 

Verona 

Milan Malpensa 

Vilnius Airport 

Riga International 

Amsterdam Schiphol 

London Heathrow Airport 

Glasgow 

NO 

Avinor 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

No engagement 

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MS 

Organisation 

AT 

BE 

BE 

BG 

CH 

DE 

DE 

EE 

EL 

FR 

FR 

FR 

FR 

HR 

HU 

IT 

IT 

LU 

MT 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

UK 

UK 

UK 

UK 

EL 

DE 

EU 

UK 

UK 

FI 

Vienna International 

Brussels 

Brussels South Charleroi  

Sofia International 

Basel Mulhouse 

Dusseldorf 

Munich 

Tallinn 

Athens International 

Bordeaux-Mérignac  

Marseille-Provence  

SAGEB 

Cannes-Mandelieu  

Zagreb International  

Budapest 

Catania  

Venice 

Luxembourg International 

Malta International 

Warsaw Frederic Chopin 

ANA 

Bucharest Henri Coanda  

Swedavia 

Ljubljana 

Bratislava 

AGS Airports 

Manchester Airports Group (MAG) 

Newcastle International 

Wilson James 

ABM 

Thessaloniki 

Berlin-Brandenburg  

Airport Regions Council (ARC) 

London Gatwick Airport 

London City Airport 

Helsinki 

Status  

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

Declined to participate 

Declined to participate 

Declined to participate 

Declined to participate 

Declined due to impact of COVID-19 

Declined due to impact of COVID-19 

Passenger and PRM representatives 

2.32 

Of the 40 PRM and passenger representative organisations contacted as part of the 
consultation, we received 11 responses. We successfully engaged numerous pan-European 

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and national representative organisations from across Europe (FI, HU, IT, PT, ES). Of those not 
to respond, BEUC invited us to contact their members individually (which we did) and the EBU 
attended the stakeholder workshop in lieu of a written questionnaire response. 

Table 2.6: Passenger/PRM representative organisation stakeholder engagement  

MS 

N/A 

N/A 

N/A 

N/A 

Organisation 

Type 

Status 

European Passenger Federation (EPF) 

PRM representative  No response 

European Disability Forum (EDF) 

PRM representative  Response received 

AGE Platform 

PRM representative  Declined to participate 

The European Consumer Organisation 
(BEUC) 

Passenger 
representative 

Declined to participate 

N/A 

European Blind Union (EBU) 

PRM representative  Declined; attended 

workshop 

N/A 

N/A 

N/A 

FI 

HU 

HU 

IT 

IT 

PT 

PT 

European Union of the Deaf (EUD) 

PRM representative  Response received 

Inclusion Europe 

PRM representative  Declined to participate 

European Network of Independent Living 
(ENIL) 

PRM representative  Response received 

Finnish Disability Forum 

PRM representative  Response received 

Association of Persons with Mobility 
Restrictions in Hungary 

Association of Blind and Visually Impaired 
in Hungary 

PRM representative  Response received 

PRM representative  Response received 

Italian Disability Forum 

PRM representative  Response received 

ANGLAT 

PRM representative  Response received 

National Confederation of Disabled Bodies  PRM representative  Response received 

Portuguese Association for Consumer 
Protection (DECO) 

Passenger 
representative 

Response received 

EL 

National Confederation of Disabled People  PRM representative  No engagement  

N/A 

PassePartout 

PRM Consultant 

Response received 

DK 

EL 

ES 

BE 

DE 

EL 

EL 

FI 

FR 

Danish Disability Organisation 

PRM representative  Declined to participate 

Consumer Protection Centre (ΚΕΠΚΑ) 

Spanish Committee of Representatives of 
People with Disabilities (CERMI) 

Passenger 
representative 

Interview only 

PRM representative 

Interview only 

Belgian Disability Forum 

PRM representative  No engagement 

German Disability Council 

PRM representative  No engagement 

Greek National Confederation of Persons 
with Reduced Mobility (ESAMEA) 

PRM representative  No engagement 

AMEA 

PRM representative  No engagement 

Finnish Railway Passengers Association 
(SRM) 

Passenger 
representative 

No engagement 

French Council of People with Disabilities 
for European Issues (CFHE) 

PRM representative  No engagement 

HR 

Spinal Injuries Zagreb (SOZ) 

PRM representative  No engagement 

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MS 

HR 

HU 

LV 

NL 

PL 

PT 

RO 

SE 

UK 

UK 

UK 

IC 

N/A 

N/A 

Organisation 

Type 

Status 

Croatian Paraplegic and Tetraplegic 
Alliance (CPTA) 

Hungarian National Council of Federations 
of People with Disabilities (FESZT) 

Latvian Disability Cooperation 
organization 

Chronically Ill and Disabled Council of the 
Netherlands 

Polish Disability Forum 

Cerebral Palsy Association 

National Disability Council 

PRM representative  No engagement 

PRM representative  No engagement 

PRM representative  No engagement 

PRM representative  No engagement 

PRM representative  No engagement 

PRM representative  No engagement 

PRM representative  No engagement 

Swedish Disability Federation 

PRM representative  No engagement 

Air Transport Users Council 

PRM representative  No engagement 

UK Coalition for Disability Rights in Europe  PRM representative  No engagement 

easyTravelseat 

PRM Consultant 

No engagement 

Consumer Association of Iceland 

Passenger 
representative 

Response received 

Reduced Mobility Rights 

PRM Consultant 

No engagement 

Skywise Solutions 

PRM Consultant 

No engagement 

European Consumer Centres 

2.33 

We contacted European Consumer Centres in all countries (apart from Switzerland where 
there is no ECC). We successfully collected 14 responses. The Slovenian and Hungarian ECCs 
declined to participate invoking a lack of experience. The French ECC coordinated a joint 
response with the Belgian, Dutch and Finnish ECCs.  

Table 2.7: European Consumer Centre stakeholder engagement 

MS 

Organisation 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

LV 

ECC Belgium 

ECC Bulgaria 

ECC Czech Republic 

ECC Denmark 

ECC Germany 

ECC Estonia 

ECC Ireland 

ECC Greece 

ECC Spain 

ECC France 

ECC Croatia 

ECC Italy 

ECC Republic of Cyprus 

ECC Latvia 

Status 

Response received 

Response received 

Response received 

No engagement 

No engagement 

No engagement 

Response received 

No engagement 

No engagement 

Response received 

No engagement 

Response received 

Response received 

No engagement 

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MS 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

IS 

NO 

CH 

Organisation 

ECC Lithuania 

ECC Luxembourg 

ECC Hungary 

ECC Malta 

ECC Netherlands 

ECC Austria 

ECC Poland 

ECC Portugal 

ECC Romania 

ECC Slovenia 

ECC Slovakia 

ECC Finland 

ECC Sweden 

ECC United Kingdom 

ECC Iceland 

ECC Norway 

N/A 

Status 

Response received 

Response received 

Declined to participate 

Response received 

Response received 

No engagement 

No engagement 

Response received 

No engagement 

Declined to participate 

No engagement 

Response received 

No engagement 

Response received 

No engagement 

No engagement 

N/A 

Alternative Dispute Resolution organisations 

2.34 

In total, 32 ADRs were contacted regarding the Regulation, of which 15 provided a response. 
Of the 17 not to provide a response. Notably, 2 ADRs who responded were also NEBs. These 
organisations were sent both an NEB questionnaire and an ADR questionnaire – the latter 
focussed more on their role as a dispute resolution body. They responded to both 
questionnaires, and so are included in the table below. 

Table 2.8: ADR stakeholder engagement 

MS 

AT 

Organisation 

Agency for Passenger Rights 

DK 

The Danish Transport, Construction and Housing Authority a 

BE 

DE 

EE 

FI 

IE 

IS 

LT 

NL 

PT 

SE 

Consumer Mediation Service 

Söp 

Consumer Disputes Committee 

Consumer Disputes Board 

Net Neutrals 

The Ruling Committee in Travel Industry Matters 

State Consumer Rights Protection Authority 

Foundation for Consumer Complaints Committees 

CNIACC 

National Board for Consumer Disputes (ARN) 

Status 

Responded as NEB and 
ADR 

Responded as NEB and 
ADR 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

Response received 

February 2021 | 15 

 
MS 

SK 

UK 

NO 

BG 

CY 

CZ 

DE 

EL 

ES 

FR 

HR 

HU 

IT 

LU 

LV 

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Organisation 

Slovak Trade Inspection 

Centre for Effective Dispute Resolution (CEDR) 

Transportklagenemda Norsk Reiselivsforum 

Commission for Consumer Protection - Conciliation Committee 
for air transport disputes 

Status 

Response received 

Response received 

Response received 

No engagement 

Cyprus Consumer Center for Alternative Dispute Resolution 

No engagement 

Czech Trade Inspection Authority 

No engagement 

Aviation Conciliation Body at the Federal Office for Justice 

No engagement 

ADR Point 

National Consumer Arbitration Board (part of AESA) 

Médiation Tourisme et Voyage 

Mediation Centre at the Croatian Chamber of Economy 

Conciliatory body of Budapest 

RisolviOnline.com 

National Consumer Ombudsman Service 

Consumer Rights Protection Centre of Latvia 

MT 

Pardee Consulta 

Air Passenger Watchdog 

National Authority of Consumer Protection in Romania 

European Centre for Dispute Resolution (ECDR) 

Aviation ADR 

PL 

RO 

SI 

UK 

Others 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

No engagement 

2.35 

A small number of stakeholders did not fall under the aforementioned groups. ECTAA were 
contacted and responded to the questions they believed were relevant to them. ASA stated 
that due to COVID-19 they were unable to engage any of their members in the study. The only 
groundhandler we received a response from was OCS – their response related specifically to 
their operations at Glasgow airport. They also took part in an interview.  

Table 2.9: ‘Other’ stakeholder engagement 

MS 

N/A 

N/A 

N/A 

N/A 

UK 

N/A 

Country/organisation 

European Travel Agents and Tour Operators Association 
(ECTAA) 

Global Business Travel Association (GBTA) 

Airport Services Association (ATA) 

OCS (Groundhandler) 

Wilson James (Groundhandler) 

ABM (Groundhandler) 

Status  

Response received 

Declined to participate 

Declined to participate. 

Response received 

No engagement 

No engagement 

Pilot interviews 

2.36 

We undertook two pilot interviews during the inception phase with the aim of identifying the 
most important issues to cover during the stakeholder consultation and to obtain an indication 

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of the likely level of engagement we should expect. Some organisations approached found it 
difficult to engage as the COVID-19 crisis was in full effect throughout Europe.  

Table 2.10: Pilot interviews 

Evaluation  Organisation type 

Organisation 

Status 

Air PRM 

PRM representative 

EDF 

Airline representative 

IATA 

Completed on 17/03/2020 

Completed on 24/03/2020 

Declined due to COVID-19 workload 

No response 

Declined due to staff furlough in April 

Dublin airport 

Athens airport 

Equal Treatment Authority (HU) 
PRM NEB 

CAA (UK)  

No response  

Airport 

Airport 

NEB 

NEB 

Interviews 

2.37 

Table 2.11 below lists all stakeholders who were approached for an interview. A total of 20 
interviews were conducted as part of the study, four additional ones were also used to 
simultaneously discuss Regulation (EC) 1107/2006 as well as other passenger rights 
Regulations ((EC)181/2011 and/or (EU) 1177/2010) as to allow to probe synergies and 
inconsistencies across the relevant regulations. Three stakeholders (Riga Airport, Hungarian 
NEB, ECAC) declined Steer’s interview request, whilst two initially agreed but subsequently did 
not engage with Steer (IAG and VCD).  

Table 2.11: Stakeholder consultation interviews 

MS 

Stakeholder type  Organisation 

British Airways 

UK  Airline 

N/A  Airline 

N/A  Airline 

IE 

Airline 

N/A  Airline 

ES 

Airline 

HU  Airline 

DE 

NL 

LV 

Airline 

Airline 

Airport 

N/A  Airport 

IE 

Airport 

UK  Airport 

CY 

LT 

ES 

Airport 

Airport 

Airport 

UK  Airport 

Status 

Declined interview 

IATA - International Air Transport Association 

Interview complete 

ERAA - European Regions Airline Association 
(Regional carriers) 

Hibernian 

A4E - Airlines for Europe 

Albastar 

Wizzair 

Lufthansa 

KLM (Dutch airline) 

Riga International 

ACI-Europe 

Shannon airport 

Glasgow airport 

Larnaka airport 

Vilnius airport 

AENA (Spanish airport operator) 

London Heathrow Airport 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Declined interview 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

Interview complete 

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MS 

Stakeholder type  Organisation 

Equal Treatment Authority 

Italian CAA (ENAC) 

Status 

Declined interview 

Interview complete 

Environment and Transport Inspectorate (ILT)  

Interview complete 

Federal Office of Civil Aviation (FOCA) 

Interview complete 

European Civil Aviation Conference (ECAC) 

Declined interview 

European Aviation Safety Agency (EASA) 

Interview complete 

OCS Group (groundhandler) 

European Travel Agents and Tour Operators 
Association (ECTAA) 

Interview complete 

Interview complete 

HU  NEB 

IT 

NEB 

NL  NEB 

CH  NEB 

N/A  Other 

N/A  Other 

UK  Other 

N/A  Other 

N/A  Passenger 

Transport Club Germany (VCD) 

No engagement 

representative 

EL 

Passenger 
representative 

Consumer Protection Centre (ΚΕΠΚΑ) 

Interview complete 

N/A  PRM 

Reduced Mobility Rights Limited  

No engagement  

representative 

N/A  PRM 

European Disability Forum (EDF) 

Interview complete 

representative 

ES 

PRM 
representative 

Spanish Committee of Representatives of 
People with Disabilities (CERMI) 

Interview complete 

Workshop 

2.38 

A total of 28 organisations (excluding the European Commission and Steer) attended the 
workshop across all stakeholder groups.  

Table 2.12: Workshop attendees 

MS 

Organisation 

Group 

- 

DK 

UK 

CY 

CZ 

IT 

- 

ES 

UK 

- 

- 

HU 

CH 

DE 

HU 

IT 

ACI-Europe 

Copenhagen 

Heathrow 

Larnaka 

Prague 

Verona 

A4E 

Albastar 

easyJet 

ERAA 

IATA 

WizzAir 

Swiss CAA (FOCA) 

German CAA (LBA) 

Hungarian Ministry of Innovation and Technology 

Italian CAA (ENAC) 

Airports 

Airlines 

NEBs 

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MS 

Organisation 

Group 

LT 

NL 

SE 

UK 

N/A 

IT 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Lithuanian Transport Safety Administration 

Human Environment and Transport Inspectorate 

Transportstyrelsen  

UK Civil Aviation Authority 

European Union Aviation Safety Agency (EASA) 

Italian ECC 

European Disability Forum (EDF) 

Skywise Solutions (EDF trainer) 

European Passengers Federation (EPF) 

European Blind Union 

European Union of the Deaf 

PassePartout (PRM Trainer) 

Other 

Passenger and PRM 
representative 

Open Public Consultation 

OPC survey 

2.39 

A total of 41 responses were received to the survey from 40 unique organisations. Two unique 
responses were received both from the German Federation of the Blind and Partially Sighted – 
both of which are considered within the sample. A breakdown of OPC respondents by 
organisation type is provided in Table 2.13. 

Table 2.13: OPC responses received 

Organisation 

Number 

Respondents 

NEBs/Member 
States 

Airlines/ 
associations 

Airports/ 
associations 

Passenger 
representatives 

PRM 
representatives 

Citizens (EU and 
non-EU) 

5 

7 

5 

3 

10 

9 

Czech Ministry of Transport, French CAA (DGAC), Icelandic 
Transport Authority, Latvian Ministry of Transport, Portuguese 
Madeira Regional Directorate 

Airlines for America, Airlines for Europe (A4E), Condor, easyJet, 
SATA Air Açores, Sunclass Airlines, KLM. 

AENA, Billund airport, Bornholm Airport, Geneva airport, Munich 
airport. 

Danish Consumer Council (FT), Portuguese Association for 
Consumer Protection (DECO), the Austrian Automobile, Motorbike 
and Touring Club. 

Austrian Federation of the Blind and Partially Sighted, Catalonian 
Federation of Deaf People, Danish Disability Organisation, 
European Blind Union, French Confederation for the Social 
Promotion of the Blind and Amblyopes (CFPSAA), German 
Federation of the Blind and Partially Sighted, Reduced Mobility 
Rights, Spanish Committee of Representatives of People with 
Disabilities (CERMI), Spanish Confederation of People with 
Physical and Organic Disabilities (COCEMFE), the Swedish 
Organisation of Free Movement (DHR). 

Anonymous (8 EU, 1 non-EU). 

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Organisation 

Number 

Respondents 

Groundhandlers
/associations 

ECCs/ADRs* 

Total 

1 

0 

40 

The Association of German Groundhandlers (VDF). 

- 

Source: Steer analysis. *Note: ECC: European Consumer Centre; ADR: Alternative Dispute Resolution. 

Figure 2.4: Breakdown of OPC respondents: Country of origin 

Source: Steer analysis 

2.40 

All but four of the responses received were from contributors form the EU. The Member 
States with the most responses were: Germany (7), France (6) and Spain (4). 

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Figure 2.5: Breakdown of OPC respondents: organisation type 

Source: Steer analysis 

2.41 

The majority of respondents were PRM representatives (11) and citizens (9).The most 
common organisation size was large (13) with most of these being Company/business 
organisations, NGOs or public authorities. A more even distribution of small (8) and medium 
(6) organisation sizes is seen. 

Figure 2.6: Breakdown of OPC respondents: organisation size 

Source: Steer analysis 

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Written contributions 

2.42 

Supplementary documents were provided by several (7) stakeholders in support of their 
response to the OPC. A summary is presented in Appendix A. 

Table 2.14: Written contributions received through the Open Public Consultation 

Organisation 

Stakeholder group 

Language 

Length 

Austrian Federation of the Blind 
and Partially Sighted 

German Federation of the Blind 
and Partially Sighted 

Spanish Committee of 
Representatives of People with 
Disabilities (CERMI) 

Spanish Confederation of 
People with Physical and 
Organic Disabilities (COCEMFE) 

Federation of deaf people of 
Catalonia (FESOCA) 

PRM representative 

English 

13 pages 

PRM representative 

English 

13 pages 

PRM representative 

Spanish 

34 pages 

PRM representative 

Spanish 

14 pages 

PRM representative 

Spanish 

Munich airport 

Airport/association 

Airlines for America 

Airline/association 

easyJet 

Source: Steer 

Airline/association 

German 

English 

English 

4 pages 

7 pages 

2 pages 

8 pages 

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3  Analysis of the results 

3.1 

3.2 

3.3 

3.4 

3.5 

In this section, we report on the findings of the consultation exercise, from both the targeted 
consultation and the OPC.  

Results of the targeted consultation 

Results of all targeted consultation activities – targeted questionnaires, interviews and 
workshop – are assessed simultaneously in this section. The targeted questionnaires were 
designed to obtain data and open responses, so that facts and opinions could be extracted. 
The questionnaires were also drafted to ensure that similar questions were posed to each 
stakeholder group, allowing their views to be easily compared and contrasted. It is important 
to note that stakeholder responses were not analysed using any statistical approaches due to 
the highly qualitative nature of the responses received. Therefore, although we closely 
monitored response rates in order to ensure that we had a robust level of stakeholder 
engagement, we were more interested in the quality, length and detail provided in the 
responses, rather than the number of responses per se.  

Response quality 

The majority of responses received were generally well detailed and provided valuable 
quantitative and qualitative information for the study. Responses were mostly received within 
the timeframe agreed with stakeholders and all responses were reviewed prior to the 
submission of the final report. Nearly all responses were supplied in English and there is no 
evidence that this affected the quality of the submissions. Several stakeholders submitted 
additional written responses alongside their questionnaire response: 

  Airlines and associations: easyJet, IATA; 
  Airports and associations: Dublin, Shannon; and 
  National Enforcement Bodies: Traficom (FI), ENAC (IT), ILT (NL). 

Interviews proved effective at investigating gaps in the qualitative data and gave stakeholders 
the opportunity to raise or stress particular points of importance. It was noted that 
stakeholders were often more obliging with their views and opinions when meeting on the 
phone. Several stakeholders also encouraged us to contact them with any queries concerning 
the information provided. This was particularly useful for the case study component of the 
study where specific queries arose. Overall, we consider that our approach to the consultation 
– including steps taken to mitigate the effects of COVID-19 on stakeholder engagement, 
ultimately succeeded in encouraging open engagement with all stakeholder groups.  

However, it should be noted that the response rate of some key industry participants 
remained limited. This was particularly the case for the groundhandlers which we have found 
to be particularly challenging to engage given the ultra-competitive nature of the sector and 
extreme pressure that COVID-19 brought to their business at the time of the consultation. 
Only one groundhandler (OCS, a large UK PRM handler) was successfully engaged as part of 

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the consultation. This was partially offset, however, by excellent engagement with European 
airports who are principally responsible for the delivery of the PRM service. 

Analysis of the results 

National Enforcement Bodies 

3.6 

3.7 

Almost all NEBs (29/31) provided a questionnaire response however, There was a large range 
in response quality across the stakeholder group with some questions left blank. This was 
particularly common for questions on good practice. Overall, the vast majority of NEBs 
answered questions with some detail. Therefore, for most questions, it was possible to 
identify a consensus across NEBs (where relevant).  

With respect to the effectiveness of the Regulation, very few felt confident asserting a position 
on whether the Regulation had changed the level of protection provided to PRMs. The 
majority to provide a view (four2 of six), however, assessed that the Regulation has improved 
protections for PRMs. The other respondents (two3) stated that the Regulation has made little 
difference due to the existence of similar legislation prior to its transposition but has been 
beneficial through the creation of a more seamless travel experience for PRMs across Europe. 

3.8 

NEBs highlighted several factors which have hindered the achievement of the objectives of the 
Regulation4 (NEBs in parentheses):  

Low pre-notification rates and improper prenotification (FR, DE, EL, PT); 

 
  Abuse of the assistance service (EL, NL, PT); 
  Commercial pressure to reduce the costs of the PRM assistance service (SK, IS, UK); 
 

Lack of clear requirements as to what disability equality and awareness training entails 
and which conditions should be included (IT, LT, PT); 
Insufficient information on airline safety conditions used to deny boarding – including 
differences in airlines’ policies on the carriage of lithium batteries (FR, NL); 
  Growing numbers of passengers and the percentage of PRM who travel5 (CH) 
  Overprovision of the assistance service – the one-size fits-all assistance service is not 

 

 
 
 
 

necessary for many requests for assistance (FR); 
Poor communication between companies in the event of irregularities (AT); 
Lack of sanctions for noncompliance (IE); 
Lack of uniform standards for mobility equipment (NL); 
The obligation on airlines to assist PRMs to and from the aircraft toilet6 is not feasible in 
the absence of an on-board wheelchair in practice given crew health and safety 
considerations, and the need for an on-board wheelchair need cannot be clearly derived  
from the Regulation (DE). 

2 LT, EE, CY, CH. 

3 SE, IE. 

4 Briefly: non-discrimination, assistance, seamless mobility and appropriate complaints handling, fair 
cost-sharing between airlines. 

5 The percentage of total passengers requesting the PRM assistance service 

6 See Annex II, Regulation (EC) 1107/2006 

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3.9 

Approximately half (15) assessed that the Regulation’s key concepts were sufficiently well 
defined. However, four definitional issues were raised by several NEBs:  

 

 

 

 

The definition of PRMs is excessively broad which has led to the growth of inappropriate 
requests, to the detriment of those who really need the service (FR, EL, CH); 
Lack of clarity as to the definition of and training requirements for assistance dogs (AT, 
DE, ES, CH); 
IATA assistance codes are not always clear e.g. DPNA embodies a broad range of 
neurological conditions (NL); and 
Lack of clarity on the definition of mobility and medical equipment leading to possible 
instances of abuse through, for example, the carriage of e-scooters (DE, SE, CH). 

3.10 

3.11 

Two factors were highlighted as having aided the realisation of the Regulation’s objectives: the 
increase in the awareness of PRMs’ rights through the internet and mobile devices (BG) and 
attitudinal changes towards PRMs (EE). 

All NEBs to provide a view (137) assessed that the Regulation’s efficiency costs are 
proportionate to the benefits of the Regulation. This likely stems from a lack of complaints 
received by NEBs (the main enforcement tool for many NEBs) in the smaller Member States, 
and the scale economies achieved by subsuming regulatory tasks within those required by 
other passenger rights legislation (e.g. EC 261/2004, EU 181/2011 and EU 1177/2010). All 
assessed that it was not possible to reduce these costs further. 

3.12 

On EU-relevance, overall NEBs assessed that the original objectives of the Regulation are 
indeed relevant to the current needs of PRMs when travelling by air. Nevertheless, the 
Regulation could be better suited to some of the more recent trends, such as: 

 

The proliferation of mobile devices and the opportunities this gives for improving 
communication between service providers and PRMs (e.g. PRMs notifying the assistance 
provider of their arrival through an app rather than finding a designated arrival point, 
direct communication with the service provider of their individual needs) and quality 
monitoring (ability to leave a review on the quality of the assistance service); and 
The carriage of lithium-ion batteries for mobility devices and medical equipment; 
PRM lifts as a replacement for manual handling into an aircraft (which is often not 
possible and seen as highly dangerous) in the absence of a wheelchair ramp or airbridge; 
  Growth in the type and specifications (size, weight, etc.) of mobility devices, such as the 

 
 

 

use of e-scooters as a legitimate mobility device;  
The mass uptake of self-service booking and check-in which excludes PRMs when such 
functions are not built-in to the self-service process (many airlines still require PRMs to 
call in advance, sometimes at cost). 

3.13 

An ageing population at airports was also highlighted as a developing trend. However, 
although this has clear implications for the PRM charge which is levied on a per passenger 
basis and the mix of assistance that may be required, it is not clear how this is of relevance to 
PRMs’ passenger experience in light of the Regulation’s current provisions (e.g. cost-sharing). 
Therefore, the Regulation appears to have adapted well to this. 

3.14 

In terms of EU added value, the main benefit highlighted by NEBs was the ability for smooth, 
airport-to-airport travel for PRMs anywhere in Europe and, albeit to a lesser extent, to 

7 DK, EE, HR, HU, IS, IT, IE, PT, MT, NL, NO, UK (+ 1 confidential) 

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anywhere in the world. This also delivers cost savings for the industry through lower 
regulatory and training costs and a larger and more developed market for outsourced PRM 
assistance services. 

On coherence, all NEBs judged that the Regulation’s provisions were coherent and consistent 
with one another. With respect to other EU legislation, however, it was noted that the 
relationship between EU 261/2004 and EC 1107/2006 can be complex. For example, it is not 
clear whether Article 11 of EU 261/2004 applies in the context of denied boarding as a result 
of delays in the assistance service (i.e. arrived after final boarding call). It was also noted that 
consistency in the definition of key terms (PRMs, assistance dogs, mobility equipment, etc.) 
across both Member States and transport modes was important in simplifying the journey 
planning process – a particularly important point in the context of assistance 
dogs.8Additionally, in general, there is a lack of coherence between the Regulation and 
national labour safety law, particularly as to how this relates to manual handling of PRMs and 
the loading of heavy wheelchairs by groundhandlers in the relatively confined space of an 
aircraft’s hold. Finally, with respect to international regulations, the United Nations 
Convention on the Rights of Persons with Disabilities was not seen as inconsistent with the 
Regulation. However, the US Department of Transport’s inclusion of emotional support 
animals within the US’ equivalent PRM legislation9 was highlighted as a potential source of 
confusion for travellers when travelling within Europe.  

Airlines 

All responses received by airlines were detailed with each answering the vast majority of 
questions. There was a relatively small number of unanswered questions, mainly as a result of 
a lack of experience or expertise in the question area. All of the responses appeared to be 
unique, with no clear similarities in written responses between responses.  

On effectiveness, as with NEBs, few provided a view on the extent to which the Regulation had 
changed the protection afforded to PRMs when travelling by air. Nevertheless, of those to 
state a position (4), all agreed that protections had improved relative to before the 
Regulation’s implementation. Nevertheless, it was highlighted that airlines have a record of 
self-regulating in this area (e.g. IATA Resolution 700 on the standards for passengers requiring 
assistance) and many were already committed to improving accessibility and had introduced 
company standards on the carriage of PRMs prior to the Regulation’s implementation. Airlines 
assessed that the effectiveness of the Regulation has been primarily hindered by: 

  A lack of airport resources (e.g. improper ground equipment, insufficient staff); 
 

The wide definition of PRMs and mobility and medical equipment which allows for the 
possibility of abuse and prevents due priority from being afforded to those most in need; 
Poor passenger prenotification rates;  
Lack of oversight/control over the assistance service by airlines; 

 
 

8 Highlighted by: AT, DE, CH. 

9 Part 382, Air Carrier Access Act of 1986. Title 14, Chapter II, Subchapter D, Part 382 (available from: 
https://www.ecfr.gov/cgi-bin/text-
idx?SID=ae47679a5dc0b0cdd685abc7e3437dbb&mc=true&node=pt14.4.382&rgn=div5) 

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3.19 

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  Uninformative quality standards which focus only on the expedience of the service and do 
not monitor quality levels (instead, most airports only report whether quality meets the 
ECAC standards or not10); 

One airline, however, highlighted two trends that have contributed to the achievement of the 
Regulation’s objectives: improvements in staff training and airport accessibility. 

Airlines did not assess whether the intervention’s regulatory costs (compliance, 
administration, etc.) were proportional to its benefits. Nevertheless, two highlighted that the 
Regulation had increased demand for air travel from PRMs (although not necessarily from all 
passengers) and had created a framework for PRM assistance across Europe, reducing 
compliance costs. Nevertheless, airlines mostly focussed their criticism on the significant direct 
costs which the assistance service had created through the PRM charge. This was fuelled by 
sentiment regarding the breadth of the definition of PRMs and exacerbated by a lack of 
transparency surrounding the charge setting process by airports. It was stated that effective 
regulatory oversight of PRM charges and meaningful consultations between airports and users 
on service design and quality could help to achieve the Regulation’s objectives at lower cost. 

In terms of coherence, one major US flag carrier highlighted that the obligations of airlines are 
different between the European Regulation and its US equivalent (Part 382, see footnote 9). 
Under Part 382, all flights operating to or from the US are in scope of Part 382 which requires 
that airlines bear the responsibility of safeguarding passengers’ rights under Part 382. This, 
therefore, creates a discrepancy between the legally accountable party (airlines) and the party 
delivering the service (in Europe: airports). For example, Part 382 does not require 
prenotification (subject to some minor exceptions) to guarantee travel, unlike Regulation (EC) 
1107/2006. Therefore, US airlines may be penalised for noncompliance by US authorities for 
the actions of European airports. Secondly, airlines identified no inconsistencies between the 
Regulation and the Package Travel Directive (EU 2015/2302) and the Groundhandling Directive 
(96/67/EC). With respect to the groundhandling of mobility equipment, it was stated by one 
airline during the stakeholder workshop that differences in legal accountability (borne by 
airlines) versus the practical responsibility (borne by groundhandlers) for damage to mobility 
equipment was an issue which was too expensive to settle through legal channels and 
alternative means of redress should be introduced – either through the Groundhandling 
Directive, Regulation 1107/2006 or otherwise. With respect to the Directive on Airport 
Charges (2009/12/EC), although the Directive specifies that the PRM charge is formally out of 
scope (Article 1(4)), airlines commented that airports occasionally include this within 
passenger charges.  

3.21 

On relevance, airlines generally agreed that the original objectives of the Regulation are 
relevant to the priorities of PRMs when travelling by air today. Technological changes in the 
form of different batteries and a wider variety of assistive devices have generated friction with 
the Regulation, such as whether e-scooters should be considered as mobility equipment, and 
tension with other legislation, such as IATA’s Dangerous Goods Regulations11 vis à vis the 
carriage of large lithium-ion batteries. Growth in the number of online travel agents has also 

10 Italy is the only known exception to this where the Italian CAA (ECAC) requires airports to publish 
annual airport service charters (https://www.enac.gov.it/aeroporti/qualita-dei-servizi-
aeroportuali/carte-dei-servizi-dei-gestori-aeroportuali) 

11 https://www.iata.org/en/publications/dgr/?gclid=EAIaIQobChMI98ma48-
87QIVQuztCh3cHAiHEAAYASAAEgJ-0fD_BwE 

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increased the complexity of the prenotification process as not all provide the ability for PRMs 
to indicate a need for assistance at the time of booking. Passengers with hidden disabilities are 
also becoming more frequent air travellers with the range of common hidden disabilities 
increasing, one airline stated, all of which are encapsulated within a single IATA SSR code 
(‘DPNA’). 

With respect to EU added value, airlines unanimously assessed that the use of legislation at a 
European level has been beneficial for ensuring fair competition within Europe and regulatory 
consistency and so lower compliance costs for airlines operating within Europe. 

Airports 

On effectiveness, of the airports to comment directly on the changes brought about by the 
implementation of the Regulation most (512) noted that the protection for PRMs has 
improved. Key points raised are: complimentary assistance at point of service for PRMs with 
costs shared for all passengers, clearly defined rights of PRMs to assistance, a reduction in 
denied boarding (only possible with justifiable safety reasons) and the clear division of tasks 
for airlines and airports. Factors which airports stated have contributed to the achievement of 
the Regulation’s objectives include: a larger, growing market for PRMs; clear requirements for 
PRM assistance; and capital investment in accessible infrastructure. Barriers that hindered the 
objectives of the Regulation include: abuse of the service by passengers other than PRMs; and 
airlines managing the costs of PRM support services down, negatively impacting the quality of 
service provided. Airports were divided on whether key terms in the Regulation are sufficiently 
defined: 8 state that definitions are clear whilst 7 state they are insufficient. Several requested 
that the definition of a PRM being clarified and information on specific training requirements 
be made available. The significant majority of airports (13) state that the EU PRM legislation 
has had an impact on their operations. Of these, 513 noted an increase in operating costs. 
Overall, airports agreed that the quality of service provided to PRMs has improved. The main 
impacts are as follows: 

  Greater demand for staff and equipment (e.g. additional assistance equipment) due to 

greater demand for assistance; 

  Greater provision of reception areas and call points in terminals; 
  Access to self-driven wheelchairs; and 
 

Publication of information regarding PRMs’ rights, quality standards and complaints 
handling. 

3.24 

With respect to cost efficiency, the majority of airports (714) responded that compliance costs 
are proportionate to the benefits of the Regulation. Two of which also stated that the 
objectives of the Regulation could not be reduced. More, however, highlighted that costs 
could be reduced by making prenotification mandatory or introducing a clear PRM-
identification process to prevent abuse. The majority (9) also noted that the PRM charges are 
set with oversight from their relevant NEBs. 

3.25 

On relevance, airports agreed that the priority needs for PRMs were: safety, comfort, 
assurance and the preservation of their dignity when travelling. Technological advancements 

12 Copenhagen, Dublin, Larnarca, Shannon, +1 anonymous  

13 AENA, Copenhagen, Dublin, Zurich, +1 anonymous 

14 Copenhagen, Larnarca, Prague, Shannon, Vilnius, +2 anonymous 

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to mobility equipment, booking systems and service trackers are highlighted as avenues for 
further positive impacts for PRMs alongside the Regulation as they will promote further 
independence of the PRM as well as keep PRMs informed along their journey. Changes within 
the aviation sector that are of relevance to the Regulation include:  

  Overall market size increase causing higher traffic levels and congestion due to increased 

 

process complexity; 
Prevalence of low-cost carriers and the impact of their reduced turnaround times on 
service quality and reliability for PRMs. 

3.26 

In terms of EU added value, as with other stakeholder groups, airports assessed that the 
Regulation provides significant value in terms of regulatory simplicity for travellers and 
airports, by providing a consistent European framework. Furthermore, the clarity which the 
Regulation provides ensures that all parties are aware of their rights and obligations, leading 
to a better overall service for PRMs. 

Regarding coherence, the majority of airports to provide a view (515) stated that the provisions 
within the Regulation are coherent. Those who disagreed (216) asked that clarity be provided 
on the burden of the indirect costs of providing PRM assistance (e.g. administration, 
compliance, etc.). It was also suggested that the responsibilities of airports and airlines could 
be clarified further. Other small details within Annex I & II are also highlighted as confusing in 
regard to handling of wheelchairs from aircraft door to aircraft hold.  The majority (8) of 
airports saw no overlap or inconsistencies within the relationship between the Regulation and 
the Package Travel Directive. In relation to the Groundhandling Directive, Directive on airport 
charges and Regulation (EC) 261/2004, the majority of airports (7) saw no overlap, gaps or 
inconsistencies with the Regulation. Nevertheless, of those to report inconsistencies, it was 
highlighted that it was challenging for airlines to pass on liability for damage to mobility 
equipment to their groundhandlers as this was challenging (and expensive) to prove in court. 
It was also noted that the Montreal Convention allows airlines to limit their liability for 
damage to luggage (including mobility equipment), although some have waived this limit. With 
respect to other international legislation, similarly to airlines, airports highlighted that the 
relationship between the EU and US PRM regulations can be problematic due to differences in 
prenotification requirements and allowances for emotional support animals. 

Passenger and PRM representatives 

On effectiveness, PRM representatives reported that the Regulation had been somewhat 
effective at encouraging a similar level of protection for PRMs when travelling by air. In 
general, the majority (5) stated that the Regulation has helped to ensure that PRMs have 
equal right to air travel, has highlighted potential practices of discrimination and allowed 
avenues for pressures to be applied on Government over implementation. It was also stated 
that, since implementation, the availability and exchange of information on the rights of PRMs 
have improved. Nevertheless, PRM representatives highlighted that barriers remain in terms 
of the disproportionate costs to PRMs of travelling with a disability (e.g. cost of accompanying 
passengers, insurance, etc.) and the lack of proper staff training at some airports. 
Furthermore, they assessed that the derogations provided within the Regulation (under Article 

15 ACI, Copenhagen, Larnarca, Vilnius, +1 anonymous 

16 AENA, Dublin 

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4) are significant barriers to travel for PRMs because of unclear and inconsistently applied 
safety conditions used by airlines to deny boarding.  

On efficiency, PRM representatives shared a view that more effective monitoring and the 
possibility to impose financial sanctions (on airports, airlines, etc.) are needed in order to have 
a dissuasive effect. The award of monetary compensation for PRMs who successfully uphold a 
complaint should also be considered as a way to encourage reporting and so improve 
monitoring. PRM representatives also criticised the limit on liability for damage to mobility 
equipment under the Montreal Convention and the legal risks associated with disputing this 
through the legal system. On balance, however, some assessed that the Regulation can be 
credited with an increase in demand from PRMs. 

On relevance, PRM representatives concluded that the current needs of PRMs travelling by air 
are similar to those when the Regulation was implemented. These include: non-discrimination, 
the carriage of mobility equipment, accessible communication and equal opportunities for 
spontaneous travel. It was noted that the number of elderly passengers and those with hidden 
disabilities has increased since the Regulation was implemented. The introduction of low-cost 
airlines has also increased commercial pressure on airports to reduce costs, with ramifications 
on the quality of the PRM assistance service. 

On coherence, one stakeholder commented that the spirit of the Regulation and the 
derogations are, to an extent, conflicting. It is also mentioned that further work is required to 
ensure that the Regulation is coherent with the United Nations Convention on the Rights of 
Persons with Disabilities. 

European Consumer Centres 

Almost all ECCs to respond had received no or very few complaints relating to the Regulation, 
and therefore could not provide a view on the effectiveness of the complaints handling 
process. In general, because ECCs do not issue binding decisions, outcomes of complaints 
raised with ECCs typically focus on mediating agreement between the carrier and consumer. 
None stated whether this approach supported the effectiveness of the Regulation more 
generally. 

In relation to efficiency, the majority of ECCs (8) agree that passenger reimbursement from 
carriers needs to improve. An automated process maintained by carriers is suggested as this 
removes the administrative and financial burden on the consumer. 

On the point of relevance, a significant majority of ECCs (10) across Member States stated that 
their decisions are not binding for transport operators and they also cannot award additional 
damages or compensation beyond what is stated in the Regulation, their primary role being of 
mediation. 

3.27 

3.28 

3.29 

3.30 

3.31 

3.32 

ECCs made no responses relevant to coherence. 

Alternative Dispute Resolution organisations 

3.33 

As with ECCs, almost all ADRs to respond had received no or very few complaints relating to 
the Regulation, and therefore could not provide a view on the effectiveness of the complaints 
handling process. In general, there is little in common across ADRs’ responses to and 
resolution of complaints, with remedial action ranging from: ordering the compensation of 
damages (UK), encouraging out of court settlements (AT), or posting decisions to ADR 
websites and statements emphasising changes to providers procedures for breaches of the 

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Regulation (PT). Notably, the Danish ADR claimed that most of the complaints received 
involved merely a perception of an infringement and so no enforcement action was necessary.  

3.34 

Most of the ADRs to provide a response (5 of 8) stated that their decisions are non-binding, 
although none commented on the extent to which this affects the effectiveness of the 
complaints handling process. Only three (DE, PT, UK) stated that they had the ability to award 
damages to plaintiffs. There is a significant majority (7) of within ADRs that state their decision 
can be used in court, this is also seen within responses from ECCs (6).  

3.35 

ADRs’ had no significant comments relating to relevance, efficiency or coherence.  

3.36 

3.37 

3.38 

3.39 

3.40 

3.41 

Others 

The following analysis is provided from two responses given respectively by the European 
Travel Agents and Tour Operators Association (ECTAA) and PRM groundhandler OCS.  

In terms of effectiveness, the ECTAA stated that two-thirds of travel agents provide the option 
to book assistance via their website, according to their survey. Restating their results: the 
option to pre-book is available on 67% of agents’ websites, with 71% offering assistance 
booking over the phone (71%) and just over half (54%) within their brochures. The majority of 
respondents (92%) to this survey also indicated that they are familiar with the IATA SSR codes 
(which specify the type of assistance required). The ECTAA also stated that the most effective 
way to notify all involved parties of PRM assistance requirements is through airlines’ 
reservation systems. However, over recent years airlines have removed content from available 
Global Distribution Systems that has led to a disruption of standardised processes for 
assistance notifications.  

The groundhandler, OCS stated that the Regulation has been relatively effective in achieving 
its original objectives, although PRMs still faces issues regarding the consistency of the 
assistance service across airlines and airports. Although the Regulation has led to an increase 
in operating costs for OCS (driven by high quality standards – it claimed), the prenotification 
requirement has helped keep costs lower. Furthermore, OCS claimed that the Regulation has 
encouraged airports and airlines to drive improvements in their service and infrastructure. 

None commented directly on the Regulation’s efficiency, although OCS commented that cost 
of assistance is not driven solely by the Regulation. For example, it is common for costs to vary 
across airports depending on passenger demographics, infrastructure, penetration rate, etc. 

On relevance, OCS responded that wayfinding and navigation within the airport (i.e. to 
designated collection and check-in points) is a priority for PRMs. OCS are of the opinion that 
the Regulation has not proved relevant here, instead referring to the role of the Equality Act 
2006 in servicing this need in the UK. Furthermore, the whole process is undermined when the 
assistance request is not communicated through the booking process, which remains a major 
stumbling block. 

On coherence, the ECTAA sees no gaps or inconsistencies between the Regulation and the 
Package Travel Directive. OCS note that there are differences between US and Canadian PRM 
legislation which require service options to be provided on their part to ensure compliance for 
flights to/from the US.  

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Problematic questions 

Effectiveness 

3.42 

Many stakeholders were unable or unwilling to provide a response on how effective the 
Regulation had been in achieving its general and specific objectives, with most finding it 
difficult to do so robustly due to a lack of data (both quantitative and qualitative) or analysis of 
such. We collected all necessary data from those who were able to provide it, thus enabling 
our own analysis of the Regulation’s effectiveness elsewhere in this report. Nevertheless, of 
the small number of stakeholders to provide a response, most stated that the Regulation has 
been beneficial in bringing about the realisation of at least some of the Regulation’s 
objectives. Relevant insights have been extracted and cited in the subsections above.  

EU added value 

3.43 

Although this question was generally answered correctly by the majority of stakeholders, a 
small minority misinterpreted the question as an assessment of how much value the 
Regulation contributed to their Member State or their individual organisation rather than the 
EU as a whole. In general, however, it is unlikely that this was of disadvantage to the study 
because those who interpreted the question correctly responded similarly.  

Areas of agreement 

3.44 

There were several areas of agreement across stakeholder groups. Agreements within 
stakeholder groups were widespread across all evaluation topics and so have not been 
assessed. 

Table 3.1: Areas of agreement across stakeholder groups 

Topic 

Stakeholder groups who agree 

Description 

Clarity and scope of 
PRM definition 

Airports, airlines NEBS 

Accessibility of air 
travel for PRMs 

All stakeholders 

Lack of consistency 
with US regulation 

NEBs, airlines, airports 

Steer analysis 

NEBs stated that the definition of PRMs is 
excessively broad which has led to the growth of 
inappropriate requests, to the detriment of those 
who really need the service. Airports and airlines 
noted that further clarification on PRM definition 
was required to prevent misuse of assistance 
services by non-PRMs which adversely impacts the 
quality of service provided to PRMs. 

Airlines and airports in particular mentioned that 
the accessibility to travel following the 
implementation of the Regulation had significantly 
improved. This evidenced across stakeholder 
groups by an increase in market share for PRMs 
and persons with disabilities   

Differences between the US Regulation (Part 382) 
and Regulation 1107/2006 creates a discrepancy 
between the who is legally accountable (under US 
law) and who is responsible for the delivery of the 
assistance service in Europe (under EU law). 
Furthermore, the US regulations allow for the 
carriage of emotional support animals for 
passengers. 

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Areas of disagreement 

3.45 

There were relatively few areas of disagreement across the stakeholder groups – described 
individually in Table 3.2. There were no significant differences of views within stakeholder 
groups. 

Table 3.2: Areas of disagreement across stakeholder groups 

Topic 

Safety conditions 
applied by airlines in 
the context of denied 
boarding 

Stakeholder groups who 
disagree 

PRM representatives 

Airlines 

Cost of provision of 
PRM assistance 

Airports, NEBs, groundhandlers 

Airlines 

Prenotification 

PRM representatives 

Airlines, airports, NEBs 

Description 

Derogations used to unfairly discriminate against 
PRMs through arbitrary application and/or vague 
definition of airline safety conditions. 

Derogations are critical for PRM and passenger 
safety. Safety conditions can be challenging to 
define given the range of relevant disabilities and 
conditions. PRM denied boarding is rare and 
typically stems from failure to pre-notify and 
inability to load wheelchairs or their batteries. 

Margins for the provision of PRM assistance 
services are relatively tight, and the increasing 
PRM penetration rate at some airports has 
increased costs. Compliance costs are relatively 
insignificant for most NEBs. Overall, there is little 
flexibility for reducing costs ceteris paribus. 

Some airlines assessed that the Regulation’s 
benefits could be delivered at lower cost to 
consumers should the setting of the PRM charge 
be made truly transparent and consultation with 
airport users encouraged. Assistance could also be 
better targeted towards those who benefit most 
from it by differentiating assistance services or 
narrowing the definition of PRMs. 

Prenotification reduces opportunities for 
spontaneous travel for PRMs. 

Prenotification is an important component of 
resource planning for airports and airlines, 
allowing resources to be planned efficiently as to 
keep the burden of the service low. 

Source: Steer analysis. 

Results of the Open Public Consultation 

Overview 

3.46 

The Open Public Consultation (OPC) primarily focussed on the effectiveness of the Regulation. 
A total of 41 responses were received. The largest number of responses was given by PRM 
Representatives (10) and EU (8) and non-EU (1) citizens, making up just under one-half (19 of 
40) of the sample. A significant number of responses were also received by airlines (7), 
airports (5) and their associations. A full breakdown of respondents who contributed to the 
OPC is seen in Table 2.13. 

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Evaluation topics 

Effectiveness 

3.47 

In general, a significant majority (30 of 40) stakeholders assessed that the Regulation has 
improved access to air travel for PRMs on comparable terms to other citizens – the 
Regulation’s general objective. Nevertheless, it was noted by one PRM representative that, to 
guarantee assistance, PRMs must pre-notify which can limit the ability to travel 
spontaneously. With respect to the Regulation’s specific objectives: 

  Non-discrimination of PRMs: the vast majority (36 of 40) stakeholders stated that the 

Regulation has improved the protection of PRMs against discrimination; 

  Right to assistance: a significant majority (27 of 40) assessed that the assistance service 
has improved over time, partially reflected by improvements to airport and airline staff 
training; 
Seamless and smooth mobility of PRMs: most (22 of 40) assessed that, between airports 
and airlines, cooperation has improved. There was, however, no consensus view for 
cooperation between airlines and other modes of transport; 

 

  Appropriate complaints handling by carriers: most stakeholders (22 of 40) assessed that 
information on complaints procedures and the quality of complaints-handling had 
improved over time; and 
Sharing of costs of PRM assistance between airlines: a majority (25 of 40) expressed no 
view with the remainder (mainly airports and airlines) disagreeing: airlines stated that the 
sharing of costs had deteriorated, while airports claimed the opposite. 

 

3.48 

A number of positive and negative impacts of the Regulation were identified by stakeholders, 
some of which can be directly accredited to the Regulation. In terms of the positive effects, in 
addition to those cited above, a majority of respondents assessed that:  

3.49 

3.50 

  Airlines and airports actively consider the needs of PRMs and persons with disabilities; 
 
The availability of information has improved (e.g. airline safety rules, accompanying 
passenger requirements, etc.); and 
Enforcement by NEBs has improved. 

 

With respect to the Regulation’s negative impacts, views varied by stakeholder. Airlines 
assessed that the definition of who qualifies for the assistance service in its current form is too 
broad. PRM representatives and citizens assessed that some of the Regulation’s provisions are 
unclear or open to interpretation by carriers and NEBs. Passenger representatives commented 
that further clarity on the complaints process would be beneficial.  

On the topic of the consistency of the Regulation’s implementation across Europe, all PRM 
representatives (5) to give an opinion and a majority of citizens (5) and airlines (4) assessed 
that some differences in implementation existed across Member States. For example, one 
PRM representative organisation stated that this was manifested through observable 
differences in the guidance issued by NEBs, the quality and scope of airport inspections and 
the accessibility (and general ease of use) of the complaints process. 

EU Relevance 

3.51 

A majority of (13 of 22) stakeholders to express a view stated that some of the Regulation’s 
provisions are obsolete. Alongside this, most (24 of 40) stated that there are issues which the 
Regulation fails to address, including: 

February 2021 | 34 

 
3.52 

3.53 

Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

  Accessibility of airline and airport websites, including the availability of information 

specifically with respect to COVID-19; 
Support for persons with visual impairments (e.g. lack of tactile devices on aircraft and 
airports); and 
The Regulation’s silence on the topic of aircraft and airport accessibility. 

 

 

This highlights that there is still further work required to make progress against the original 
objectives of the Regulation, although a significant portion (25) agree that the Regulation has 
improved the protection of persons with disabilities and PRMs. 

Efficiency 

Most (13 of 23) stakeholders to hold a view stated that they had experienced difficulties 
implementing the Regulation. CERMI notes that issues with the Regulation had been corrected 
in application through collaboration with the airport authorities responsible for the Regulation 
in Spain. Airports and airlines stated that the cost of providing the service has risen greatly as 
more PRM passengers make use of the service. Airports and airlines also suggested that abuse 
of the service has also become more common, although this was not substantiated. The costs 
of ‘go-show’ (non-pre-notified) passengers were also highlighted as significant. PRM 
representatives and citizens also stated that pre-notification was inconvenient and 
occasionally onerous. Groundhandler association (VDF) stated that “identifying applicable 
training” for staff to comply with the requirements was a difficulty. 

EU added value 

3.54 

The OPC did not address the question of EU added value. 

Coherence 

3.55 

One stakeholder stated that different pre-notification periods between the EU and US PRM 
regulations has caused confusion for transatlantic passengers. No other points were raised as 
the OPC did not explicitly address the question of coherence. 

February 2021 | 35 

 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Appendices 

A 

B 

C 

Analytical results of the OPC 

GDPR notice 

Targeted questionnaires   

D  Workshop agenda 

E 

Workshop summary 

37 

73 

79 

112 

114 

February 2021 | 36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

A  Open public consultation  

Analysis of responses 

A.1 

We provide below a detailed analysis of the views expressed by the stakeholders who took 
part in the Open Public Consultation. The reader is reminded that the sample of respondents is 
skewed marginally in favour of passengers and PRMs who make up just under one-half of the 
sample (19 of 40) as shown in Table 2.13: OPC responses received on p.19. Results are 
disaggregated by stakeholder group to control for this. 

On average, how often do you travel by plane? 

Figure A.1: Level of agreement on the statement above. 

Table A.1: Breakdown of responses. 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

1 

2 

3 

1 

2 

- 

2 

3 

2 

- 

- 

2 

- 

1 

- 

- 

- 

- 

2 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

1 

- 

- 

- 

- 

2 

7 

6 

6 

2 

Responses 

More than 
once a week 

Once a month 

Once a 
trimester 

Once a 
semester 

Once a year 

A.2 

The majority of respondents (19) travelled by plane at least three times per year. 

February 2021 | 37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Which answer describes best the purpose of your flights in 2019? 

Figure A.2: Level of agreement on the statement above 

Table A.2: : Breakdown of responses  

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

2 

3 

- 

- 

4 

1 

3 

2 

- 

1 

1 

- 

1 

1 

- 

1 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

1 

- 

- 

- 

- 

6 

7 

3 

1 

6 

Responses 

I travelled only 
for business 

I travelled 75% 
for business, 
25% for leisure 

I travelled 50% 
for business, 
50% for leisure 

I travelled 25% 
for business, 
75% for leisure 

I travelled only 
for leisure 

A.3 

A majority of respondents (13 of 23) travelled predominantly for business in 2019. Just under 
one-quarter (6 of the 23) travelled by plane exclusively for leisure or for business. 

February 2021 | 38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

To what extent do you agree with the statement that the needs of persons with disabilities 
and persons with reduced mobility when traveling by air are sufficiently considered by air 
carriers after the introduction of EU passengers rights in 2008? 

Figure A.3: Level of agreement on the statement above 

Table A.3: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

2 

2 

1 

2 

2 

2 

3 

- 

2 

- 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No opinion 

Somewhat agree 

Strongly agree 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

Total 

- 

- 

1 

1 

- 

- 

- 

- 

1 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

4 

5 

2 

7 

5 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

- 

- 

- 

3 

A.4 

Of the respondents to express a view, the majority (12) somewhat or strongly agreed that the 
needs of persons with disabilities and persons with reduced mobility are considered when 
travelling by air. A large number of PRM representatives and citizens (9) disagreed, however.  

February 2021 | 39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Did you face difficulties in implementing the obligations stemming from the Regulation? 

Figure A.4: Level of agreement on the statement above 

Table A.4: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

1 

5 

1 

1 

5 

3 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

2 

- 

5 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

4 

- 

1 

- 

2 

- 

- 

- 

1 

10 

13 

13 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

2 

1 

2 

Responses 

No 

No opinion 

Yes 

A.5 

13 of 36 respondents noted that they faced difficulties in implementing the obligations 
stemming from the regulations. Of the 7 Airlines/associations to respond to this question 5 
faced difficulties with implementation. Of the 10 respondents who did not face difficulties, 4 
were given by National Enforcement Bodies/Member States. 

February 2021 | 40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

To what extent has the Regulation improved the protection of persons with disabilities and 
persons with reduced mobility (PRM) traveling by air against discrimination during the past 
12 years? 

Figure A.5: Level of agreement on the statement above 

Table A.5: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

1 

2 

4 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

1 

- 

5 

5 

Responses 

Not at all 

No opinion 

Slightly 

Significantly 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

2 

5 

- 

- 

- 

5 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

1 

3 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

- 

2 

1 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

- 

2 

Total 

3 

1 

12 

25 

A.6 

The majority of respondents (25) expressed that the protection of persons with disabilities and 
persons with reduced mobility (PRM) have been significantly improved when travelling by air 
during the last 12 years. Only 3 stakeholders (2 citizens, 1 PRM representative) disagreed. 

February 2021 | 41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Have the opportunities for PRM to use air transport when compared with other citizens 
have improved/deteriorated? 

Figure A.6: Level of agreement on the statement above 

Table A.6: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

3 

4 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

1 

4 

6 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

7 

- 

- 

5 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

1 

2 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

Total 

3 

8 

30 

A.7 

The significant majority (30) of respondents stated that the opportunities for PRM to use air 
transport compared with other citizens had improved. There was some disagreement between 
Citizens and PRM representatives. Only 3 stakeholders (2 citizens, 1 PRM representative) 
believed that the situation had deteriorated. 

February 2021 | 42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the information for PRM about their passenger rights improved/deteriorated? 

Figure A.7: Level of agreement on the statement above 

Table A.7: Breakdown of responses 

)

U
E
-
n
o
n

M
R
P

d
n
a
U
E
(

s
n
e
z
i
t
i
C

2 

2 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

2 

1 

8 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

1 

6 

- 

- 

5 

r
e
b
m
e
M

/
s
B
E
N

- 

1 

4 

r
e
g
n
e
s
s
a
P

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

- 

- 

3 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

Total 

4 

5 

32 

A.8 

Of the respondents to have expressed a view, the majority (32) believe the information for 
PRM about their passenger rights has improved. The only stakeholders to disagree were 
citizens (2) and PRM representatives (2). 

February 2021 | 43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the information that airlines publish about their safety rules (e.g. airlines’ accompanying 
passenger requirements) improved/deteriorated? 

Figure A.8: Level of agreement on the statement above 

Table A.8: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

4 

3 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

2 

6 

3 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

2 

3 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

1 

2 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

4 

13 

24 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

- 

7 

A.9 

The majority of the respondents (24) noted that the information that airlines publish about 
their safety rules (e.g. airlines’ accompanying passenger requirements) had improved. The 
only stakeholders to disagree were citizens (2) and PRM representatives (2). 

February 2021 | 44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the assistance that PRM receive from airlines to travel by plane improved/deteriorated? 

Figure A.9: Level of agreement on the statement above 

Table A.9: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

2 

5 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

2 

5 

4 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

1 

6 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

1 

4 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

- 

3 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

4 

9 

28 

A.10 

The most common view expressed by (28) respondents was that the assistance that PRM 
receive from airlines to travel by plane had improved. The only stakeholders to disagree were 
citizens (2) and PRM representatives (2). 

February 2021 | 45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the assistance that PRM receive from airports to travel by plane 
improved/deteriorated? 

Figure A.10: Level of agreement on the statement above 

Table A.10: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

3 

4 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

1 

5 

5 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

1 

2 

4 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

- 

3 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

4 

10 

27 

A.11 

The majority of respondents (27) expressed a view that the assistance PRM receive from 
airports to travel by plane had improved. A small number of citizens (2), PRM representatives 
(1) and airlines (1) disagreed. 

February 2021 | 46 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the training that airline staff receive on how to help PRM improved/deteriorated? 

Figure A.11: Level of agreement on the statement above 

Table A.11: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

4 

3 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

3 

5 

3 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

- 

7 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

2 

1 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

1 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

2 

3 

Total 

5 

14 

22 

A.12 

The most common view (22) expressed by the respondents was that the training that airline 
staff receive on how to help PRM had improved. PRM representatives and citizens were 
divided on the topic. 

February 2021 | 47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the training that airport staff receive on how to help PRM improved/deteriorated? 

Figure A.12: Level of agreement on the statement above 

Table A.12: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

3 

4 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

3 

4 

4 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

3 

4 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

1 

4 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

2 

1 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

5 

13 

23 

A.13 

The most common view (23) expressed by the respondents was that the training that airport 
staff receive on how to help PRM had improved, this was generally evenly distributed across 
the stakeholder groups. PRM representatives and citizens were divided on the topic. 

February 2021 | 48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the cooperation between airlines and airports to assist PRM improved/deteriorated? 

Figure A.13: Level of agreement on the statement above 

Table A.13: Breakdown of responses 

Responses 

Deteriorated 

No opinion / not 
sure 

Improved 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

2 

3 

4 

3 

4 

4 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

3 

4 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

2 

3 

- 

2 

1 

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

5 

14 

22 

A.14 

Of those respondents to express a view, the majority (22) believe that the cooperation 
between airlines and airports to assist PRM has improved. PRM representatives were divided 
on the topic. 

February 2021 | 49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Have the connections between airlines and train, bus or coach operators to assist PRM 
accessing the airport improved/deteriorated? 

Figure A.14: Level of agreement on the statement above 

Table A.14: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

5 

2 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

3 

6 

2 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

4 

1 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

3 

- 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

1 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

2 

3 

Total 

6 

27 

8 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

1 

6 

- 

A.15 

The majority of respondents across most stakeholder groups to this question (27) had no 
opinion or were unsure as to whether connections between modes had improved or 
deteriorated. Airlines and PRM representatives were the only exception to this, with the 
majority of airports (3) assessing that the situation had improved with the majority of PRM 
representatives (3) holding the contrary view. 

February 2021 | 50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the sharing between airlines and airports of costs of assisting PRM 
improved/deteriorated? 

Figure A.15: Level of agreement on the statement above 

Table A.15: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

4 

3 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

2 

9 

- 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

1 

4 

- 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

3 

- 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

1 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

2 

3 

Total 

9 

25 

7 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

4 

2 

1 

A.16 

Most respondents (25) had no opinion or were unsure if the sharing of costs of assisting PRM 
between airlines and airports had improved. Of those to express an opinion (16) the majority 
(9) believed that this had deteriorated. All but one airline to express a view (4) believed that 
the sharing of PRM assistance costs had deteriorated. The other two groups to have a majority 
opinion (citizens and airports) both believed, however, that the situation had improved.  

February 2021 | 51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the information for PRM as to whom they can complain to if their rights are not 
respected improved/deteriorated? 

Figure A.16: Level of agreement on the statement above 

Table A.16: Breakdown of responses 

Responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

Deteriorated 

No opinion / not 
sure 

Improved 

3 

2 

4 

3 

5 

3 

1 

1 

5 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

2 

3 

- 

1 

2 

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

5 

Total 

7 

11 

23 

A.17 

The majority of respondents (23) stated that the information available to PRM as to whom to 
they can complain to if their rights are not respected had improved – a position held by the 
majority of airlines (5), airports (5), NEBs (3), passenger representatives (2) and 
groundhandlers (1). Only 7 of the total 41 respondents believed the availability of information 
regarding filing a complaint had had deteriorated. 

February 2021 | 52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the follow-up of complaints by the airline/ the airport improved/deteriorated? 

Figure A.17: Level of agreement on the statement above 

Table A.17: Breakdown of responses 

Responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

Deteriorated 

No opinion / not 
sure 

Improved 

4 

1 

4 

3 

5 

3 

- 

1 

6 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

5 

2 

- 

1 

- 

1 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

1 

4 

Total 

9 

9 

23 

A.18 

Of the respondents to have expressed an opinion, the majority (23) stated that the follow-up 
of complaints by airline and airports had improved. Of these, 10 were from airlines (6) or 
airports (4), however. Citizens and PRM representatives disagreed as to whether the situation 
had improved. Passenger representatives was the only group to state that the situation had 
deteriorated. 

February 2021 | 53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Has the enforcement of passenger rights of PRM by national authorities 
improved/deteriorated? 

Figure A.18: Level of agreement on the statement above 

Table A.18: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

4 

3 

2 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

2 

5 

4 

Responses 

Deteriorated 

No opinion / 
not sure 

Improved 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

- 

3 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

2 

3 

Total 

6 

14 

21 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

4 

3 

A.19 

The majority of respondents (21) stated that the enforcement of passenger rights of PRM by 
national enforcement bodies (NEBs) had improved, of which 5 were from NEBs/Member 
States themselves. Citizens were the only stakeholder group to disagree, with 4 of the 6 
citizens to provide an answer assessing that enforcement by NEBs had deteriorated.  

February 2021 | 54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

What is your opinion about the level of knowledge of airport staff on the specific needs of 
PRMs? 

Figure A.19: Level of agreement on the statement above 

Table A.19: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

1 

3 

1 

4 

- 

Responses 

I do not 
know 

Poor 

Fair 

Good 

Excellent 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

1 

2 

2 

3 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

- 

- 

2 

2 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

- 

- 

1 

- 

- 

- 

1 

- 

- 

- 

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

- 

- 

2 

- 

Total 

2 

5 

3 

12 

4 

A.20 

Of the 24 to state a view, the majority (16) assessed that the knowledge of airport staff as to 
the specific needs of PRMs was good or excellent – a view expressed by all airlines, airports, 
NEBs, passenger representatives and groundhandlers. There was disagreement between 
citizens and PRM representatives, however, with the majority of these two groups assessing 
that airport staffs’ knowledge was poor (5) or fair (3). 

February 2021 | 55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

What is your opinion about the level of knowledge of airline staff on the specific needs of 
PRMs?  

Figure A.20: Level of agreement on the statement above 

Table A.20: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

2 

2 

3 

1 

- 

2 

3 

3 

- 

- 

- 

- 

3 

1 

- 

- 

- 

2 

- 

- 

- 

- 

1 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

1 

Responses 

I do not 
know 

Poor 

Fair 

Good 

Excellent 

Total 

1 

4 

5 

13 

3 

A.21 

As in the previous question, the majority of respondents (16) believed that the knowledge of 
airline staff on the specific needs of PRM was either good (13) or excellent (1). Likewise, there 
was significant disagreement between citizens and PRM representatives, with the majority of 
these two groups assessing that airline staffs’ knowledge was poor (4) or fair (5). 

February 2021 | 56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

What is your opinion about the level of knowledge of groundhandling staff on the specific 
needs of PRM?  

Figure A.21: Level of agreement on the statement above 

Table A.21: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

3 

1 

4 

- 

- 

4 

3 

1 

- 

- 

- 

- 

3 

1 

- 

- 

- 

1 

1 

- 

- 

- 

1 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

1 

Responses 

I do not 
know 

Poor 

Fair 

Good 

Excellent 

Total 

1 

7 

4 

11 

3 

A.22 

As previously, the majority of respondents (14) stated that the knowledge of groundhandling 
staff on the specific needs of PRM was good (11) or excellent (3). Likewise, there was 
significant disagreement between citizens and PRM representatives, with the majority of these 
two groups assessing that groundhandlers’ knowledge was poor (7) or fair (4). These two 
groups were more critical of groundhandling staff than either airport or airline staff. 

February 2021 | 57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

In your opinion, what have been the main benefits of the Regulation? (e.g. easier access to 
terminals and means of transport, accessible information and equal opportunities as other 
citizens when travelling by air)? 

A.23 

Overall, stakeholders were positive and noted an improvement in PRM-access to aviation and 
clarity on the rights for PRMs and obligations of service providers. The pressure placed on 
airlines and airports by the Regulation to ensure adequate service quality of the PRM 
assistance service has led to an improvement in service quality. 

In your opinion what have been the main negative aspects of the Regulation (e.g. costs, 
higher administrative burden, duration of pre-notification notice, more complex complaint 
procedures, etc.), and who is affected by them? 

A.24 

A variety of negative impacts were highlighted by different stakeholder groups: 

  Airlines assessed that the definition of PRM and the Regulation’s scope is very broad and 
that some customers request assistance for reasons that are not intended under the 
Regulation. This negatively impacts waiting times for PRMs and service quality. This view 
is shared by other responding stakeholders and it is suggested that better human 
resourcing and clarity in definition of PRMs and Regulation scope may be suitable 
methods to resolve this.  
PRM representatives highlighted that the need to pre-notify to guarantee assistance is 
onerous and efforts to pre-notify are not always successful, thus inhibiting the 
spontaneity for travel by air for PRMs who may be reluctant to risk the possibility of not 
receiving assistance. This limits the extent to which PRMs have comparable options to 
travel by air. 

 

February 2021 | 58 

 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

In your opinion, is the Regulation properly applied in your Member State? 

Figure A.22: Level of agreement on the statement above 

Table A.22: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

4 

1 

4 

M
R
P

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

6 

3 

2 

Responses 

No 

I don't 
know 

Yes 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

- 

1 

4 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

- 

2 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

1 

4 

Total 

10 

6 

22 

A.25 

There was significant disagreement between PRM representatives and other groups in their 
assessment of whether the Regulation was correctly applied, with a majority of the former (6) 
assessing that the Regulation was not applied correctly. Citizens were also divided on this 
question. Nevertheless, the majority of respondents (22) assessed that the Regulation is 
correctly applied, with all airlines, airports, NEBs, passenger representatives and 
groundhandlers to express a view assessing that this was the case. 

February 2021 | 59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Have you experienced differences in the way the Regulation is implemented from one 
Member State to another? 

Figure A.23: Level of agreement on the statement above 

Table A.23: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

1 

3 

5 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

- 

6 

5 

Responses 

No 

No 
opinion 

Yes 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

2 

2 

1 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

3 

- 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

1 

- 

Total 

5 

21 

15 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

- 

5 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

2 

1 

4 

A.26 

The majority of respondents (21) did not have an opinion as to whether they have experienced 
differences in implementation across Member States. Nevertheless, of those to state a view, 
the majority (15 of 20) assessed that differences did exists in the Regulation’s implementation 
across Europe, with citizens (5 of 9) and airlines (4 of 7) being particularly likely to support this 
view.  

February 2021 | 60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Have you ever submitted a complaint to a NEB? 

Figure A.24: Level of agreement on the statement above 

Table A.24: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

6 

1 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

5 

2 

Responses 

No 

Yes 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

3 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

1 

1 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

- 

- 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

1 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

- 

Total 

16 

5 

A.27 

The vast majority of respondents (16) have not submitted a complaint to a NEB. Of those 
respondents who have submitted a complaint (5), 2 were PRM representatives with the 
remainder from citizens, airports and one passenger representative. 

February 2021 | 61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Sub-question 1: If yes, to what extent do you agree/disagree with the following 
statements?: It was easy to find the competent NEB 

Figure A.25: Level of agreement on the statement above 

Table A.25: Breakdown of responses 

R
e
s
p
o
n
s
e
s

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Strongly disagree 

Somewhat disagree 

No opinion / not 
sure 

Somewhat agree 

Strongly agree 

- 

1 

- 

- 

- 

- 

1 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

T
o
t
a

l

- 

2 

- 

2 

1 

A.28 

Of those who submitted a complaint (5) the majority (3) of respondents noted positively that 
they somewhat (2) or strongly (1) agree that it was easy to find the competent NEB. No 
respondent strongly disagreed with this statement. 

February 2021 | 62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Sub-question 2: If yes, to what extent do you agree/disagree with the following 
statements?: The process of submission of my complaint was easy 

Figure A.26: Level of agreement on the statement above 

Table A.26: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

- 

1 

- 

- 

- 

- 

1 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

3 

- 

- 

2 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.29 

The majority of those who submitted a complaint found the process of submitting a complaint 
was not easy (3), responding somewhat disagree. This opinion was made up of responses from 
citizens (1), PRM (1) and passenger representatives (1). Stakeholders who found a complaint 
easy to submit was made up of PRM representatives (1) and airports (1). 

February 2021 | 63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Sub-question 3: If yes, to what extent do you agree/disagree with the following 
statements?: The NEB has an easy-to-use complaint form 

Figure A.27: Level of agreement on the statement above 

Table A.27: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

- 

1 

- 

- 

- 

- 

1 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

2 

- 

3 

- 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.30 

Of those who filed a complaint, most (3) found that the NEB had an easy to use complaint 
form.  

February 2021 | 64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Sub-question 4: If yes, to what extent do you agree/disagree with the following 
statements?: I received a fast reply to my complaint 

Figure A.28: Level of agreement on the statement above 

Table A.28: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

- 

- 

- 

1 

- 

- 

- 

- 

2 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

3 

1 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.31 

None of the respondents disagreed that they had a fast reply to their complaint, with all those 
who gave an opinion stating that they somewhat (3) or strongly agree (1) with this statement. 

February 2021 | 65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

Sub-question 5: If yes, to what extent do you agree/disagree with the following 
statements?: I agree with the way my complaint was handled   

Figure A.29: Level of agreement on the statement above 

Table A.29: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

Total 

1 

- 

- 

- 

- 

- 

- 

- 

1 

1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

1 

- 

1 

1 

2 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.32 

Of those respondents who filed a complaint, the majority somewhat (1) or strongly agreed (2) 
that they agreed with how their complaint was handled. One EU-citizen was the only 
respondent to strongly disagree with how their complaint was handled.  

February 2021 | 66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

To what extent do you agree/disagree that the tasks of NEBs are clear? 

Figure A.30: Level of agreement on the statement above 

Table A.30: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

- 

4 

3 

1 

- 

3 

2 

6 

- 

- 

- 

3 

3 

1 

1 

- 

- 

- 

4 

- 

- 

1 

3 

1 

- 

- 

- 

2 

1 

- 

- 

- 

- 

1 

Total 

2 

3 

10 

17 

9 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.33 

A majority of all stakeholder groups assessed that the tasks of the NEBs are clear, with 17 
respondents somewhat agreeing and 9 strongly agreeing with the statement. Disagreement 
was reserved primarily to PRM representatives, albeit only 3. 

February 2021 | 67 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the EU framework for passenger rights                               PART A - Evaluation of Regulation (EC) No 1107/2006 on the 
rights of persons with disabilities and with reduced mobility when travelling by air | Stakeholder Consultation Report 

To what extent do you agree/disagree that coordination of NEBs at the European level is 
satisfactory? 

Figure A.31: Level of agreement on the statement above 

Table A.31: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

1 

4 

3 

- 

- 

2 

8 

- 

1 

- 

1 

5 

- 

1 

- 

1 

- 

- 

4 

- 

- 

1 

3 

1 

1 

- 

2 

- 

- 

- 

- 

1 

- 

- 

Total 

2 

5 

21 

6 

7 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.34 

The largest proportion of responses (21 out of 41) stated that they have no opinion or are 
unsure that coordination of NEBS at the European level is satisfactory. Nevertheless, a slim 
majority (13) of those to express a view (20) assessed that coordination of NEBs at a European 
level is satisfactory. 

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To what extent do you agree/disagree that the NEBs contribute to the correct application of 
the Regulation throughout the EU? 

Figure A.32: Level of agreement on the statement above 

Table A.32: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

1 

3 

2 

2 

- 

3 

3 

3 

2 

- 

- 

2 

3 

2 

- 

1 

- 

- 

4 

- 

- 

1 

3 

1 

- 

1 

- 

1 

1 

- 

- 

1 

- 

- 

Total 

1 

6 

10 

12 

12 

Responses 

Strongly 
disagree 

Somewhat 
disagree 

No 
opinion / 
not sure 

Somewhat 
agree 

Strongly 
agree 

A.35 

The majority of respondents to state an opinion (24 of 31), either assessed that NEBs 
contribute to the correct application of the Regulation throughout Europe. Of the 7 
stakeholders to disagree, 5 were citizens and PRM representatives. There was disagreement 
between stakeholders within each of these two stakeholder groups.  

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Do you consider any provisions in the Regulation are unclear and/or interpreted differently 
by carriers and/or NEBs? 

Figure A.33: Level of agreement on the statement above 

Table A.33: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

3 

4 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

- 

3 

8 

Responses 

No 

No 
opinion 

Yes 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

2 

2 

3 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

1 

3 

1 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

- 

1 

2 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

1 

- 

- 

Total 

8 

14 

19 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

2 

2 

1 

A.36 

The majority of respondents (19) consider that the Regulation contains provisions which are 
unclear and/or are open to interpretation, although this response is driven by the large 
number of PRM representatives and citizens in the sample. There was disagreement between 
stakeholders within the airport and airline groups. Stakeholders highlighted several provisions 
which could be clarified further:   

  Definitions and charges associated with recognized assistance dogs; 
  Definitions and charges associated with the carriage of medical equipment; 
 

The safety conditions applied by airlines in instances of denied boarding; and 

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Do you consider any provisions in the Regulation are obsolete?  

Figure A.34: Level of agreement on the statement above 

Table A.34: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

2 

4 

3 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

- 

7 

4 

Responses 

No 

No 
opinion 

Yes 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

1 

4 

2 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

3 

- 

2 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

1 

1 

1 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

1 

- 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

2 

2 

1 

Total 

9 

19 

13 

A.37 

The majority of respondents (19) had no opinion on whether any of the Regulation’s 
provisions are obsolete. Nevertheless, the majority of those to express a view (13 of 22) 
considered that some provisions were obsolete, assessing that: 

 

The Regulation needs to be updated to account for the “digitalisation of the journey” as 
this has impacted the booking procedure as well as the treatment and expectations of the 
passenger; and 

  A greater focus on passenger-dignity should also be considered.  

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Are there any other issues related to the transport of persons with disabilities and persons 
with reduced mobility by air which you consider should be tackled? 

Figure A.35: Level of agreement on the statement above 

Table A.35: Breakdown of responses 

d
n
a
U
E
(

s
n
e
z
i
t
i
C

)

U
E
-
n
o
n

3 

2 

4 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

M
R
P

- 

1 

10 

Responses 

No 

No 
opinion 

Yes 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
e
n

i
l
r
i
A

1 

2 

4 

r
e
b
m
e
M

/
s
B
E
N

s
e
t
a
t
S

3 

1 

1 

s
e
v
i
t
a
t
n
e
s
e
r
p
e
r

r
e
g
n
e
s
s
a
P

1 

- 

2 

l

s
r
e
d
n
a
h
d
n
u
o
r
G

s
n
o
i
t
a
i
c
o
s
s
a
/

- 

- 

1 

s
n
o
i
t
a
i
c
o
s
s
a

/
s
t
r
o
p
r
i
A

1 

2 

2 

Total 

9 

8 

24 

A.38 

A majority (24) of respondents noted that there are other issues which should be tackled: 

  A general lack of support for persons with visual impairments, e.g. lack of tactile devices 

on aircraft and airports; 

  Accessibility of airline and airport websites; 
 

Two airlines and airports highlighted that the scope of the Regulation is too broad with 
respect to the definition of PRMs; and 
Some stakeholders assessed that the availability of information specifically with respect to 
COVID-19 is insufficiently accessible. 

 

A.39 

The Regulation’s silence on the topic of aircraft and airport accessibility was also noted. 

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B  GDPR privacy notice 

EUROPEAN COMMISSION 

PROTECTION OF YOUR PERSONAL DATA 

Processing operation: Targeted consultation activities (including surveys, interviews and focus 
groups)  

Data Controller: Directorate-General for Mobility and Transport, Directorate B, Unit B5 – 
Social aspects, passenger rights and equal opportunities 

Record reference:  DPR- EC-111  

Table of Contents 

1. 

Introduction 

2.  Why and how do we process your personal data? 

3.  On what legal ground(s) do we process your personal data? 

4.  Which personal data do we collect and further process? 

5.  How long do we keep your personal data? 

6.  How do we protect and safeguard your personal data? 

7.  Who has access to your personal data and to whom is it disclosed? 

8.  What are your rights and how can you exercise them?  

9.  Contact information 

10. Where to find more detailed information? 

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1. 

Introduction 

The European Commission (hereafter ‘the Commission’) is committed to protect your personal 
data and to respect your privacy. The Commission collects and further processes personal data 
pursuant to Regulation (EU) 218/1725 of the European Parliament and of the Council of 
23 October 218 on the protection of natural persons with regard to the processing of personal 
data by the Union institutions, bodies, offices and agencies and on the free movement of such 
data (repealing Regulation (EC) No 45/21). 

This privacy statement explains the reason for the processing of your personal data, the way 
we collect, handle and ensure protection of all personal data provided, how that information is 
used and what rights you have in relation to your personal data. It also specifies the contact 
details of the responsible Data Controller with whom you may exercise your rights, the Data 
Protection Officer and the European Data Protection Supervisor. 

This privacy statement concerns the processing operation ‘Targeted consultation activities’, 
undertaken by the Commission Directorate-General for Mobility and Transport, Directorate B, 
Unit B5 – Social aspects, passenger rights and equal opportunities as presented below.  

2.  Why and how do we process your personal data? 

Purpose of the processing operation: The European Commission collects and uses your 
personal information within the framework of targeted consultation activities.  

More specifically, this concerns the following processing activities: 

 ● obtain the views of the respondents of the targeted consultation activity. In view of the 
design, evaluation and revision of initiatives it is indispensable for the Commission to receive 
input and views from those who are considered to be concerned by the policy or initiative. 

 ●to obtain the views of stakeholders to explore a subject for which very limited information is 
available. This exploratory targeted consultation activity (hereafter, 'targeted consultation') 
will provide further information to the Commission necessary to take basic conceptual 
decisions.  

For reasons of transparency and openness, in principle, your views will be published on a 
Europa website, in the form of a summary report, or included in a wider policy document. 
Your identity is only published together with your contribution if you consent to the 
publication of your identity.  

The subject matter of the consultation activity requires you to provide personal data in your 
response. These personal data will only be published subject to your explicit consent.  

It is your responsibility if you opt for confidentiality of your personal data to avoid any 
reference in your submission or contribution that would reveal your identity. 

To avoid misuse, anonymous contributions to the consultation activity may not be accepted. 

The personal data processed may be reused for the purpose of procedures before the EU 
Courts, national courts, the European Ombudsman or the European Court of Auditor. 

Your personal data will not be used for an automated decision-making including profiling. 

3.  On what legal ground(s) do we process your personal data 

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We process your personal data, because: 

(a) processing is necessary for the performance of a task carried out in the public interest; 

(b) processing is necessary for compliance with a legal obligation to which the controller is 
subject; 

(d) it is based on your consent, for one or more specified purposes: 

  Publication of the identity of the stakeholder or respondent; 
 

If  the  subject  matter  of  a  targeted  consultation  requires  respondents  to  provide 
personal data in their response, their publication; 
if applicable, the processing of special categories of personal data. 

 

The Union law which is the basis for the processing based on Articles 5(1)(a) and (b) of 
Regulation (EU) 218/1725 is the Treaty of the European Union, and more specifically its 
Articles 1 and 11, Article 298 of the Treaty on the Functioning of the European Union, read in 
conjunction with Recital 22 of Regulation (EU) 218/1725), as well as the Protocol 2 on the 
application of the principles of subsidiarity and proportionality.  

4. 

 Which personal data do we collect and further process?  

In order to carry out this processing operation the Data Controller collects the following 
categories of personal data: 

job title,  
e-mail address of the respondent, 

  name and surname, 
 
 
  Professional telephone number of the respondent, 
  Name of the organisation on whose behalf the respondent is contributing, 
  personal data included in the response or contribution to the targeted consultation (if 

the targeted consultation at hand requires so). 

Furthermore, you may spontaneously provide other, non-requested personal data in the 
context of your reply to the targeted consultation. 

5.  How long do we keep your personal data? 

The Data Controller only keeps your personal data for the time necessary to fulfil the purpose 
of collection or further processing, namely for a maximum of five years after the closure of the 
file to which the present targeted consultation belongs. A file is closed at the latest once there 
has been a final outcome in relation to the initiative to which the targeted consultation 
contributed. This retention period is without prejudice to an earlier elimination of personal 
data not part of the file or cases of administrative elimination. 

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This administrative retention period of five years is based on the retention policy of European 
Commission documents and files (and the personal data contained in them), governed by the 
common Commission-level retention list for European Commission files SEC(219)9. It is a 
regulatory document in the form of a retention schedule that establishes the retention periods 
for different types of European Commission files. That list has been notified to the European 
Data Protection Supervisor. 

The administrative retention period is the period during which the European Commission 
departments are required to keep a file depending on its usefulness for administrative 
purposes and the relevant statutory and legal obligations. This period begins to run from the 
time when the file is closed. 

In accordance with the common Commission-level retention list, after the ‘administrative 
retention period’, files including (the outcome of) targeted consultations (and the personal 
data contained in them) can be transferred to the Historical Archives of the European 
Commission for historical purposes (for the processing operations concerning the Historical 
Archives, please see notifications DPO-153.4 ARES-NOMCOM. ARES (Advanced Records 
System) et NOMCOM (Nomenclature Commune), DPO-3871-3 Notification for the digital 
archival repository and ARCHISscanning' and 'DPO-286-5 Gestion des dossiers papier 
structurés par nom de personnes et transférés aux Archives Historiques'.). 

6.  How do we protect and safeguard your personal data? 

All personal data in electronic format (e-mails, documents, databases, uploaded batches of 
data, etc.) are stored on the servers of the European Commission (or of its contractors 
(processors), if contractors are engaged to assist the controller). All processing operations are 
carried out pursuant to Commission Decision (EU, Euratom) 217/46 of 1 January 217 on the 
security of communication and information systems in the European Commission. 

In order to protect your personal data, the Commission has put in place a number of technical 
and organisational measures. Technical measures include appropriate actions to address 
online security, risk of data loss, alteration of data or unauthorised access, taking into 
consideration the risk presented by the processing and the nature of the personal data being 
processed. Organisational measures include restricting access to the personal data solely to 
authorised persons with a legitimate need to know for the purposes of this processing 
operation. 

If the controller uses (a) contractor(s) (processor(s)) to assist the controller, this will be 
indicated in the specific privacy statement and the following paragraph will be provided: 

The Commission’s processors (contractors) are bound by a specific contractual clause for any 
processing operations of your personal data on behalf of the Commission. The processors have 
to put in place appropriate technical and organisational measures to ensure the level of 
security, required by the Commission. 

7.  Who has access to your personal data and to whom is it disclosed? 

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Access to your personal data is provided to the Commission staff responsible for carrying out 
this processing operation and to authorised staff according to the “need to know” principle, in 
particular to follow-up on the targeted consultation. Such staff abide by statutory, and when 
required, additional confidentiality agreements. 

Certain personal data may be made public on the Europa website, namely: 

  any personal data on which you consented to their publication; 
  personal  data  spontaneously  provided  by  you  in  your  contribution  (without  it  being 

required by the consultation activity. 

 Please note that pursuant to Article 3(13) of Regulation (EU) 218/1725 public authorities (e.g. 
Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a 
particular inquiry in accordance with Union or Member State law shall not be regarded as 
recipients; the processing of those data by those public authorities shall be in compliance with 
the applicable data protection rules according to the purposes of the processing.  

The information we collect will not be given to any third party, except to the extent and for 
the purpose we may be required to do so by law. 

8.  What are your rights and how can you exercise them?  

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 
218/1725, in particular the right to access your personal data and to rectify them in case your 
personal data are inaccurate or incomplete. Under certain conditions, you have the right to 
erase your personal data, to restrict the processing of your personal data, to object to the 
processing and the right to data portability. 

You have the right to object to the processing of your personal data, which is lawfully carried 
out pursuant to Article 5(1)(a), on grounds relating to your particular situation. 

Insofar you have consented to the certain processing of your personal data to the Data 
Controller for the present processing operation, you can withdraw your consent at any time by 
notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing 
carried out before you have withdrawn the consent. 

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data 
Protection Officer. If necessary, you can also address the European Data Protection Supervisor. 
Their contact information is given under Heading 9 below.  

Where you wish to exercise your rights in the context of one or several specific processing 
operations, please provide their description (i.e. their Record reference(s) as specified under 
Heading 1 below) in your request. 

Any request for access to personal data will be handled within one month. Any other request 
mentioned above will be addressed within 15 working days. 

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9.  Contact information 

-  The Data Controller 

If you would like to exercise your rights under Regulation (EU) 218/1725, or if you have 
comments, questions or concerns, or if you would like to submit a complaint regarding the 
collection and use of your personal data, please feel free to contact the Data Controller.  

European Commission, Directorate-General for Mobility and Transport, Directorate B, Unit B5 
– Social aspects, passenger rights and equal opportunities at move-pr-evaluation-
studies@ec.europa.eu. 

-  The Data Protection Officer (DPO) of the Commission 

You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) 
with regard to issues related to the processing of your personal data under Regulation (EU) 
218/1725. 

-  The European Data Protection Supervisor (EDPS) 

You have the right to have recourse (i.e. you can lodge a complaint) to the European Data 
Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under 
Regulation (EU) 218/1725 have been infringed as a result of the processing of your personal 
data by the Data Controller. 

10. Where to find more detailed information? 

The Commission Data Protection Officer (DPO) publishes the register of all processing 
operations on personal data by the Commission, which have been documented and notified to 
him. You may access the register via the following link: http://ec.europa.eu/dpo-register. 

This specific processing operation has been included in the DPO’s public register with the 
following Record reference: DPR-EC-111.1 

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C  Targeted questionnaires  

NEBs 

Table C.1: Targeted questionnaire for NEBs 

Questions 

Background Information 

1 

2 

3 

4 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

Please briefly describe the activity of your organisation and in 
particular whether you are the NEB for Regulation 1107/2006 
only, or whether you enforce other passenger rights legislation 
also.  

Please indicate whether you are part of larger organisation (e.g. 
civil aviation authority, ministry etc.). 

Are other NEBs involved for enforcement in this area in your 
Member State? 

Do you deal with (and help resolve) individual passenger 
complaints or only carry out system-level enforcement?  Are your 
decisions binding? 

Do you act as an appeal body only so that passengers have to 
complain to the airline/airport first? 

Are you an ADR? If not, what is your relationship with ADR 
bodies? 

How would you describe the level of cooperation between NEBs 
within your Member State and with NEBs in other Member 
States? 

What information on PRM rights do you provide online? Could you please provide 
a link? Please also identify any specific information you offer on how PRMs can 
seek redress or submit a complaint to the NEB and what they should expect (e.g. 
timeframe for receiving a response). 

Please provide the following data, if available (where possible, for the years 2006 
to 2019): 

a) 

The proportion of traffic covered by the Regulation. 

Please 
explain:  

a) 

how you monitor that PRM passengers are kept informed about 
their journey before, during and after travel in 
appropriate/accessible formats. 

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b) 

c) 

d) 

e) 

f) 

g) 

how you ensure that carriers do not unlawfully refuse 
embarkation/reservation by PRMs on safety grounds or other 
reasons (including requiring PRM passengers to be accompanied). 

how you ensure that carriers do not unlawfully refuse 
embarkation/reservation by PRMs on the grounds that the design 
of the aircraft or airport infrastructure is not adequate (or 
sufficient equipment (e.g. ambulifts) is not available). 

how you monitor what mechanisms are provided to enable PRMs 
to notify requirements for assistance at points of sale. 

how you monitor the mechanisms carriers have put in place to 
notify airports and/or PRM service providers in advance of 
requirements for assistance. 

how you monitor that PRMs are informed about their rights. How 
you inform passengers about their rights (e.g. information 
campaigns) and in what languages and formats (e.g. accessible). 

how you monitor what communication systems terminal 
managing bodies have in place for PRMs to notify their arrival 
and need for assistance. 

How many Regulation 1107/2006-related complaints have you received annually? 
What are the main types of complaint (e.g. denied boarding, airport waiting 
times, lost or damaged mobility equipment)? 
Do you think this reflects the real number of cases?  If not, what are, in your 
opinion, the reasons for the low number of complaints compared to the real 
number of cases? 

Please explain your process for handling complaints from passengers on issues 
relating to Regulation 1107/2006? How do you liaise with airlines, airports and 
service providers? What processes do you have in place (e.g. webform), how long 
do you take to respond to complaints? What languages do you accept complaints 
in? Is the process free, accessible, and easy to use for passengers? 

To what extent have your complaint handling procedures changed since the 
Regulation came into force in 2008? 

What measures are in place to ensure that PRMs can make a complaint to a 
carrier, airport, other service provider, and/or NEB, and that the complaint is 
adequately addressed without undue delays and complications for PRM? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And going forward? Please distinguish between: 

a) 

General technological changes 

February 2021 | 80 

5 

6 

7 

8 

Relevance 

9 

10 

 
  
  
  
  
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b) 

c) 

d) 

Changes affecting the aviation sector 

Changes affecting PRMs (e.g. social, population, legal) 

Other developments. 

Effectiveness 

11 

12 

13 

14 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

 Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

What do you think the impact of EU PRM legislation has been on airlines' and 
airports' operations; – for example, have carriers changed their seating policies, 
or have airports changed their level of staffing? Please explain. 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

b) 

c) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly 
complaint procedures? 

the service quality that airlines and airports deliver to 
passengers? 

Please explain how your enforcement processes are working? What is the process 
for issuing sanctions related to Regulation1107/2006? 

In addition: 

a) 

b) 

c) 

d) 

What evidence do you require passengers and performing parties 
to provide? 

How many financial sanctions you have imposed? What was the 
amount of these penalties? Have these penalties been paid? 
Have you issued any non-financial sanctions? Do you consider 
that sanctions are effective, dissuasive and proportional? 

How do you think that sanctions affect the reputation of carriers, 
airports or other service providers? 

Is enforcement of carriers not registered in your Member State 
effective? 

Cost efficiency 

15 

What costs (financial and non-financial) do you incur in order to assist PRMs as a 
result of the Regulation?  How does this compare to the situation before the 
Regulation’s implementation? 

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In particular 

a) 

b) 

c) 

What was the total cost associated with Regulation 1107/2006 
for your organisation for each year 2006-2019?  

How are these costs split between costs of complaint-handling, 
costs of monitoring, cost of enforcement? 

How many staff (in FTEs) do you employ? 

What benefits do you think the Regulation has generated for PRMs and for 
airlines or airports (e.g. do carriers benefit from increased demand, increased 
market share, other)?  

Do you think the costs (compliance, administrative, legal) are proportionate to 
the benefits of the Regulation? Could the objectives of the Regulation have been 
achieved at lower cost? If so, how? 

Is there any potential for reducing costs for the NEB without affecting its 
performance with respect to handling passenger complaints, or its monitoring 
and enforcement activity? 

How have you cooperated with NEBs in other Member States to monitor carriers 
with international/EU-wide operations? Were good results achieved? Is there 
potential for this to be made more cost efficient? 

To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

In your view, what is the relationship, if any, between Regulation 1107/2006 and: 

a) 

b) 

c) 

d) 

the Package Travel Directive ? Are there any overlaps, gaps or 
inconsistencies? 

the Groundhandling Directive ? Do you see any overlaps, gaps or 
inconsistencies? 

Directive on airport charges? Do you see any overlaps, gaps or 
inconsistencies? 

Regulation (EC) 261/2004 on air passenger rights? Are there any 
overlaps, gaps or inconsistencies? 

Is there coherence with the wider relevant transport policy framework, for 
example in respect of safety and security (e.g. EASA decision 2016/004/R on 
Special Category Passengers), accessibility, other modes or national legislation? 
Are there any overlaps, gaps or inconsistencies, and if so what are the impacts of 
these? 

In your view, to what extent are the requirements of Regulation 1107/2006 
coherent and consistent with other EU interventions/initiatives or legislation, for 
example in respect of non-discrimination, accessibility, EU consumer policy, policy 
towards persons with disabilities and competition policy?  

16 

17 

18 

19 

Coherence 

20 

21 

22 

23 

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24 

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO regulations, 
EU's external transport policy, and agreements with third countries (e.g. the 
equivalent requirements for the US, Canada or other countries)?  

Value added 

25 

Good practices 

What is the value-added resulting from the Regulation 1107/2006 compared to 
any pre-existing or subsequent national legislation, or compared to what could be 
achieved at national level? 

26 

Do you have examples of good practice, guidelines or other guidance, minimum 
standards, contingency plans available in respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

The information about and service quality of assistance for 
PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to 
provide assistance with regard to the passengers' immediate 
practical needs following such an incident?  

Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

NEB structures or practices in terms of dealing with complaints, 
cooperating with other NEBs, monitoring cross-border operators, 
performing ADR functions, etc.? Good practices to incentivise a 
full application, to avoid circumvention (if any) and to have an 
effective, proportionate and persuasive enforcement? Types of 
sanction regimes that have proven to be good practice in this 
regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

Addressing the interaction between the Regulation 1107/2006 
and the Package Travel Directive (2015/2302)? 

27 

Can you provide any other examples of good practice, guidelines or other 
guidance, minimum standards, contingency plans available, including from non-
European countries? 

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28 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h)  

i) 

j) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to avoid offering discriminatory contract conditions, 
including for PRM access, or any direct or indirect discrimination 
based on residency of the final customer or on the place of 
establishment of the carriers, or ticket vendors? 

How to reimburse passengers quickly and with a minimum of 
administrative burden, when the trip is not carried out as 
planned? 

How to fulfil the obligation of rerouting and rebooking effectively 
and efficiently?  

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

How to quickly and easily establish whether the carrier is 
responsible for a certain travel disruption or whether it can be 
exempted from its obligation to pay compensation due to 
extraordinary circumstances? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations? 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

Other 

29 

30 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

Do you have any other comments?  

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Airlines 

EU Airlines 

Table C.2: Targeted questionnaire for EU Airlines 

Questions 

Background Information 

1 

2 

3 

Is your PRM customer policy (including safety rules) available online? If so, please 
provide a link? If not, please send us a copy? Please explain: 

a) 

b) 

Whether your PRM policies are reviewed and/or approved by a 
NEB, national safety regulator or by EASA. 

what safety-related information you request from PRMs to make 
an adequate safety assessment before the flight (i.e. type of 
battery, degree of mobility on board, etc.). Who (airline, travel 
agent, ground-handling agent, other party) makes this 
assessment and at which point of the journey (booking, pre-
notification, check-in, gate, etc.)? 

What training do you provide to your staff to ensure compliance with the 
Regulation?  

Please provide the following data, if available (where possible, for the years 2006 
to 2019): 

a) 

b) 

c) 

d) 

e) 

Total number of flights and total number of passengers carried 
(all passengers). 

The number of PRMs who were denied boarding on safety 
grounds and the reasons (as communicated to passengers).  

Total number of PRMs carried, by type of PRM passenger (based 
on IATA SSR codes or similar). 
Total number of wheelchair assistance provided. 

How many checked items of mobility aids (e.g. wheelchairs, 
scooters etc) were carried? How many items of checked mobility 
aids were lost, damaged or delayed? 
How many items of medical equipment were carried in addition 
to the mobility aids? 

The proportion of PRMs who pre-notified? How long before 
travel was pre-notification provided?  
How consistent in practice is the pre-notified PRM classification 
with the assistance needs of PRMs? 
The proportion of PRM who pre-notified technical information of 
the mobility aids (dimensions, manual of battery powered aid 
etc.). 

4 

Please 
explain:  

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a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

how you ensure that PRMs are kept informed about their journey 
before, during and after travel in appropriate/accessible formats. 

what the most frequent situations are, if any, when you are 
forced to refuse embarkation/reservation by PRM on safety 
grounds or other reasons, or ask them to be accompanied by a 
safety assistant 

what the most frequent situations are, if any, when you are 
forced to refuse embarkation/reservation by PRM on the grounds 
that the design of the aircraft or airport infrastructure is not 
adequate (or sufficient equipment (e.g. ambulifts) is not 
available). 

what mechanisms you provide to enable PRMs to notify 
requirements for assistance at points of sale (please distinguish 
between direct sales and sales via an intermediary such as a 
travel agent, tour operator or other organisation). 

the mechanisms you have put in place to notify airports and/or 
PRM service providers in advance of requirements for assistance. 

any specific PRM requirements your organisation/members may 
have (such as maximum number of PRMs per flight, need to be 
accompanied, etc). 

how you ensure that PRMs are informed about their rights (in 
appropriate/accessible formats). 

whether you provide refunds or rerouting where PRM 
embarkation is refused and how this is organised. 

5 

6 

7 

8 

Relevance 

9 

How many Regulation 1107/2006-related complaints have you received annually 
and what are the main types of complaint? How many are resolved at your level? 

Please explain your process for handling complaints from passengers on issues 
relating to Regulation 1107/2006? How do you liaise with airports and service 
providers? What processes do you have in place (e.g. webform), how long do you 
take to respond to complaints? What languages do you accept complaints in? Is 
the process free, accessible, and easy to use for passengers? 

To what extent have your complaint handling procedures changed since the 
Regulation came into force in 2008? 

What mechanisms do you have in place for monitoring standards? Have you 
undertaken any surveys of the satisfaction of passengers with the services they 
receive? Do you have any evidence of how different PRM groups (e.g. wheelchair 
users, partially sighted passengers, etc.) are satisfied with the services they 
receive? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

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10 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And in the future? Please distinguish between: 

a) 

b) 

c) 

d) 

General technological changes 

Changes affecting the aviation sector 

Changes affecting PRMs (e.g. social, population, legal).   

Other developments. 

Effectiveness 

11 

12 

13 

14 

15 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

 Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

Has EU PRM legislation had any impact on your operations – for example, 
turnaround times and boarding procedures, seating policies or the use of 
equipment on board? 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

b) 

c) 

d) 

e) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly 
complaint procedures? 

 the service quality that you deliver to PRMs (including the 
handling of mobility aids)? 

your operating costs? 

your fares (for all passengers)? 

How satisfied are you with the activities, powers and skills of the National 
Enforcement Bodies (NEBs) with which you have contact? 

How well do you think that the NEB complaints-handling and enforcement 
processes are working? Have you ever been inspected/audited by an NEB? Have 
you ever been sanctioned by a NEB for issues related to Regulation 1107/2006? If 
so,  

In addition: 

a) 

Please explain the reasons. Were you able to provide evidence to 
support your case? 

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b) 

c) 

Please explain what financial penalties you incurred as a result. 
Have these penalties been paid? Do you consider that sanctions 
are effective, dissuasive and proportional? 

Did the sanction affect your reputation? 

Cost efficiency 

16 

17 

18 

19 

Coherence 

20 

21 

What costs (financial and non-financial) do you incur in order to assist PRMs as a 
result of the Regulation?  How does this compare to the situation before the 
Regulation’s implementation? 

In particular 

a) 

b) 

c) 

d) 

e) 

f) 

What was the total cost associated with Regulation 1107/2006 
for your organisation for each year 2006-2019?  

How are these costs split between costs of compensation, 
administrative costs, and costs of refund or rerouting (if relevant 
under 1107/2006 – e.g. for denied boarding due to a change in 
aircraft type that cannot accommodate the mobility equipment)? 

How PRM charges are set by airports (process, consultation, KPIs, 
etc)?  

How have PRM charges evolved at the main airports where you 
operate? 

Have you undertaken any analysis of whether the charges levied 
by airports for PRM services are cost-reflective, as required by 
the Regulation?  

Are NEBs and/or Airport Charges ISAs (if relevant) involved with 
overseeing PRM charges? 

If relevant, what benefits do you receive as a result of the Regulation (increased 
demand, increased market share, other)?  

Do you think the costs (compliance, administrative, legal) are proportionate to 
the benefits of the Regulation? Could the objectives of the Regulation have been 
achieved at lower cost? If so, how? 

Is there any potential for reducing costs without affecting the service provided to 
passengers? 

To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

In your view, what is the relationship, if any, between Regulation 1107/2006 and: 

a) 

the Package Travel Directive ? Are there any overlaps, gaps or 
inconsistencies? 

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b) 

c) 

d) 

Groundhandling Directive ? Do you see any overlaps, gaps or 
inconsistencies? 

Directive on airport charges? Do you see any overlaps, gaps or 
inconsistencies? 

Regulation (EC) 261/2004 on air passenger rights? Are there any 
overlaps, gaps or inconsistencies? 

Is there coherence with the wider relevant transport policy framework, for 
example in respect of safety and security (e.g. EASA decision 2016/004/R on 
Special Category Passengers), accessibility, other modes or national legislation? 
Are there any overlaps, gaps or inconsistencies, and if so what are the impacts of 
these? 

In your view, to what extent are the requirements of Regulation 1107/2006 
coherent and consistent with other EU interventions/initiatives or legislation, for 
example in respect of non-discrimination, accessibility, EU consumer policy, policy 
towards persons with disabilities and competition policy?  

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO regulations, 
EU's external transport policy, and agreements with third countries (e.g. the 
equivalent requirements for the US, Canada or other countries)?  

What is the value-added resulting from the Regulation 1107/2006 compared to 
any pre-existing or subsequent national legislation, or compared to what could be 
achieved at national level? 

22 

23 

24 

Value added 

25 

Good practices 

26 

Do you have examples of good practice, guidelines or other guidance, minimum 
standards, contingency plans available in respect of: 

a) 

b) 

c) 

d) 

e) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

The information about and service quality of assistance for 
PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to 
provide assistance with regard to the passengers' immediate 
practical needs following such an incident?  

Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

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f) 

g) 

h) 

NEB structures or practices in terms of dealing with complaints, 
cooperating with other NEBs, monitoring cross-border operators, 
performing ADR functions, etc.? Good practices to incentivise a 
full application, to avoid circumvention (if any) and to have an 
effective, proportionate and persuasive enforcement? Types of 
sanction regimes that have proven to be good practice in this 
regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

Addressing the interaction between the Regulation 1107/2006 
and the Package Travel Directive (2015/2302)? 

27 

28 

Can you provide any other examples of good practice, guidelines or other 
guidance, minimum standards, contingency plans available, including from non-
European countries? 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h)  

i) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to avoid offering discriminatory contract conditions, 
including for PRM access, or any direct or indirect discrimination 
based on residency of the final customer or on the place of 
establishment of the carriers, or ticket vendors? 

How to reimburse passengers quickly and with a minimum of 
administrative burden, when the trip is not carried out as 
planned? 

How to fulfil the obligation of rerouting and rebooking effectively 
and efficiently?  

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

How to quickly and easily establish whether the carrier is 
responsible for a certain travel disruption or whether it can be 
exempted from its obligation to pay compensation due to 
extraordinary circumstances? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations? 

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j) 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

Other 

29 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

30 

Do you have any other comments?  

Non-EU Airlines 

Table C.3: Targeted questionnaire for Non-EU Airlines 

Questions 

Background Information 

1 

2 

3 

Is your PRM customer policy (including safety rules) available online? If so, please 
provide a link? If not, please send us a copy? Please explain: 

a) 

b) 

whether your PRM policies applying to flights arriving 
to/transiting through/departing from EU aiports differs from 
those applicable to your wider network 

what safety-related information you request from PRMs to make 
an adequate safety assessment before the flight (i.e. type of 
battery, degree of mobility on board, etc.). Who (airline, travel 
agent, ground-handling agent, other party) makes this 
assessment and at which point of the journey (booking, pre-
notification, check-in, gate, etc.)? 

What training do you provide to your staff to ensure compliance with the 
Regulation?  

Please provide the following data for operations in scope of Regulation 
1107/2006 (i.e. flights arriving to/transitting through/departing from EU airports), 
if available (where possible, for the years 2006 to 2019): 

a) 

b) 

c) 

d) 

Total number of flights and total number of passengers carried 
(all passengers). 

The number of PRMs who were denied boarding on safety 
grounds and the reasons (as communicated to passengers).  

Total number of PRMs carried, by type of PRM passenger (based 
on IATA SSR codes or similar). 
Total number of wheelchair assistance provided. 

How many checked items of mobility aids (e.g. wheelchairs, 
scooters etc) were carried? How many items of checked mobility 
aids were lost, damaged or delayed? 
How many items of medical equipment were carried in addition 
to the mobility aids? 

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e) 

The proportion of PRMs who pre-notified? How long before 
travel was pre-notification provided?  
How consistent in practice is the pre-notified PRM classification 
with the assistance needs of PRMs? 
The proportion of PRM who pre-notified technical information of 
the mobility aids (dimensions, manual of battery powered aid 
etc.). 

4 

Please 
explain:  

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

how you ensure that PRMs are kept informed about their journey 
before, during and after travel in appropriate/accessible formats. 

what the most frequent situations are, if any, when you are 
forced to refuse embarkation/reservation by PRM on safety 
grounds or other reasons, or ask them to be accompanied by a 
safety assistant 

what the most frequent situations are, if any, when you are 
forced to refuse embarkation/reservation by PRM on the grounds 
that the design of the aircraft or airport infrastructure is not 
adequate (or sufficient equipment (e.g. ambulifts) is not 
available). 

what mechanisms you provide to enable PRMs to notify 
requirements for assistance at points of sale (please distinguish 
between direct sales and sales via an intermediary such as a 
travel agent, tour operator or other organisation). 

the mechanisms you have put in place to notify airports and/or 
PRM service providers in advance of requirements for assistance. 

any specific PRM requirements your organisation/members may 
have (such as maximum number of PRMs per flight, need to be 
accompanied, etc). 

how you ensure that PRMs are informed about their rights (in 
approriate/accessible formats). 

whether you provide refunds or rerouting where PRM 
embarkation is refused and how this is organised. 

5 

6 

7 

How many Regulation 1107/2006-related complaints have you received annually 
and what are the main types of complaint? How many are resolved at your level? 

Please explain your process for handling complaints from passengers on issues 
relating to Regulation 1107/2006? How do you liaise with airports and service 
providers? What processes do you have in place (e.g. webform), how long do you 
take to respond to complaints? What languages do you accept complaints in? Is 
the process free, accessible, and easy to use for passengers? 

To what extent have your complaint handling procedures changed since the 
Regulation came into force in 2008? 

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8 

Relevance 

9 

10 

Effectiveness 

11 

12 

13 

What mechanisms do you have in place for monitoring standards? Have you 
undertaken any surveys of the satisfaction of passengers with the services they 
receive? Do you have any evidence of how different PRM groups (e.g. wheelchair 
users, partially sighted passengers, etc.) are satisfied with the services they 
receive? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And in the future? Please distinguish between: 

a) 

b) 

c) 

d) 

General technological changes 

Changes affecting the aviation sector 

Changes affecting PRMs (e.g. social, population, legal).   

Other developments. 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

 Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

Has EU PRM legislation had any impact on your operations – for example, 
turnaround times and boarding procedures, seating policies or the use of 
equipment on board? 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

b) 

c) 

d) 

e) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly 
complaint procedures? 

 the service quality that you deliver to PRMs (including the 
handling of mobility aids)? 

your operating costs? 

your fares (for all passengers)? 

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14 

15 

How satisfied are you with the activities, powers and skills of the National 
Enforcement Bodies (NEBs) with which you have contact? 

How well do you think that the NEB complaints-handling and enforcement 
processes are working? Have you ever been inspected/audited by an NEB? Have 
you ever been sanctioned by a NEB for issues related to Regulation 1107/2006? If 
so,  

In addition: 

a) 

b) 

c) 

Please explain the reasons. Were you able to provide evidence to 
support your case? 

Please explain what financial penalties you incurred as a result. 
Have these penalties been paid? Do you consider that sanctions 
are effective, dissuasive and proportional? 

Did the sanction affect your reputation? 

Cost efficiency 

16 

What costs (financial and non-financial) do you incur in order to assist PRMs as a 
result of the Regulation?  How does this compare to the situation before the 
Regulation’s implementation? 

In particular 

a) 

b) 

c) 

d) 

e) 

f) 

What was the total cost associated with Regulation 1107/2006 
for your organisation for each year 2006-2019?  

How are these costs split between costs of compensation, 
administrative costs, and costs of refund or rerouting (if relevant 
under 1107/2006 – e.g. for denied boarding due to a change in 
aircraft type that cannot accommodate the mobility equipment)? 

How PRM charges are set by airports (process, consultation, KPIs, 
etc)?  

How have PRM charges evolved at the main EU airports where 
you operate? 

Have you undertaken any analysis of whether the charges levied 
by airports for PRM services are cost-reflective, as required by 
the Regulation?  

Are NEBs and/or Airport Charges ISAs (if relevant) involved with 
overseeing PRM charges? 

17 

18 

If relevant, what benefits do you receive as a result of the Regulation (increased 
demand, increased market share, other)?  

Do you think the costs (compliance, administrative, legal) are proportionate to 
the benefits of the Regulation? Could the objectives of the Regulation have been 
achieved at lower cost? If so, how? 

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19 

Coherence 

20 

21 

22 

Good practices 

23 

Is there any potential for reducing costs without affecting the service provided to 
passengers? 

To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

Is there coherence with the national legislation surrounding air PRM rights in your 
home based country, for example in respect of safety and security, accessibility, 
other modes or national legislation? Are there any overlaps, gaps or 
inconsistencies, and if so what are the impacts of these? 

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO 
regulations? 

Do you have examples with regards to Regulation 1107/2006, or other examples 
not specifically concerning the regulation from your wider network, of good 
practices guidelines or other guidance, minimum standards, contingency plans 
available in respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

The information about and service quality of assistance for 
PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to 
provide assistance with regard to the passengers' immediate 
practical needs following such an incident?  

Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

Authorities or oversight/enforcement body structures or 
practices in terms of dealing with complaints, cooperating with 
other authorities or oversight/enforcement bodies, monitoring 
cross-border operators, performing ADR functions, etc.? Good 
practices to incentivise a full application, to avoid circumvention 
(if any) and to have an effective, proportionate and persuasive 
enforcement? Types of sanction regimes that have proven to be 
good practice in this regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

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24 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

i) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to reimburse passengers quickly and with a minimum of 
administrative burden, when the trip is not carried out as 
planned? 

How to fulfil the obligation of rerouting and rebooking effectively 
and efficiently?  

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

How to quickly and easily establish whether the carrier is 
responsible for a certain travel disruption or whether it can be 
exempted from its obligation to pay compensation due to 
extraordinary circumstances? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations or in national law? 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

Other 

25 

26 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

Do you have any other comments?  

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Airports 

Table C.4: Targeted questionnaire for airports 

Questions 

Background Information 

1 

2 

3 

4 

Is your PRM customer policy available online? If so, could you please provide a 
link? If not, could you please send us a copy? 

What training do you provide to your staff to ensure compliance with the 
Regulation?  

Please provide the following data, if available (where possible, for the years 2006 
to 2019): 

a) 

b) 

c) 

d) 

Please 
explain:  

a) 

b) 

c) 

d) 

e) 

f) 

Total number of flights and total number of passengers handled 
(all passengers). 

Total number of PRMs carried, by type of PRM passenger (based 
on IATA SSR codes or similar). 
Total number of wheelchair assistance provided. 

How many checked items of mobility aids (e.g. wheelchairs, 
scooters etc) were carried? How many items of checked mobility 
aids were lost, damaged or delayed? 
How many items of medical equipment were carried in addition 
to the mobility aids? 

The proportion of PRMs who pre-notified? How long before 
travel was pre-notification provided?  
How consistent in practice is the pre-notified PRM classification 
with the assistance needs of PRMs? 

how you ensure that PRMs are kept informed about their journey 
before, during and after travel in appropriate/accessible formats. 

what the most frequent situations are, if any, when you cannot 
enable embarkation/reservation by PRM on the grounds that the 
design of the airport infrastructure is not adequate (or sufficient 
equipment (e.g. ambulifts) is not available). 

 the mechanisms you have put in place to exchange information 
(provide/receive notification) with carriers and/or PRM service 
providers in advance of requirements for assistance. 

any specific PRM requirements your organisation/members may 
have (need to be accompanied, etc.). 

how you ensure that PRMs are informed about their rights (in 
appropriate/accessible formats). 

what communication systems you have in place for PRMs to 
notify their arrival and need for assistance. 

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5 

6 

7 

8 

Relevance 

9 

10 

Effectiveness 

11 

12 

13 

How many Regulation 1107/2006-related complaints have you received annually 
and what are the main types of complaint? How many are resolved at your level? 

Please explain your process for handling complaints from passengers on issues 
relating to Regulation 1107/2006? How do you liaise with airlines and service 
providers? What processes do you have in place (e.g. webform), how long do you 
take to respond to complaints? What languages do you accept complaints in? Is 
the process free, accessible, and easy to use for passengers? 

To what extent have your complaint handling procedures changed since the 
Regulation came into force in 2008? 

What mechanisms do you have in place for monitoring quality standards? Have 
you undertaken any surveys of the satisfaction of passengers with the services 
they receive? Do you have any evidence of how different PRM groups (e.g. 
wheelchair users, partially sighted passengers, etc.) are satisfied with the services 
they receive? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And in the future? Please distinguish between: 

a) 

b) 

c) 

d) 

General technological changes 

Changes affecting the aviation sector 

Changes affecting PRMs (e.g. social, population, legal).   

Other developments. 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

 Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

Has EU PRM legislation had any impact on your operations – for example, in the 
level of staffing and equipment provision? 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

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14 

15 

Cost efficiency 

16 

b) 

c) 

d) 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly 
complaint procedures? 

 the service quality that you deliver to PRMs (including the 
handling of mobility aids)? 

your operating costs? 

How satisfied are you with the activities, powers and skills of the National 
Enforcement Bodies (NEBs) with which you have contact? 

 How well do you think that the NEB complaints-handling and enforcement 
processes are working?  Have you ever been inspected/audited by an NEB? Have 
you ever been sanctioned by a NEB for issues related to Regulation 1107/2006? If 
so,  

In addition: 

a) 

b) 

c) 

Please explain the reasons. Were you able to provide evidence to 
support your case? 

Please explain what financial penalties you incurred as a result. 
Have these penalties been paid? Do you consider that sanctions 
are effective, dissuasive and proportional? 

Did the sanction affect your reputation? 

What costs (financial and non-financial) do you incur in order to assist PRMs as a 
result of the Regulation?  How does this compare to the situation before the 
Regulation’s implementation? 

In particular 

` 

a) 

b) 

c) 

d) 

e) 

f) 

What was the total cost associated with Regulation 1107/2006 
for your organisation for each year 2006-2019?  

How are these costs split between cost of service provision (staff 
and equipment), cost of procurement of service provider (if 
relevant), costs of compensation, administrative costs? 

How PRM charges are set (process, consultation, KPIs, etc.)?  

How have PRM charges evolved? 

How do you demonstrate that the charges levied for PRM 
services are cost-reflective, as required by the Regulation?  

Are NEBs and/or Airport Charges ISAs (if relevant) involved with 
overseeing PRM charges? 

17 

If relevant, what benefits do you receive as a result of the Regulation (increased 
demand, increased market share, other)?  

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18 

19 

Coherence 

Do you think the costs (compliance, administrative, legal) are proportionate to 
the benefits of the Regulation? Could the objectives of the Regulation have been 
achieved at lower cost? If so, how? 

Is there any potential for reducing costs without affecting the service provided to 
passengers? 

20 

21 

22 

23 

24 

Value added 

25 

Good practices 

To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

In your view, what is the relationship, if any, between Regulation 1107/2006 and: 

a) 

b) 

c) 

d) 

the Package Travel Directive ? Are there any overlaps, gaps or 
inconsistencies? 

Groundhandling Directive ? Do you see any overlaps, gaps or 
inconsistencies? 

Directive on airport charges? Do you see any overlaps, gaps or 
inconsistencies? 

Regulation (EC) 261/2004 on air passenger rights? Are there any 
overlaps, gaps or inconsistencies? 

Is there coherence with the wider relevant transport policy framework, for 
example in respect of safety and security (e.g. EASA decision 2016/004/R on 
Special Category Passengers), accessibility, other modes or national legislation? 
Are there any overlaps, gaps or inconsistencies, and if so what are the impacts of 
these? 

In your view, to what extent are the requirements of Regulation 1107/2006 
coherent and consistent with other EU interventions/initiatives or legislation, for 
example in respect of non-discrimination, accessibility, EU consumer policy, policy 
towards persons with disabilities and competition policy?  

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO regulations, 
EU's external transport policy, and agreements with third countries (e.g. the 
equivalent requirements for the US, Canada or other countries)?  

What is the value-added resulting from the Regulation 1107/2006 compared to 
any pre-existing or subsequent national legislation, or compared to what could be 
achieved at national level? 

26 

Do you have examples of good practice, guidelines or other guidance, minimum 
standards, contingency plans available in respect of: 

a) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

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b) 

c) 

d) 

e) 

f) 

g) 

h) 

The information about and service quality of assistance for 
PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to 
provide assistance with regard to the passengers' immediate 
practical needs following such an incident?  

Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

NEB structures or practices in terms of dealing with complaints, 
cooperating with other NEBs, monitoring cross-border operators, 
performing ADR functions, etc.? Good practices to incentivise a 
full application, to avoid circumvention (if any) and to have an 
effective, proportionate and persuasive enforcement? Types of 
sanction regimes that have proven to be good practice in this 
regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

Addressing the interaction between the Regulation 1107/2006 
and the Package Travel Directive (2015/2302)? 

27 

28 

Can you provide any other examples of good practice, guidelines or other 
guidance, minimum standards, contingency plans available, including from non-
European countries? 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations? 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

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Other 

29 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

30 

Do you have any other comments?  

PRM Representatives 

Table C.5: Targeted questionnaire for PRM representatives 

Questions 

Background Information 

1 

2 

3 

4 

Please briefly describe the activity of your organisation and in particular whether 
you cover passengers in other modes (e.g. rail, bus and coach, ferries). 

Please 
explain:  

a) 

b) 

c) 

d) 

f) 

g) 

k) 

how compliant carriers are with ensuring that PRMs are kept 
informed about their journey before, during and after travel in 
appropriate/accessible formats. 

what the most frequent situations are, if any, when carriers refuse 
embarkation/reservation by PRM on safety grounds or other 
reasons, or ask them to be accompanied by a safety assistant. 

what the most frequent situations are, if any, when carriers refuse 
embarkation/reservation by PRM on the grounds that the design 
of the aircraft or airport infrastructure is not adequate (or 
sufficient equipment (e.g. ambulifts) is not available). 

what mechanisms are provided to enable PRMs to notify 
requirements for assistance at points of sale. 

how compliant carriers are with ensuring that PRMs are informed 
about their rights (in approriate/accessible formats). 

what communication systems terminal managing bodies have in 
place for PRMs to notify their arrival and need for assistance. 

whether carriers provide refunds or rerouting where PRM 
embarkation is refused and how this is organised. 

How many Regulation 1107/2006-related complaints have you received annually 
and what are the main types of complaint (e.g. denied boarding, airport waiting 
times, lost or damaged mobility equipment)? Do you think this reflects the real 
number of cases?  If not, what are, in your opinion, the reasons for the low 
number of complaints compared to the real number of cases? 

To what extent have complaint handling procedures (of airlines, airports and/or 
NEBs) changed since the Regulation came into force in 2008?  

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5 

6 

Relevance 

7 

8 

Effectiveness 

9 

What measures are in place to ensure that PRMs can make a complaint to a 
carrier, airport, other service provider, and/or NEB, and that the complaint is 
adequately addressed without undue delays and complications for PRM? 

Have you undertaken any surveys of the satisfaction of passengers with the 
services they receive? Do you have any evidence of how different PRM groups 
(e.g. wheelchair users, partially sighted passengers, etc.) are satisfied with the 
services they receive? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And going forward? Please distinguish between: 

a) 

b) 

c) 

d) 

General technological changes; 

Changes affecting the aviation sector; and 

Changes affecting PRMs (e.g. social, population, legal).   

Other developments. 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

 Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

10 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

b) 

c) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly complaint 
procedures? 

the service quality that airlines and airports deliver to passengers? 

How satisfied are you with the activities, powers and skills of the National 
Enforcement Bodies (NEBs) with which you have contact? 

How well do you think that the NEB complaints-handling and enforcement 
processes are working?  

In addition: 

11 

12 

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a) 

b) 

c) 

Please explain the reasons. 

Do you think that financial penalties (or other sanctions) are 
effective, dissuasive and proportional? 

Do you think that sanctions affect the reputation of carriers, 
airports or other service providers? 

Cost efficiency 

13 

14 

Coherence 

15 

16 

17 

18 

19 

What costs (financial and non-financial) do PRMs incur in order to enforce their 
rights?  How does this compare to the situation before the Regulation’s 
implementation? 

What benefits do you think the Regulation has generated for PRM and for 
airports/airlines (e.g. do carriers benefit from increased demand, increased 
market share, other)?  

 To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

In your view, what is the relationship, if any, between Regulation 1107/2006 and: 

a) 

d) 

the Package Travel Directive ? Are there any overlaps, gaps or 
inconsistencies? 

Regulation (EC) 261/2004 on air passenger rights? Are there any 
overlaps, gaps or inconsistencies? 

Is there coherence with the wider relevant transport policy framework, for 
example in respect of safety and security (e.g. EASA decision 2016/004/R on 
Special Category Passengers), accessibility, other modes or national legislation? 
Are there any overlaps, gaps or inconsistencies, and if so what are the impacts of 
these? 

In your view, to what extent are the requirements of Regulation 1107/2006 
coherent and consistent with other EU interventions/initiatives or legislation, for 
example in respect of non-discrimination, accessibility, EU consumer policy, policy 
towards persons with disabilities and competition policy?  

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO regulations, 
EU's external transport policy, and agreements with third countries (e.g. the 
equivalent requirements for the US, Canada or other countries)?  

Good practices 

20 

Do you have examples of good practice, guidelines or other guidance, minimum 
standards, contingency plans available in respect of: 

a) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

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b) 

c) 

d) 

e) 

f) 

g) 

h) 

The information about and service quality of assistance for PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to provide 
assistance with regard to the passengers' immediate practical 
needs following such an incident?  

Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

NEB structures or practices in terms of dealing with complaints, 
cooperating with other NEBs, monitoring cross-border operators, 
performing ADR functions, etc.? Good practices to incentivise a 
full application, to avoid circumvention (if any) and to have an 
effective, proportionate and persuasive enforcement? Types of 
sanction regimes that have proven to be good practice in this 
regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

Addressing the interaction between the Regulation 1107/2006 and 
the Package Travel Directive (2015/2302)? 

21 

22 

Can you provide any other examples of good practice, guidelines or other 
guidance, minimum standards, contingency plans available, including from non-
European countries? 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to avoid offering discriminatory contract conditions, including 
for PRM access, or any direct or indirect discrimination based on 
residency of the final customer or on the place of establishment of 
the carriers, or ticket vendors? 

How to reimburse passengers quickly and with a minimum of 
administrative burden, when the trip is not carried out as 
planned? 

How to fulfil the obligation of rerouting and rebooking effectively 
and efficiently?  

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

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g) 

h)  

i) 

j) 

How to quickly and easily establish whether the carrier is 
responsible for a certain travel disruption or whether it can be 
exempted from its obligation to pay compensation due to 
extraordinary circumstances? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations? 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

Do you have any other comments?  

Other 

23 

24 

Others 

Table C.6: Targeted questionnaire for other stakeholders 

Questions 

Background Information 

1 

2 

3 

4 

Please briefly describe the activity of your organisation and in particular whether 
you cover passengers in other modes (e.g. rail, bus and coach, ferries). 

Is the PRM customer policy of your Members available online? Please explain 

a) 

b) 

Are the PRM policies of your members reviewed and/or 
approved by a National Enforcement Body (NEB), national safety 
regulator, EASA or other? 

what safety-related information your members request from 
PRMs to make an adequate safety assessment before the flight 
(i.e. type of battery, degree of mobility on board, etc.). Who 
(airline, travel agent, ground-handling agent, other party) makes 
this assessment and at which point of the journey (booking, pre-
notification, check-in, gate, etc.)? 

What training do your members provide to their staff to ensure compliance with 
Regulation 1107/2006?  

Please provide the following data, if available (where possible, for the years 2006 
to 2019): 

a) 

Total number of PRMs assisted, by type of PRM passenger (if 
available). 
Total number of wheelchair assistance requested/provided. 

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b) 

c) 

How many checked items of mobility aids (e.g. wheelchairs, 
scooters etc) were carried? How many items of checked mobility 
aids were lost, damaged or delayed? 
How many items of medical equipment were carried in addition 
to the mobility aids? 

The proportion of PRMs who pre-notified? How long before 
travel was pre-notification provided?  
How consistent in practice is the pre-notified PRM classification 
with the assistance needs of PRMs? 
The proportion of PRM who pre-notified technical information of 
the mobility aids (dimensions, manual of battery powered aid 
etc.). 

5 

Please 
explain:  

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

how compliant carriers are with ensuring that PRMs are kept 
informed about their journey before, during and after travel in 
appropriate/accessible formats. 

what the most frequent situations are, if any, when carriers 
refuse embarkation/reservation by PRM on safety grounds or 
other reasons, or ask them to be accompanied by a safety 
assistant. 

what the most frequent situations are, if any, when carriers 
refuse embarkation/reservation by PRM on the grounds that the 
design of the aircraft or airport infrastructure is not adequate (or 
sufficient equipment (e.g. ambulifts) is not available). 

what mechanisms are provided to enable PRMs to notify 
requirements for assistance at points of sale. 

the mechanisms you have put in place to notify airlines, airports 
and/or PRM service providers in advance of requirements for 
assistance. 

how you ensure that PRMs are informed about their rights (in 
appropriate/accessible formats). 

what communication systems you have in place for PRMs to 
notify their arrival and need for assistance. 

whether you provide refunds or rerouting where PRM 
embarkation is refused and how this is organised. 

6 

7 

How many Regulation 1107/2006-related complaints have you received annually 
and what are the main types of complaint? How many are resolved at your level? 

Please explain the process for handling complaints from passengers on issues 
relating to Regulation 1107/2006? How do you/your members liaise with airlines, 
airports and other providers? What processes are in place (e.g. webform), how 
long does it take you/your members to respond to complaints? What languages 
do you/your members accept complaints in? Is the process free, accessible, and 
easy to use for passengers? 

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8 

9 

10 

Relevance 

11 

12 

Effectiveness 

13 

14 

15 

To what extent have the complaint handling procedures of your members 
changed since Regulation 1107/2006 came into force in 2008? 

What measures are in place to ensure that PRMs can make a complaint to a 
carrier, airport, other service provider, and/or NEB, and that the complaint is 
adequately addressed without undue delays and complications for PRM? 

Have you undertaken any surveys of the satisfaction of passengers with the 
services they receive? Do you have any evidence of how different PRM groups 
(e.g. wheelchair users, partially sighted passengers, etc.) are satisfied with the 
services they receive? 

What do you think are the current priority needs of PRMs travelling by air? Have 
these changed since the Regulation was implemented? 

Compared to 2008 when Regulation 1107/2006 came into force, have there been 
any technological or scientific advances that may help/obstruct PRMs travelling 
by air? And going forward? Please distinguish between: 

a) 

b) 

c) 

d) 

General technological changes; 

Changes affecting the aviation sector; and 

Changes affecting PRMs (e.g. social, population, legal).   

Other developments. 

To what extent has Regulation 1107/2006 changed the protection provided to 
passengers compared to the period before its implementation in 2008? 

a)  

b) 

Which factors have contributed to/hindered the achievement of 
the objectives of Regulation 1107/2006? Are there any barriers in 
providing better quality assistance to PRMs? 

Are key terms in the Regulation sufficiently well defined to 
support effective implementation? 

What do you think the impact of EU PRM legislation has been on airlines' and 
airports' operations; – for example, have carriers changed their seating policies, 
or have airports changed their level of staffing? Please explain. 

Has Regulation 1107/2006 had any impact on (please explain):  

a) 

b) 

c) 

d) 

how you ensure that PRMs have equal right to air travel 
comparable to that of all other passengers? 

how you ensure that PRMs are informed of their rights and can 
exercise them in practice by accessible and user-friendly 
complaint procedures? 

the service quality that airlines and airports deliver to 
passengers? 

your/your members' operating costs? 

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16 

17 

How satisfied are you with the activities, powers and skills of the National 
Enforcement Bodies (NEBs) with which you have contact? 

How well do you think that the NEB complaints-handling and enforcement 
processes are working?  

In addition: 

a) 

b) 

c) 

Please explain the reasons. 

Do you think that financial penalties (or other sanctions) are 
effective, dissuasive and proportional? 

Do you think that sanctions affect the reputation of carriers, 
airports or other service providers? 

Cost efficiency 

18 

19 

20 

21 

Coherence 

22 

23 

What costs (financial and non-financial) do PRMs incur in order to enforce their 
rights?  How does this compare to the situation before the Regulation’s 
implementation? 

In particular 

a) 

What was the total cost associated with Regulation 1107/2006 
for your members for each year 2006-2019?  

What benefits do you think the Regulation has generated for PRM and for 
airports/airlines (e.g. do carriers benefit from increased demand, increased 
market share, other)?  

Do you think the costs (compliance, administrative, legal) are proportionate to 
the benefits of the Regulation? Could the objectives of the Regulation have been 
achieved at lower cost? If so, how? 

Is there any potential for reducing costs without affecting the service provided to 
passengers? 

To what extent are the provisions of the Regulation 1107/2006 coherent and 
consistent with one another? 

In your view, what is the relationship, if any, between Regulation 1107/2006 and: 

a) 

b) 

c) 

d) 

the Package Travel Directive ? Are there any overlaps, gaps or 
inconsistencies? 

the Groundhandling Directive ? Do you see any overlaps, gaps or 
inconsistencies? 

Directive on airport charges? Do you see any overlaps, gaps or 
inconsistencies? 

Regulation (EC) 261/2004 on air passenger rights? Are there any 
overlaps, gaps or inconsistencies? 

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24 

25 

26 

Good practices 

Is there coherence with the wider relevant transport policy framework, for 
example in respect of safety and security (e.g. EASA decision 2016/004/R on 
Special Category Passengers), accessibility, other modes or national legislation? 
Are there any overlaps, gaps or inconsistencies, and if so what are the impacts of 
these? 

In your view, to what extent are the requirements of Regulation 1107/2006 
coherent and consistent with other EU interventions/initiatives or legislation, for 
example in respect of non-discrimination, accessibility, EU consumer policy, policy 
towards persons with disabilities and competition policy?  

Is the Regulation consistent with other requirements such as United Nations 
Convention on the Rights of Persons with Disabilities (UNCRPD), ICAO regulations, 
EU's external transport policy, and agreements with third countries (e.g. the 
equivalent requirements for the US, Canada or other countries)?  

27 

Do you have examples of good practice, guidelines or other guidance, minimum 
standards, contingency plans available in respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h) 

Pre-notification and transmission of information between travel 
agents, airlines, airports and PRM service providers?  

The information about and service quality of assistance for 
PRMs? 
The provision of medical oxygen on board or the transport of 
mobility aids at no additional cost? 

How to keep passengers, including those, who might have 
disabilities or who are less IT-literate informed about disruptions 
in an accurate and timely manner? 

Replacement of damaged or lost mobility aids and how to 
provide assistance with regard to the passengers' immediate 
practical needs following such an incident?  

 Rapid and effective handling of complaints, especially in terms of 
procedures and deadlines? 

NEB structures or practices in terms of dealing with complaints, 
cooperating with other NEBs, monitoring cross-border operators, 
performing ADR functions, etc.? Good practices to incentivise a 
full application, to avoid circumvention (if any) and to have an 
effective, proportionate and persuasive enforcement? Types of 
sanction regimes that have proven to be good practice in this 
regard? 

Consumer bodies/authorities and/or dispute resolution 
(ADR/ODR) practices? 

Addressing the interaction between the Regulation 1107/2006 
and the Package Travel Directive (2015/2302)? 

28 

Can you provide any other examples of good practice, guidelines or other 
guidance, minimum standards, contingency plans available, including from non-
European countries? 

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29 

For all air passengers (including PRMs), do you have examples of good practice, 
guidelines or other guidance, minimum standards, contingency plans available in 
respect of: 

a) 

b) 

c) 

d) 

e) 

f) 

g) 

h)  

i) 

j) 

Right to get assistance in case of long delay at departure or at 
connecting points. For example, are there contingency plans for 
assistance and care in case of massive disruptions to avoid long 
waiting time at the premises or by phone or online? 

How to avoid offering discriminatory contract conditions, 
including for PRM access, or any direct or indirect discrimination 
based on residency of the final customer or on the place of 
establishment of the carriers, or ticket vendors? 

How to reimburse passengers quickly and with a minimum of 
administrative burden, when the trip is not carried out as 
planned? 

How to fulfil the obligation of rerouting and rebooking effectively 
and efficiently?  

How to keep all passengers (including PRM) informed without 
undue delay? 

Help for passengers in case of injury and loss or damage to 
luggage? 

How to quickly and easily establish whether the carrier is 
responsible for a certain travel disruption or whether it can be 
exempted from its obligation to pay compensation due to 
extraordinary circumstances? 

Systematic use of IT tools which help to improve the 
implementation of Passenger Rights? Other cooperation between 
operators of different modes in multimodal travel? 

Where carriers offer contract conditions which are more 
favourable for passengers than the conditions laid down in the 
Regulations? 

With the application, monitoring or enforcement of passenger 
rights (including PRM) during the COVID-19 pandemic? 

Other 

30 

31 

Do you have any other comments to make regarding the existing European 
framework on PRM protections for air passengers? Please specify which market 
and/or socio-economic developments (if any) since the introduction of the 
Regulation do not support its application. 

Do you have any other comments?  

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D  Workshop agenda  

EU workshop on the evaluation of Regulation 1107/2006 (rights of PRM 
travelling by air) 

Tuesday, 10 November 2020 

Introduction 

The Terms of Reference (ToR) for the support study to the evaluation of the PRM Regulation 
(1107/2006) require that a workshop is undertaken as part of the study. This note sets out the 
format and content of this workshop. 

Objectives of the workshop 

The  objective  of  this  workshop  is  to  foster  a  discussion  between  PRMs  and  passenger 
representatives, operational stakeholders and authorities on some key themes related to the 
implementation or  enforcement  of  Regulation 1107/2006.  It  will  also  be  an  objective  of the 
workshop to highlight good practices or potential areas for solutions where they exist.  

To facilitate this, the workshop is being designed to be participatory around a discussion format, 
involving  a  limited  number  of  attendees  (c.  30)  with  a  balance  of  representation  across 
stakeholder groups.   

Format and draft programme 

Format 

The workshop will be a full-day event, taking place on Tuesday 10 November 2020.  

It will be a participatory workshop with selected invited stakeholders (c. 30). Discussions will 
be held in English only – interpretation will not be available. A scene-setting introduction by 
DG MOVE and Steer will be followed by round-table discussions in three smaller groups. 

It will be online-only, using Zoom. A single set of login details will be sent to attendees, which 
will allow them to attend both the plenary and the individual virtual roundtables. 

A balance between participants will be ensured in the virtual plenary room and within each 
virtual roundtable. The following participants have been invited: 

  Representatives of PRMs and passengers;  
  Representatives of airports; 
  Representatives of airlines; 
  Representatives of NEBs; 
  Representatives of EASA; 

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Draft programme 

All participants are expected to take part in round-table discussions. Each table will be invited 
to report back on the findings/conclusions of their discussion.  Discussions will be conducted in 
view of discussing issues and considering possible solutions. The themes for the discussion 
may include the following: 

– 

– 

– 

Theme 1: What is the link between pre-notification and the provision and dimensioning 
of PRM assistance? Can pre-notification be required if disabled and PRM passengers 
want to be independent travellers? Towards improved airport accessibility: ideas and 
issues, good practices; 

Theme 2: is there a trade-off being made between the right to travel of disabled and 
PRM passengers vs. the safety requirements of the aviation industry? Is the seating of 
PRMs  in  the  cabin  of  aircraft  subject  to  multiple  demands  based  on  comfort  and 
convenience,  safety  requirements,  commercial  policies,  etc?  Towards  improved 
aircraft accessibility: ideas and issues, good practices; 

Theme  3:  Looking  forward:  how  to  ensure  that  1107/2006  remains  fit  for  purpose? 
What clarifications/grey areas should the EC be asked to address as a priority? Possible 
improvements of NEB enforcement, good practices. 

Outline agenda  

 
 
 
 
 
  BREAK 
 
 
 
 
 
 
 
 
 

9:30 (CET) - Start  
[Plenary] Introduction by DG MOVE and Steer, Q&A 
[Plenary] Introduction of roundtable 1; 
[In groups] Round-table discussion 1; 
[Plenary] Reporting of the discussion of roundtable 1; 

[Plenary] Introduction of roundtable 2; 
[In groups] Round-table discussion 2; 
[Plenary] Reporting of the discussion of roundtable 2; 
12:15 – 13:30 - LUNCH  
[Plenary] Introduction of roundtable 3; 
[In groups] Round-table discussion 3; 
[Plenary] Reporting of the discussion of roundtable 3; 
[Plenary] Summary of the day  
15:00 (CET) - End 

Next steps 

 

If you have not done so already, we kindly invite you to confirm your participation as soon 
as possible, by sending an email to Sean Barker at Steer 
(Passenger.Rights@steergroup.com)  

  We will send you a Zoom invitation upon confirmation;  
  Any ideas or proposals on the content can be sent to the same address. 

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E  Workshop summary 

EU workshop on the evaluation of Regulation 
1107/2006 (rights of PRM travelling by air) 

Introduction 

Minutes 

The workshop on the evaluation of Regulation 1107/2006 took place on Tuesday 10 November 
2020, online.  

It was attended by 29 stakeholders, including 8 NEBs, 7 PRM and passenger representatives, 6 
airports and their representatives, 7 airlines and their representatives, and one representative 
of the European Aviation Safety Agency. In addition, the European Commission and Steer 
joined as observers.  

Objectives of the workshop 

The objective of this workshop was to foster a discussion between PRM and other passenger 
representatives, operational stakeholders and authorities on some key themes related to the 
implementation  and  enforcement  of  Regulation  1107/2006.  It  was  also  an  objective  of  the 
workshop to highlight good practices. To facilitate this, the workshop was being designed to be 
participatory around a discussion format. 

Summary of discussions 

Introduction by Mr. Herald Ruijters, DG MOVE.B Director 

Mr Ruijters welcomed the participants. He provided an introduction to the day, explaining the 
context of the study to participants and the Commission’s next steps: the planned publication 
of a Commission Staff Working Document summarising the Commission’s findings of the 
evaluation.  He stressed that it was unsure at this stage whether amending existing rules 
would be required.  

Presentation of emerging findings by Steer 

Steer presented its emerging findings on the five evaluation topics of the study: 

 

Effectiveness:  
– 

Findings from the evidence gathered from desk and field research indicate that the 
Regulation has been effective in meeting the objectives of the intervention: The 
Regulation has guaranteed a right of travel to PRMs, but there are still some instances 
of denied boarding of PRMs;  
There has been only a very limited number of sanctions issued by NEBs to operators. 
However, the fact that these are few should not necessarily be interpreted as a sign 
that “all is well”; 

– 

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–  Very few complaints have been received by NEBs relating to the Regulation. 

Complaints received by airlines and airports are also very limited, but it remains 
difficult to say with full certainty whether this rate of complaint is “the tip of the 
iceberg” or the real situation;  
Some factors (mobility device liability limits, a lack of sanctions for non-compliance, 
no consistent enforcement activities, etc) have hindered the effectiveness of the 
Regulation;  

– 

 

Efficiency:  
– 

The Regulation’s mechanisms designed to ensure that the funding of assistance work 
well and have contributed to the adequate provision of PRM assistance pre-covid; 
Stakeholders have not complained of disproportionate costs, but as assistance 
requests have grown, so have the costs of the system; 
Some stakeholders have called for greater transparency and oversight from the 
adequate authorities to ensure maximum cost-efficiency; 

– 

– 

  Coherence:  

– 

The approach taken in Europe is mostly coherent with other European policies 
although some areas would benefit from better alignment, notably with Regulation 
261/2004, the groundhandling Directive, or with the Airport Charges Directive; 

–  One of the most important issue on Coherence is the provision on liability for 

– 

damaged or lost mobility equipment;  
There is an important relationship between the right to travel and aviation safety, 
careful considerations need to be made in this area; 

 

EU added-value: 
– 

the Regulation has been successful at ensuring a Europe-wide provision of assistance 
for passengers with disabilities and passengers with reduced mobility, meaning that 
all can travel with higher confidence and less risk of discrimination; 

  Relevance:  

– 

– 

The needs of PRMs have not significantly changed since the Regulation was drafted. 
Without the Regulation, these problems would likely remain, meaning that the 
Regulation is still relevant; 
The Regulation has adapted well to most technological challenges, but by solely 
addressing the problems of PRM through assistance, it has not necessarily been a tool 
for better infrastructure accessibility of PRMs in air travel. 

First group discussion 

Theme of the discussion: “What is the link between pre-notification and the provision and 
dimensioning of PRM assistance? Can pre-notification be required if passengers with 
disabilities and passengers with reduced mobility want to be independent travellers? Towards 
improved airport accessibility: what are the issues, are there any good practices to highlight?” 

Participants mentioned the following points: 

 

 

The definition of PRMs is very broad, but this was not an issue specifically raised by 
stakeholders. A stakeholder stated that the definition should more closely reflect the 
UNCRPD – there was widespread agreement with this. 
Some stakeholders would prefer no pre-notification but recognises that pre-notification is 
needed in practice. “If we have to have it, it should deliver greater quality/value for 
money than would otherwise be provided”; 

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  Making pre-notification easier could be the key to ‘unlocking’ higher pre-notification 

rates: 
– 

The point was made that the European Accessibility Act (2019) could be the key to 
‘unlocking’ better prenotification as this requires that airline and airport websites to 
be accessible; 

–  A PRM representative and a NEB also encouraged the booking process to be much 
simpler (currently it is very complex, time consuming, and sometimes costly); 
Issues arise when passengers use an online travel agent – they cannot contact the 
airline easily; 

– 

–  Passengers do not always want assistance at every point in the journey: one size does 
not fit all. Sometimes they only need help at one point. We need to get to the point 
where passengers are provided with a tailor-made service; 

–  Passengers are generally keen to pre-book. Some airlines are better than others in 
helping passengers through the process. Websites and helplines need to be easy to 
follow. A free phone number allowing people to speak to someone about their needs 
is essential;  

–  A NEB has focused on airlines that are reluctant to apply established codes. It has also 

launched a campaign to improve awareness and launched an app to provide 
passengers with access to information in four languages. Passengers can obtain a 
travel and medical card and provide information on their needs just once – the 
system should recognise who they are for subsequent bookings;  

 

Sometimes staff are not well-trained. There are also no obligations on tour operators and 
other third parties. 

Second group discussion 

Theme of the discussion: “Is there a trade-off being made between the right to travel of 
passengers with disabilities and passengers with reduced mobility vs. the safety requirements 
of the aviation industry? Is the seating of PRMs in the cabin of aircraft subject to multiple 
demands based on comfort and convenience, safety requirements, commercial policies, etc? 
Towards improved aircraft accessibility: what are the issues, are there any good practices to 
highlight?” 

Participants mentioned the following points: 

 
 
 

 

 
 

There is no trade-off between safety and the right to travel of PRMs safely 
Safety procedures are inconsistent across airlines.  
PRMs are sometimes treated as a risk to other passengers (in terms of blocking 
emergency routes) and with this in mind, are required to occupy a window seat.  
Safety rules/information needs to be available in braille and aircraft should be more 
tactile. The call button in aircraft needs to be more accessible – this is the first port of call 
when a passenger needs assistance; 
It was recognised that some safety conditions used to deny boarding are unclear. 
Some stakeholders called for industry to allow passengers into aircraft with their own 
wheelchairs; 

  A PRM stakeholder believed that there remains a small number of cases where denied 
boarding is not explicitly justified on the grounds of the derogations permitted by the 
Regulation. 

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 

PRM and passenger representatives believe that airlines’ commercial decisions to have 
maximum number of wheelchairs or assistance dogs on a flight should be addressed by 
the Regulation. 

  Airline algorithms sometimes automatically allocate PRMs to window seats. Failure to 

 

provide passengers with what they need sometimes compromises safety. Cited a case of a 
passenger needing constant assistance whose wife was placed in a seat two rows behind; 
The evolution of technology is an issue and clarification on safety would be welcome. 
Problems also arise on the day when aircraft are changed for operational reasons. Airport 
constraints are not always communicated in good time; 

Third group discussion 

Theme of the discussion: “Looking forward: how to ensure that 1107/2006 remains fit for 
purpose? What clarifications/grey areas should the EC be asked to address as a priority? 
Possible improvements of NEB enforcement, good practices”. 

Participants mentioned the following points: 

 

Suggestions for EC action include: 
– 
Increased liability for damaged/lost mobility equipment; 
–  Compensation for PRMs denied boarding to be investigated; 
–  More transparency and clarity on denied boarding of PRMs; 
–  Assistance dogs/animals certification; 
–  Wheelchair: batteries, loading/unloading onboard aircraft; 
– 
–  Address delays to delivery of wheelchairs or other equipment (as opposed to loss or 

Lack of consistency of approach of carriers on oxygen, batteries, etc;  

damage) and potential for theft at the airport 

–  Better definition of the scope of the Regulation and PRMs  

  An airport has moved away from “PRM” as a definition and now considers 

Passengers Requiring Support (PRSs) in the broadest sense. It needs to be clear 
that the regulation is not just for people with limited mobility. Passengers have a 
wide range of support needs. 
passengers with allergies (introducing a further complexity in the carriage of 
guide dogs – who travels, the passenger with the dog or the one with the dog 
allergy?) 

 

–  Accessibility is a fundamental issue for PRMs: 

  Websites and communication channels of stakeholders (airline and airports) 
  Airports infrastructure and processes; 
  Aircraft cabin (and hold for wheelchairs); 

–  Monitoring and enforcement: 

  Data and transparency of NEBs adds value 
  Better sanctioning consistency of NEBs 
  NEBs mandates to be clarified and harmonised 
  More prescriptive reporting responsibilities: at present, everyone reports in 

different ways; 

  Consistency with other countries’ regulations (US + Canada) regarding the carriage of 

animals could be addressed 

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Summary of the day 

Steer provided a summary of the discussions of the day. Ms Elisabeth Kotthaus wrapped-up 
the workshop by thanking all participants for their valuable contributions and explaining that 
the study will be finalised in early 2021. A Commission Staff Working Document will follow in 
Spring 2021.  

February 2021 | 118 

 
Control Information 

Prepared by 

Steer 
28-32 Upper Ground 
London SE1 9PD 
+44 20 7910 5000 
www.steergroup.com 

Prepared for 

  DG MOVE, European Commission 

Directorate E – Aviation  
Avenue du Bourget 1 
1140 Brussels (Evere) 
Belgium 

Steer project/proposal number 

Client contract/project number 

23772601 

Author/originator 

Thomas Cahill 

Other contributors 

Harry Clarke, Sean Barker 

Version control/issue number 

V3 

  MOVE B5/2019 - 279 

Reviewer/approver 

Clémence Routaboul 

  Distribution 

Client: 

Steer:   

  Date 

27/05/2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
steergroup.com  

 
 
 
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