COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council establishing the European Disability Card and the European Parking Card for persons with disabilities
Date: 2023-09-06
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: European social policy, disabled person, free movement of persons, health card, parking area

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 6.9.2023  SWD(2023) 290 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council establishing the European Disability Card and the European Parking Card for persons with disabilities  {COM(2023) 512 final} - {SEC(2023) 305 final} - {SWD(2023) 289 final} - {SWD(2023) 291 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 1 

PROBLEM DEFINITION .................................................................................................................... 2 

2.2.  What are the problems? ..................................................................................... 5 
2.2.1.  When persons with disabilities travel to or visit other Member States, their access to 
preferential conditions including those related to services is hampered as their disability status 
is not recognised........................................................................................................................... 6 

2.2.2.  When travelling  by car in  the EU, persons with  disabilities face difficulties in  using 
their EU parking card. .................................................................................................................. 8 

2.3  What are the problem drivers? .......................................................................... 9 
 How likely is the problem to persist? ............................................................. 11 
2.4. 

3.  WHY SHOULD THE EU ACT? ........................................................................................................ 13 

3.1. 
3.2. 

 Legal basis ...................................................................................................... 13 
 Subsidiarity: Necessity and added value of EU action .................................. 14 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 15 

General objective of the European Disability Card initiative ................................... 15 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 17 

 What is the baseline from which options are assessed? ................................. 17 
5.1. 
5.2.  Description of the policy options .................................................................... 17 
5.2.1.  Policy area A: Options aimed at facilitating mutual recognition of disability status in 
the EU in relation to access to services when visiting another Member State ........................... 17 

5.2.2.  Policy area B: Options aimed at facilitating use and legal certainty in the use of the EU 
parking card for persons with disabilities .................................................................................. 19 

5.2.3.  Common accompanying measure for policy options A1, A2, B2 ............................... 20 

5.2.4.  Options discarded at an early stage .............................................................................. 20 

5.2.5. Stakeholders’ views on policy options ............................................................................. 23 

5.2.6. Link between policy options and objectives .................................................................... 25 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 26 

6.1.  Assessment of the baseline scenario ............................................................... 26 
6.2.  Assessment of policy options aimed at facilitating mutual recognition of disability 
status in the EU in relation to access to services when visiting another Member 
State (Area A) ................................................................................................. 31 

6.3.  Assessment of policy options aimed at facilitating use and legal certainty in the 

use of the EU parking card for persons with disabilities (Area B) ................. 39 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................ 42 

8. 

PREFERRED OPTION ...................................................................................................................... 46 

9.  HOW WOULD ACTUAL IMPACTS BE MONITORED AND EVALUATED? ............................. 48 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 49 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 52 

i 

 
 
ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 86 

ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 98 

ANNEX 5: COMPETITIVENESS CHECK .............................................................................................. 135 

ANNEX 6: EVIDENCE FEEDING THE PROBLEM DEFINITION ....................................................... 138 

ANNEX 7: INTERVENTION LOGIC, AND MONITORING.................................................................. 173 

ANNEX 8: IMPACTS OF THE POLICY OPTIONS ................................................................................ 176 

ANNEX 9: POTENTIAL IMPACTS OF THE POLICY OPTIONS ON TRAVEL GAP OF PERSONS WITH 
DISABILITIES AND VALUE ADDED TO THE MARKET OF ACCESSIBLE TOURISM ........ 183 

Glossary 

Term or acronym 

Meaning or definition 

CEA 

CMI 

CSO 

Cost-Effectiveness Analysis 

Carte mobilité inclusion (Mobility inclusion card) 

Civil Society Organisation 

DG EMPL 

Directorate-General for Employment, Social Affairs and Inclusion 

DG GROW 

Directorate-General  for  Internal  Market,  Industry,  Entrepreneurship 
and SMEs 

DG JUST 

Directorate-General for Justice and Consumers 

EDC 

EDF 

EP 

European Disability Card 

European Disability Forum 

European Parliament 

EUCFR 

Charter of Fundamental Rights of the EU  

EU-SILC 

EU Statistics on Income and Living Conditions  

EU DAP 

EU Disability Action Plan  

ii 

 
 
 
 
 
GALI 

GO 

ICT 

NCA 

PWG 

REC 

SME 

SDG  

SO 

Global Activity Limitation Instrument 

General Objectives 

Information and Communication Technologies 

National Competent Authority 

Project Working Group  

Rights, Equality and Citizenship Programme (2014-2020) 

Small and Medium-sized Enterprise  

Sustainable Development Goal 

Specific Objectives 

SOLVIT 

Solutions to problems with your EU rights 

SWD 

TFEU 

UN 

Staff Working Document 

Treaty on the Functioning of the EU 

United Nations 

UNCRPD 

UN Convention on the Rights of Persons with Disabilities 

WHO 

World Health Organisation  

List of Member States 

AT  Austria  

iii 

 
 
 
 
 
 
BE  Belgium 

BG  Bulgaria 

CY  Cyprus 

CZ  Czech Republic 

DE  Germany 

DK  Denmark 

EE 

Estonia 

EL  Greece 

ES 

FI 

FR 

Spain 

Finland 

France 

HR  Croatia 

HU  Hungary 

IE 

IT 

Ireland 

Italy 

LT 

Lithuania 

LU  Luxembourg 

LV  Latvia 

MT  Malta 

NL  The Netherlands 

PT 

PL 

Portugal 

Poland 

RO  Romania 

SE 

SI 

SK 

Sweden 

Slovenia 

Slovakia 

iv 

 
 
1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The Treaty on the Functioning of the EU (TFEU) and the Charter of Fundamental Rights of the 
EU (EUCFR) establish equality as a cornerstone of EU policies, and the fundamental right to free 
movement of persons  is established by Article 21 of TFEU and Article 45 of  EUCFR. Article 56 
TFEU prohibits restrictions on freedom to provide services to nationals of Member States who are 
established in a Member State other than that of the person for whom the services are intended, as 
well as restrictions to the freedom to receive services from a provider established in another Member 
State1. Around 25% of the EU population have some form  of disability (2021).2 While there was 
significant progress over the last decades in terms of policy and legislation, persons with disabilities 
still face barriers to their full participation in society. In 2019 for example, over half of respondents 
with  disabilities  say  they  felt  discriminated  against3.  To  improve  this  situation,  in  2021  the 
Commission  adopted  the  Strategy  for  the  Rights  of  Persons  with  Disabilities  2021-2030.  It 
contributes to the implementation of several principles of the European Pillar of Social Rights, of 
the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), ratified by 
the  EU  and  all  its  Member  States,  to  the  implementation  of  the  2030  United  Nations  Agenda 
Sustainable Development Goals.  

One of the Strategy’s flagship initiatives is the creation of a European Disability Card. It is included 
in the Commission Work Programme 2023 and the Communication on the Conference on the 
Future  of  Europe.  The  European  Parliament  called  for  the  Card  in  three  resolutions.  In  its 
Resolution of 18 June 2020 on the European Disability Strategy post-2020 it asked the Commission 
to expand the existing pilot project of the EU Disability Card and to ensure that the EU parking card 
for people with disabilities is fully observed in all Member States. The EP welcomed the initiative on 
the European Disability Card in its Resolution of 7 October 2021 on the protection of persons with 
disabilities through petitions and its Resolution of 13 December 2022 towards equal rights for persons 
with  disabilities,  advocating  for  a  legally  binding  and  ambitious  initiative,  covering  a  range  of 
different areas beyond culture, leisure and sport. The European Economic and Social Committee 
adopted the supportive Opinion SOC/765-EESC. The Member States appear generally in favour of 
the initiative.  

The European Disability Card builds on two instruments already in place: the EU parking card and 
the EU Disability Card pilot. The EU parking card for people with disabilities4 was created by 
Council recommendation 98/376/EC and amended in 20085. It provides for a standardised model of 
EU parking card with  a  view of ensuring its mutual  recognition  across the Member States, hence 
facilitating  the  free  movement  of  persons  with  disabilities  by  car.  The  EU  Disability  Card  pilot 
project, tested following the EU Citizenship Report 20136, was carried out in eight Member States 
(Belgium, Cyprus, Estonia, Finland, Italy, Malta, Romania and Slovenia) in 2016-2018 and remained 
in place after the end of the project. The pilot provides a common format for a card for voluntary 
mutual recognition among the participating Member States of the disability status, as established in 

1 C-286/82, Luisi and Carbone v Ministero del Tesoro, ECLI:EU:C:1984:35. 
2 Eurostat database, hlth_silc_12. Available at: link. 
3 Special Eurobarometer 493, Discrimination in the EU, May 2019. 
4 https://europa.eu/youreurope/citizens/travel/transport-disability/parking-card-disabilities-people/index_en.htm  
5 It was amended to extend its application by reason of accession, but no changes were made to its content.  
6 EU citizenship report (2013), Directorate-General for Justice, which included under Action 6: “The Commission will 
facilitate the mobility of persons with disabilities within the EU by supporting, in 2014, the development of a mutually 
recognised EU disability card to ensure equal access within the EU to certain specific benefits (mainly in the areas of 
transport, tourism, culture and leisure)”. 

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accordance with national eligibility criteria or rules, for access to benefits and services in the areas of 
culture, leisure, sport and, in some countries, transport7. 

This  initiative  aims  to  make  it  easier  for  persons  with  disabilities  to  exercise  their  right  to  free 
movement within the EU, for the purposes of benefiting from available preferential conditions when 
accessing  services,  with  or  without  remuneration,  under  equal  conditions  to  residents  with 
disabilities8. It will also contribute to the implementation of the 2030 United Nations Agenda for 
Sustainable Development, as Goal 8 encourages policies that promote sustainable tourism and local 
culture; Goal 10 aims to reduce inequalities; and Goal 11 aims at providing access to safe, affordable, 
accessible and sustainable transport systems for all. 

The European Disability Card could facilitate the application of the EU passenger rights legislation 
adopted between 2004 and 2021 that is applicable to four transport modes: aviation, rail, waterborne, 
and bus and coach transport.9 The initiative is also in line with the recent Directive (EU) 2022/36210, 
which enables the Member States to provide for reduced tolls or user charges as well as exemptions 
from  the  obligation  to  pay  tolls  or  user  charges  for  any  vehicle  used  or  owned  by  persons  with 
disabilities as concerns roads subject to road charging. 

2.  PROBLEM DEFINITION 

People in the EU are increasingly mobile and all have the right to move freely in the EU and to access 
services in all Member States. Nevertheless, in practice persons with disabilities still face hurdles that 
may deter or discourage them from moving freely given physical, cultural, environmental and social 
barriers.11 A recent  Eurobarometer survey  highlighted the difficulty  of finding  information  on the 
accessibility  of  the  destination  for  persons  with  disabilities  or  reduced  mobility  (39%  find  this 
difficult).12  When  travelling  to  other  Member  States,  persons  with  disabilities  may  also  face 
difficulties in accessing services and preferential conditions for persons with disabilities provided by 
some service providers. While statistics are scarce, the findings on these challenges are based on solid 

7 The Study assessing the implementation of the pilot action on the EU Disability Card and associated benefits concluded 
that there is potential for larger-scale action. 
8  The  conditions  for  exercising  this  right  are  set  out  in  the  Free  Movement  Directive  (2004/38/EC),  the  Directive on 
services in the internal market (2006/123/EC), and the Regulation (EU) 2018/302 on addressing unjustified geo-blocking 
and other forms of discrimination in cross-border transactions between a trader and a customer relating to the sales of 
goods and the provision of services within the Union.   
9  Regulation  (EC)  No  1107/2006  concerning  the  rights  of  disabled  persons  and  persons  with  reduced  mobility  when 
travelling by air, Regulation (EU) No 1177/2010 concerning the rights of passengers when travelling by sea and inland 
waterway  and  amending  Regulation  (EC)  No  2006/2004,  Regulation  (EU)  No  181/2011  concerning  the  rights  of 
passengers in bus and coach transport and amending Regulation (EC) No 2006/2004, Regulation (EU) 2021/782 on rail 
passengers’ rights and obligations (recast). This legislation guarantees passengers with disabilities and reduced mobility 
the right to non-discrimination in access to transport and to receive assistance free of charge and, if necessary, adaptation 
of the transport services to their special needs in order to allow them to use the four transport modes as any other citizen. 
See: EU Passenger rights; The passenger rights regulatory framework including rights for persons with disabilities and 
reduced mobility in transport by air, water, bus and coach is currently under review. 
10  
charging of vehicles for the use of certain infrastructures 
11 Elisabeth Kastenholz, Celeste Eusébio & Elisabete Figueiredo (2015), Contributions of tourism to social inclusion of 
persons with disability, 30(8) Disability & Society, 1259-1281; Keunhyun Park, Hossein Nasr Esfahani, Valerie Long 
Novack, Jeff Sheen, Hooman Hadayeghi, Ziqi Song & Keith Christensen (2023), Impacts of disability on daily travel 
behaviour: A systematic review, 43(2) Transport Reviews 178-203; Pagán (2012), Time allocation in tourism for people 
with disabilities’ 39(3) Annals of Tourism Research 1514–1537. 
12 Flash Eurobarometer 499, Attitudes of Europeans towards tourism, Report, November 2021. Available at: link. 

Directive  (EU)  2022/362  amending  Directives  1999/62/EC,  1999/37/EC  and  (EU)  2019/520,  as  regards  the 

2 

 
 
 
 
evidence gathered, e.g. through desk research, consultation of public authorities and experts, online 
surveys, interviews, and multiple reports from academia and the European Parliament (See Annex 2).  

2.1.Background (context) 

Disability assessments in Member States  

The  concept  of  disability  for  all  Member  States  as  State  Parties  to  the  UNCRPD  is  based  on  the 
Article 1 of that Convention. There is no single EU definition of disability, nor any EU requirement 
for mutual recognition of disability status between  Member States, except for  a few limited cases 
included in Annex VII of Regulation 883/2004 on the coordination of social security systems.13  

The  Member  States  have  full  competence  to  define  the  eligibility  criteria  and  the  assessment 
procedures to recognise disability status, in accordance with their national provisions or laws. The 
disability  assessment  has  a  variety  of  policy  functions  such  as  assessments  of  work  capacity,  and 
assessments of needs for support (for ‘long-term care’) or even access to transport or parking cards 
(see Annex 6).  

Estimating the number of persons with disabilities who are travelling  

The number of persons with disabilities in the EU can only be estimated in the absence of systematic 
monitoring  or  statistical  data.  The  information  about  persons  with  disabilities  with  a  nationally 
recognised  disability,  who  are  in  possession  of  the  national  disability  cards  or  certificates,  are 
available only from 14 Member States (BE, BG, HR, CY, DE, EE, ES, HU, IT, LV, LT, MT, PL and 
RO). By extrapolating EU-wide, it is estimated that the overall number of persons with a recognised 
disability and thus  potentially  eligible for all or some preferential  conditions  would be  around 30 
million in EU27. This is comparable to the number of persons with severe disabilities according to 
EU-SILC.14 A subset of these persons travel to other Member States and can face barriers to have 
their disability status recognised. 

Data on persons with disabilities participating in tourism and travelling are scarce. Estimates were 
done based on the 2012-13 data from the Study on travel patterns of persons with disabilities and on 
Eurostat  data  on  the  general  population  participating  in  tourism  (i.e.  travelling  for  at  least  one 
overnight stay in a domestic, foreign country or both) for personal reasons, including also travelling 
in  relation  to  education  or  work  such  as  the  participation  on  seminars,  trainings  or  meetings. 
Travelling for work related purposes, for example attending a meeting, is not explicitly excluded from 
these estimates.15 The year 2019 was used as  a reference year in view of the disruptions to travel 
caused by the Covid pandemic in subsequent years.16 

13 Regulation (EC) NO 883/2004 on the coordination of social security systems. Available at: link. 
14  The number of people with a recognised disability based on the 14 Member States is lower than the number of persons 
with  disabilities  mapped  by  the  EU  statistics.  EU-SILC  is  collecting  data  on  disability  based  on  a  question  on  “self-
perceived” long-standing limitations in usual activities due to health problems for the age group 16+. EU-SILC contains 
two categories as concerns disability (=limitations): “some” and “severe”.  
15 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
European Commission (further “DG GROW Report”). Available at: link; Eurostat database. Available at: link. 
16 Study supporting the Impact assessment of an EU initiative introducing the European Disability Card, prepared by EY, 
Valdani, Vicari & Associati (VVA), Open Evidence and FBK-IRVAPP (“Study supporting the impact assessment”) 

3 

 
 
 
 
The  rate  of  participation  in  tourism  increased  between  2012  and  2019.  The  trend  for  the  general 
population in the EU is expected to be relevant also for persons with disabilities.  By applying the 
2012  gap  in  participation  in  tourism  between  the  two  groups  to  the  2019  data  on  the  general 
population,  it  is  estimated  that  an  upper  bound  range  of  19.33m  (i.e.  62.8%)  persons  with 
recognised disabilities aged 15-64 might have travelled abroad in 2019.17 Not all of them may 
have been effectively travelling or experiencing major obstacles in obtaining preferential conditions.  

Table 1: Participation in tourism between 2012 and 2019 

Member State 

Share of 
persons aged 
15-64 
participating in 
tourism, 2012 

Share of 
persons with 
disabilities 
participating in 
tourism, 2012-
2013 

Participation 
gap in tourism, 
between the 
general 
population and 
persons with 
disabilities, 
2012 

Share of 
persons aged 
15-64 
participating in 
tourism, 2019 

EU 27 

64.4% 

58.1% 

6.3 

69.1% 

Estimated 
number and 
share of 
persons with 
disabilities 
participating in 
tourism, 2019 

19,334,354 
62.8% 

Note: Detailed table with per country information is provided in annex 6, Source: Study for the impact 
assessment based on Eurostat data and DG GROW’s report on accessible tourism in Europe 

Preferential conditions 

Preferential  conditions  provided  to  persons  with  disabilities  are  offered  mainly  for  the  following 
services:18 i) public and private transport; ii) parking; iii) culture; iv) leisure and sport; v) tourism and 
vi) amusement parks. The services may be with or without remuneration, and may be provided by 
private operators or public authorities. The most frequent type of preferential condition is monetary 
support (such as price reduction or free entries and memberships) and exemptions from an obligation 
such as paying for particular services (e.g. certain taxes, electricity or telecommunications services, 
membership fees). Other types of preferential conditions provided include: access to braille and audio 
guides, adapted guided visits (in sign language), specialised support within the recruitment sector, 
receiving priority service (i.e. the ability to skip queues or be served before other customers), reserved 
accessible parking areas, provision of wheelchairs and/or mobility scooters to be used on the premises 
etc.19 

Preferential  conditions  are  also  offered  when  accessing  services  not  for  remuneration.  Examples 
include:  sign  language interpretation  when  using  public  services;  accessible  seating  in  a  public 
concert; loan of a wheelchair or other aid in natural parks; obtaining tourist information in accessible 
formats in a public information point; using a mobility scooter on roads or a wheelchair in bike lanes 
without a fine; assistance on the beach to enter the water, loan of a floating wheelchair; designated 
seats in parks and other public areas, etc.  

17 To obtain an estimate of the number of persons with disabilities travelling in 2019, the share was then multiplied by the 
number of persons reporting “severe” disabilities. The use of the “severe” disabilities data is justified by their resemblance 
with the number of persons with recognised disability status. 
18 Study supporting the impact assessment, see Annex 6 for more details; Classification of services can be found here: 
Complete list of all NACE Code (nacev2.com)   
19 Ibid. 

4 

 
 
 
 
 
Reasons  why  service  providers  decide  to  offer  preferential  conditions  to  persons  with  disabilities 
include:  (i)  ensuring  that  all  their  (potential)  customers  have  access  to  their  services;  (ii)  their 
customers expressing a preference for greater accessibility of services; (iii) following a marketing 
strategy  to  improve  the  visibility/reputation  of  their  services;  (iv)  attracting  a  higher  volume  of 
customers; or (v) receiving financial support from public authorities for such service provision.20  

2.2.What are the problems? 

The ‘problem tree’ below summarises the main problem at stake and the related drivers which this 
initiative tackles, with its underlying consequences for different stakeholders. 

While, as described below, the initiative focuses on persons with disabilities travelling across Member 
States, it addresses two very specific problems, namely the difficulties encountered by persons with 
disabilities to use their parking cards and difficulties to get access to preferential conditions offered 
by service providers in other Member States due to the limited recognition of their respective parking 
and disability cards. It is acknowledged that persons with disabilities face also other barriers such as 
the  limited,  or  even  absence  of,  accessibility  of  the  built  environment  and  some  services  or  the 
discriminatory treatment experienced when compared to persons without disabilities. However, it is 
not the intention of this initiative to tackle those problems, which are being addressed through other 
EU level initiatives, including specific accessibility legislation and standards and a specific proposal 
for equal treatment that is being discussed in the Council since 2008. Hence the specific focus of this 
initiative. 

Figure 1: Intervention logic 

2.2.1.  When  persons  with  disabilities  travel  to  or  visit  other  Member  States,  their  access  to 
preferential conditions including those related to services is hampered as their disability 
status is not recognised. 

The disability status is determined by the assessment of disability of a person in a Member States and 
then  proved  by  national  disability  cards  and/or  certificates,  which  are  also  necessary  to  access 

20 Ibid. 

5 

 
 
 
 
 
preferential  conditions.21  However,  these  national  disability  cards  and/or  certificates  are  often  not 
recognised when persons with disabilities travel to or visit other Member States and would like to 
access preferential conditions. This difficulty was confirmed by many respondents to consultations 
done for this impact assessment (NCAs, CSOs, persons with disabilities). Persons with disabilities 
indicated  that  they  face  challenges  in  proving  their  disability  status  and  using  their  national 
disability  cards  for  accessing  benefits,  getting  assistance  or  accessing  preferential  conditions 
offered  by  services  in  the  host  Member  State22.  The  number  of  persons  with  disabilities 
travelling and experiencing the problems may be small when compared to the total population 
travelling, yet for them these problems are very significant as shown in the answers to the public 
consultation by persons with disabilities (see Annex 2). This initiative would help them to access 
preferential conditions on equal basis with the residents with disabilities of the visited country and to 
improve the predictability and legal certainty of that access. 

The  evidence  collected  indicates  that  more  preferential  conditions  are  available  to  residents  with 
disabilities in comparison to non-residents with disabilities recognised in another Member State. For 
example,  all  Member  States  offer  preferential  conditions  for  public  transport  to  residents  with 
disabilities, while 14 of them were found to also extend such conditions to non-residents23.  

The consequences faced by persons with disabilities and their families are diverse. They may be 
discouraged from travelling to other Member States. This was highlighted by 980 respondents to 
the  public  consultation  (individuals,  civil  society,  public  authorities,  different  organisations).24 
Persons with disabilities also face an additional burden as they are often requested to prove their 
disability status, e.g. by showing medical documentation as their national card is not recognised, in 
order  to  receive  disability-related  preferential  conditions  for  using  certain  services  abroad.  This 
consequence was also identified by the EP study.25  

High  travelling  expenses,  due  to  their  additional  specific  needs,  are  a  key  factor,  which  may 
discourage  many  persons  with  disabilities  from  travelling,26  in  comparison  to  persons  without 
disabilities.27 Such additional costs can be expenses to access and use services (e.g. adapted hotel 
rooms for persons using wheelchairs or requiring personal assistants) or caregivers’ travel. Therefore, 
they highly value preferential conditions offered by the place of destination such as monetary support 
(price  reduction  or  free  access,  including  for  personal  assistants),  exemptions  (from  paying  for 
particular services), and other types of support (access to braille, audio guides, etc.).28  

21 See section 2.1. and Annex 6 for more details on national disability assessment. 
22 In the public consultation 349 persons with disabilities stated that their disability status is not recognised across Member 
States and 377 persons with disabilities specified that their disability card is not accepted when they travel across the EU. 
Specifically, limited provision of preferential conditions offered by certain services to non-residents was mentioned as a 
perceived obstacle by 762 respondents. Annex 6 provides some examples of difficulties encountered. 
23  See Annex 6. Some of those Member States participated in the pilot but decided not to include transport. 
24 Ibid. 
25  European  Parliament,  Priestly,  M.  (2022),  Disability  assessment,  mutual  recognition  and  the  EU  Disability  Card. 
Available at: link. 
26 Alongside physical barriers in accessing both public and private spaces, e.g. transport,  accommodations, attractions, 
cultural venues. Eugénia Lima Devile and Andreia Antunes Moura (2021), Travel by People With Physical Disabilities: 
Constraints and Influences in the Decision-Making Process. 
27 McKercher and Darcy (2018), Re-conceptualizing barriers to travel by people with disabilities, Tourism Management 
Perspectives, 59-66. 
28 Eugénia Lima Devile and Andreia Antunes Moura (2021), Travel by People With Physical Disabilities: Constraints 
and Influences in the Decision-Making Process. 

6 

 
 
 
 
Given the precarious financial situation of persons with disabilities, it can be expected that financial 
concerns are important for their travel decisions.29 In 2021, the at-risk-of-poverty or social exclusion 
rate for persons without disabilities was 18.8% compared to 29.7% for those with disabilities, and 
36.2% for persons with severe disabilities, the latter being considered a reliable proxy for the share 
of the population with recognised disabilities.30  

Consequences for public authorities are mostly additional information requests which constitute an 
additional administrative burden. Examples of requests for clarification were extracted from SOLVIT 
and are listed in Annex 6. These requests came from citizens of AT, SK, HU, DE, and ES. Citizens 
were asking if their national disability cards would be accepted in another Member State, to  what 
preferential  conditions  they  could  have  access,  etc.31  Another  consequence  is  legal  uncertainty  as 
public authorities do not have means to confirm validity of cards in case of doubts about validity of 
a foreign card. There are as well economic impacts on the tourism sector with missed opportunities 
for travel by persons with disabilities as there will be less income for public authorities providing 
services such as is the case for transport.  

Consequences for service providers are difficulties in recognising the diverse national disability 
cards and certificates to provide preferential conditions. Consulted service providers (12 out of 18) 
agreed that the European Disability Card would  simplify the process  of  recognising  the disability 
status of customers with a disability from other EU Member States.32 There are also possible negative 
financial impacts because fewer persons with disabilities and their families are using their services. 

2.2.2.  When travelling by car in the EU, persons with disabilities face difficulties in using their 

EU parking card.  

For  many  persons  with  disabilities,  private  car  transport  is  the  best  or  only  possibility  of  getting 
around independently. The ability to park as close to their destination as possible and the availability 
of reserved parking facilities is key in supporting their autonomy and free movement. The EU parking 
card for persons with disabilities was created in 199833 and is one of the most visible and important 
achievements of EU disability policy. It is widely used by all the Member States. It contributed to the 
(implicit) mutual recognition of the disability status and facilitated the free movement of persons with 
disabilities  in  the  EU.  This  was  confirmed  by  a  majority  of  respondents  to  the  survey  on  the  EU 
Parking  Card  (16/25  NCAs,  6/10  EU-level  CSOs  and  13/23  national  CSOs).  75.4%  (or  908)  of 
respondents to the public consultation (on line standard questionnaire) agreed that the EU parking 
card  facilitates  the  mobility  of  persons  with  disabilities.34  The  card  is  also  known  and  used  as 
confirmed by the majority of respondents to the public consultation (187735). 36 

29 Financial reasons are a key argument for not travelling also among the general population. According to Eurostat, more 
than 60 million people did not participate in tourism “for financial reasons” in 2019. Eurostat database, tour_dem_npsex. 
Available at: link. 2019 was the latest available year for this information. The second main reason for not travelling were 
health reasons (32 465 994 people or 23.99% of the total population). 
30 Eurostat database, EU SILC 2021, HLTH_DPE010. Available at: link. 
31 Study supporting the impact assessment based on SOLVIT, see Annex 6 for details 
32 Study supporting the impact assessment based on Questionnaire on costs targeted at service providers 
33 Council Recommendation of 4 June 1998 on a parking card for persons with disabilities (98/376/EC), link. 
34 EDF recommendations for strengthening the EU Parking Card 2020. Available at: link. 
35  This  figure  includes  response  to  the  online  standard  questionnaire,  the  Easy  to  read  questionnaire  and  Word 
questionnaire. 
36  Study supporting the impact assessment, see Annex 2. 

7 

 
 
 
 
Despite its positive role, users are facing difficulties in the use of the EU parking card. From 2018 to 
2022, around 260 enquiries about the EU parking card were submitted on the SOLVIT platform. Such 
complaints  mainly  regarded  uncertainties  as  to  the  rights  granted  by  the  card  to  persons  with 
disabilities when travelling to  other  Member States (around 30% of cases), mutual  recognition  of 
national  parking  cards,  issued  based  on  the  EU  model  (around  25%  of  cases),  as  well  as  the 
justification for fines received even when showing the EU parking card (around 12% of cases).37 

Problems in using the EU parking card and with its limited recognition were confirmed by the public 
consultation, specifically by 586 respondents with disabilities.38 The Commission took stock of the 
state of play in 2019 and collected information from Member States.39 

As a consequence, persons with disabilities have practical difficulties in exercising their freedom 
of movement. The use of the card is made more difficult due to the uncertainty about whether and 
how they can use it.40 The non-recognition of the EU parking card results in practical disadvantages, 
such  as  not  being  able  to  park  near  the  entrance  of  premises  and  may  bring  limitations  in  use  of 
services and thus unequal treatment when accessing such services. Moreover, they can bear financial 
impacts. For example, 12% of SOLVIT complaints on this topic were about fines. Finally, due to the 
risk of non-recognition of the card in another Member State, persons with disabilities feel discouraged 
from travelling by car across the EU.41 

National differences in the design and implementation of the EU parking card contribute to increasing 
overall enforcement costs for public authorities. Specifically, as reported by the representative of 
an  EU-level  parking  association  interviewed,  the  increasing  divergences  in  the  design  of  the  EU 
parking card across the Member States have highlighted the need to provide parking controllers with 
ad-hoc training on the different types of cards in place.42 There are also economic impacts on the 
tourism sector with missed opportunities for travel by persons with disabilities. 

Consequences for service providers are additional costs and the burden of lengthy document checks, 
and uncertainty how to handle requests or claims from persons with disabilities. 

2.3 What are the problem drivers?                                       

2.3.1.  Drivers  for  problem  area  A:  There  is  limited  acceptance  across  the  EU  of  national 
disability cards and certificates of non-residents with disabilities issued by other Member States 

37 Study supporting the Impact assessment based on the SOLVIT platform, see annex 6 for more details 
38 Study supporting the impact assessment, see Annex 2. 
39 Do not take my spot! – The EU Disability Parking Card, organized by the European Parliament, link. 
40 Study supporting the impact assessment based on Survey targeted at PwDs; Survey targeted at NCAs; Survey targeted 
at other PAs; Survey targeted at EU-level CSOs; Survey targeted at national CSOs; Respondents to the online workshop 
with CSOs held on 22 March 2023 and to the online workshop with NCAs held on 23 March 2023; Evidence collected 
during case study interviews; Public Consultation - Respondents to the standard questionnaire. 
41 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public authorities; 
Survey targeted at EU-level CSOs; Survey targeted at national CSOs; Public Consultation. 
42 Study supporting the impact assessment based on Targeted interview with one EU Parking association. 

8 

 
 
 
 
Preferential conditions provided for persons with disabilities and their personal assistants are reasons 
for  limited  acceptance  of  national  disability  cards  and  certificates  of  persons  with  disabilities 
travelling or visiting other Member States.43  

Insufficient awareness and knowledge of different national disability cards and 

A.1 
certificates  

Very  different  formats  of  national  disability  cards  and  certificates  make  it  difficult  for  service 
providers to verify and recognise them.44 Some national service providers consulted complained that 
they  are  not  familiar  with  all  disability  cards  or  certificates  and  thus  often  do  not  accept  them, 
especially when information is provided in foreign languages.45  

The TFEU and the Directive on services in the internal market (2006/123/EC) prohibit discrimination 
on  the  basis  of  nationality.  However,  service  providers  are  not  aware  and  explicitly  obliged  to 
recognise the disability status certified in a different country of origin. This may lead to discrimination 
on the basis of nationality in some cases, or at least to uncertainty as to whether service providers will 
recognise the disability status. 

A.2  No obligation to accept and limited voluntary acceptance of national disability 
cards and certificates 

There is limited willingness of national authorities and/or service providers to recognise a disability 
card / certificate issued by another Member State, which may apply, in their view, less strict disability 
assessment criteria and procedures than in their own Member State.46   

Differences exist also in the amount and types of preferential conditions available to persons with 
disabilities across the Member States. They are mainly decided and offered on a voluntary basis by 
individual  service  providers.  Only  a  few  Member  States  have  introduced  a  legislative  framework 
establishing the type of benefits offered by services, as defined in the internal market  acquis (and 
mainly provided for remuneration). The mandatory preferential conditions for resident persons with 
disabilities are found in only a few services, with most countries introducing them in public transport 
(23) and in parking (18). Differences also concern preferential conditions made available to personal 
assistants of persons with disabilities. A detailed mapping is presented in Annex 6. 

2.3.2.  Driver  B:  National  divergences  in  the  implementation  of  the  EU  parking  cards  for 
persons with disabilities 

43 Study supporting the impact assessment based on Survey targeted at PwDs; Workshops with CSOs and NCAs held 
respectively on 22 and 23 March; Targeted interviews with one academic expert, one EU CSO and one EU body. 
44 Study supporting the impact assessment, 6 Member States have paper disability cards and certificates (AT, DE, EL, 
HU, RO, SK), 16 have plastic cards (BE, CY, CZ, DK, ES, FR, FI, HR, IT, IE, LU, LV, MT, PL, NL, SI), and 3 have a 
mixed format (EE, LT, PT). 
45 Study supporting the impact assessment based on the online workshop with service providers held on 11 May 2023. 
46 Disability assessment in Member States was analysed recently by two studies: Priestley, M., Disability assessment, 
mutual recognition and the EU Disability Card. Study Requested by the PETI Committee, European Parliament (2022), 
link;  Waddington,  L.,  Priestley,  M  &  Sainsbury,  R.,  Disability  assessment  in  the  European  States,  on  behalf  of  the 
Academic network of European disability experts (ANED), with contributions from the ANED country experts, 2018, 
link.  

9 

 
 
 
 
Council  Recommendation  98/376/EC47  (amended  by  Council  Recommendation  2008/205/EC48) 
introduced the EU parking card model for people with disabilities. Despite being one of the most 
important achievements of the EU disability policy, the Recommendation did not fully succeed to 
achieve  a  truly  EU-wide  model  card  recognised  among  all  Member  States,  especially  due  to  its 
voluntary nature. Indeed, its Annex I provided only for minimum standards in terms of the design 
and  layout  of  the  EU  parking  card.  It  leaves  it  to  Member  States  to  adapt  the  card’s  layout  and 
functional  features  to  their  own  priorities  and  needs.  It  does  not  contain  any  provisions  on 
coordination  and  monitoring  by  Member  States.  National  authorities  are  free  to  establish  the 
eligibility criteria for obtaining the card, the management system in place and the issuing authority, 
enforcement, any further elements to be added in the card layout. The model has not been updated 
since  1998  to  reflect  technological  progress,  especially  to  take  into  account  the  risk  of  fraud  and 
forgery of the card, and did not include any security features. In order to better prevent fraud and 
forgeries, 12 Member States49 have added their own security features (such as QR codes, holograms, 
barcodes). This increases differences in the card design. In response to the public consultation 45.6% 
(or 549 replies), 38.4% (or 462), 35.9% (or 432) claimed that differences in terms of design,  the 
possible  fraudulent  use  of  the  card    and  possible  forgeries  hinder  the  implementation  of  the  EU 
parking card.50  

The visual format contains the international  disability symbol representing a wheelchair, which is 
easy to recognise, but the text displayed on the EU parking card is usually printed in the national 
language of the Member State, where the card is issued. This further adds to the difficulties for local 
authorities or service providers of other Member States to understand the text written on the card and 
thus its purpose.51 A further element of complexity is the coexistence of older and newer models of 
cards. Since 2017, in France the EU parking card is progressively being replaced by a new non-EU 
model parking card, i.e. the CMI (‘Carte mobilité inclusion’), yet both of these quite different models 
are currently valid and in use. This has resulted in increasing national differences in: (i) the card’s 
layout,  (ii)  the  parking  rights  granted  to  cardholders,  and  (iii)  the  control  and  enforcement  of  the 
parking card. Such differences sometimes even occur within a single Member State, when the card is 
issued at the regional or local level.52 

It has been found that there is a lack of information on the conditions granted to cardholders across 
municipalities  and  across  the  Member  States.  This  again  creates  uncertainty  for  cardholders  and 
discourages  them  from  travelling.  Indeed,  they  often  do  not  know  what  concessions  are  granted, 
which may result in fines. Member States also have different approaches to control the validity and 
the  proper  use  of  the  EU  parking  card.  In  addition,  parking  and  traffic  control  methods  are 
increasingly digitised and focused on automated checks on the car plate, rather than on manual checks 
on  the  paper-based  EU  parking  card.  In  cities  where  automatic  checks  are  performed,  parking 
cardholders have to register their parking card to their car plate on a local platform (e.g. in Brussels 
or  Milan).  This  means  that  it  is  necessary  to  register  in  a  different  local  platform  when  visiting 
different cities, creating significant uncertainty for cardholders on the rules. They are often required 

47 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 
48 2008/205/EC: Council Recommendation of 3 March 2008 adapting Recommendation 98/376/EC. Available at: link. 
49 AT, BE, DK, ES, FI, IE, IT, MT, NL, PL, SE, SK. Annex 6 contains more information. 
50 Study supporting the impact assessment, more details are in Annex 2. 
51 European Parliament (2022), Priestley, M.,  Disability assessment,  mutual recognition and the  EU Disability Card - 
Progress and opportunities. Available at: link. 
52 Do not take my spot! – The EU Disability Parking Card. Available at: link; Final Report based on Survey targeted at 
national CSOs. 

10 

 
 
 
 
to communicate with local authorities of the city they are going to visit to inform them that they hold 
the EU parking card and to ask how to use it, in order to avoid possible fines.53  

2.4. 

 How likely is the problem to persist? 

In case of no action, persons with disabilities are likely to continue facing uncertainty about access to 
preferential  conditions  when  travelling  abroad  within  the  EU.  When  they  travel  to  other  Member 
States,  the recognition  of their national  disability cards and  certificates will  remain voluntary  and 
limited when it comes to preferential conditions when accessing services. For the positive effects of 
the pilot EU Disability Card to be extended, all Member States should join the initiative.  

Free  movement  and  access  to  services  are  also  affected  by  matters  of  accessibility.  There  are 
comprehensive  rules  on  accessibility  of  trains  and  railway  stations  in  Commission  Regulation 
1300/2014.  Some  (but  not  all)  maritime  ships  have  to  be  accessible  according  to  Directive 
2009/45/EC. Certain (but not all) buses must also be accessible according to Regulation 661/2009. 
There are, however, no EU level accessibility rules on air transport. The incomplete coverage of the 
legislative framework is among the reasons why some persons with disabilities have to rely on private 
cars, rather than public transport. This underlines the importance of the EU parking card.  

The positive role of the parking card in promoting the free movement and parking rights of persons 
with disabilities will continue. However, the problems with its recognition among Member States are 
expected to increase due to technical and digital developments which increase the divergence of the 
models. The number of Member States using automatic number-plate recognition automatic cameras 
is likely to further increase. The paper-based format of the EU parking card is not adequate for such 
innovations. More Member States would likely add security features to prevent fraud.  

The problem is also expected to further grow in magnitude given the ageing of the EU population54 
and higher prevalence of disability in the age category above 65 years.55 Older people with disabilities 
(usually aged 65+) can benefit across the EU from preferential conditions (discounts or reduced fees) 
granted based on age without needing any EU disability card. However, they usually cannot benefit 
in other Member States from preferential conditions for persons with disabilities, such as personalised 
services and assistance, priority service, etc.  

Travelling  patterns  of  the  general  population  in  the  future  can  be  expected  to  continue  a  linear 
increase,  as  was  the  trend  until  2019  before  the  Covid  pandemic.56  To  estimate  future  trends  in 
participation in tourism of persons with disabilities and how the gap between persons with disabilities 
and  the  general  population  will  develop,  data  on  trends  in  participation  in  tourism  of  the  general 
population aged 15 to 64, and survey data on persons with disabilities in the same age group were 
combined to simulate future scenarios. The basic scenario assumes that the gap remains constant. The 
increasing  gap  scenario  is  the  most  pessimistic  and  assumes  that  the  participation  in  tourism  of 

53 Study supporting the impact assessment. 
54  There  has  been  an  increase  in  the  total  EU  population  aged  65+  (from  81  million  in  2013  to  94  million  in  2022), 
Eurostat, Available at: link, and this is predicted to continue in the future from 21.1% of the total population in 2022 to 
31.3 % of the total population by 2100, Eurostat: Available at: link 
55 Eurostat database, hlth_silc_12. Available at: link. 
56 Several projections of future trends in participation in tourism were made for the general population and the population 
of  persons  with  disabilities  for  2022-2030, based  on  past  trends  in  travel  propensity  of  the  population  aged  15  to 64 
(Eurostat database, TOUR_DEM_TOTOT. Available at: link) and survey data on persons with disabilities in the same 
age group (DG GROW Report).  . 

11 

 
 
 
 
persons  with  disabilities  does  not  grow  in  parallel  with  that  of  the  general  population.  Two  more 
optimistic scenarios assume that the travel gap would slightly decrease. In the minimum improvement 
scenario, the share of persons aged 15-64 travelling by 2030 is estimated at 70% for persons with 
disabilities and 75% for the general population. In the most optimistic scenario, the share for both 
groups would be 75 % but that is considered to require a significant improvement in accessibility of 
destinations for persons with disabilities.57   

These last two scenarios are encouraging as a stronger reduction of the travel gap would not happen 
without  major  policy  interventions  aimed  at  improving  physical  and  virtual  accessibility  and  the 
financial affordability for persons with disabilities. The recognition of the disability cards of people 
travelling for the purposes of accessing services under the same preferential conditions as persons 
with  disabilities  residing  in  the  country  they  are  visiting  is  the  third  element  and  the  aim  of  this 
initiative. Indeed, as uncertainty continues as concerns recognition of the disability and parking cards 
to access preferential conditions, the most likely scenario would be that the estimated gap between 
the travel participation of persons with disabilities and the general population remains unchanged. 
The scenarios are further analysed in section 6 on impact of the options. 

Figure 2: Scenarios of future changes in participation in tourism for general population and 
persons with disabilities (age group 15-64)58 

Source: Study supporting the impact assessment 

This  assumption  is  also  supported  by  stakeholders’  feedback,  in  particular  from  persons  with 
disabilities replying to the public consultation. Respondents replied positively59  

•  On the importance of the EU action to facilitate mutual recognition of disability in the EU: 
936  EU  citizens,  62  NGOs,  23  public  authorities,  16  companies/businesses/business 

57 They build on DG GROW’s study on accessible tourism, where respondents were asked about their travel propensity 
under scenarios of “minimum” and “moderate” improvements in accessibility. The former would minimally reduce the 
gap, while the latter would remove the gap. 
58 The age group is 15-64 is the one used in the DG GROW Report. In addition, using this age group addresses the issue 
that there are other preferential conditions for the elderly, irrespective of disability. 
59 Study supporting the impact assessment, Annex 2. 

12 

 
 
 
 
 
associations, 21 academia/research institutions, 20 non-EU citizens and 4 trade unions, and 
695 persons with disabilities across all categories.  

•  On the need to facilitate access to those services offering preferential conditions to persons 
with disabilities: 925 EU citizens, 61 NGOs,  20 public authorities, 14 companies/business 
associations, 20 academia/research institutions, 20 non-EU citizens and 4 trade unions, and 
690 persons with disabilities across all categories.  

•  And  on  the  need  to  improve  the  implementation  of  the  EU  Parking  card  for  persons  with 
disabilities: 
15 
companies/businesses/business  associations,  19  academia/research  institutions,  18  non-EU 
citizens and 4 trade unions, and 631 persons with disabilities across all categories. 

56  NGOs, 

authorities, 

citizens, 

public 

836 

EU 

24 

3.  WHY SHOULD THE EU ACT? 

3.1.   Legal basis 

This  legislative  initiative  falls  under  EU  shared  competence.  It  will  fully  respect  the  subsidiarity 
principle and national powers as it will not affect the mechanisms in place at national level, granting 
the disability status based on national assessments (including issuance of national cards/certificates), 
nor lead to any harmonisation of disability assessment status or disability definition at EU level. 

The Treaties provide for a multiple legal base to meet the objectives of the initiative: 

-  The starting point of the present initiative is to facilitate the free movement of persons with 
disabilities as Union citizens. Its purpose is to ensure that when exercising their right of free 
movement, this  group of EU citizens is not discriminated on the ground of nationality or face 
disadvantages  because  they  do  not  hold  a  disability  card  or  certificate  issued  by  the  host 
Member State (in comparison with persons with a disability recognised in that country).  A 
European Disability card, and / or the European Parking Card for persons with disabilities 
recognised  in  all  Member  States,  will  provide  legal  certainty  with  respect  to  the  access  to 
preferential condition offered by services in other Member States. 

-  The EDC  will  allow cardholders  when travelling  to  benefit  from preferential conditions 
when  accessing  services,  whether  with  or  without  remuneration,  on  an  equal  basis  with 
persons with a disability in the visited Member State. Articles 53/62 TFEU concern services 
provided in the internal market.  

-  With respect to special conditions and preferential treatment to access services in the field of 
transport, including parking facilities, Article 91 TFEU applies. In addition, this Article is 
also relevant since it allowed for the adoption of the 1998 Council Recommendation creating 
the  existing  EU  parking  card  voluntary  scheme,  which  will  be  replaced  by  the  current 
initiative.60 

- 

If and to the extent that the initiative would cover services falling outside the scope of the 
above-mentioned legal bases, Article 21 TFEU, establishing the right to free movement of 
persons, could be added to cover residual services. Article 21 TFEU states that “[e]very citizen 
of the Union shall have the right to move and reside freely within the territory of the Member 

60 98/376/EC, the Council Recommendation was based on Article 75 TEC, now Article 95(1) TFEU. 

13 

 
 
 
 
States, subject to the limitations and conditions laid down in the Treaties and by the measures 
adopted to give them effect”.61 

3.2.   Subsidiarity: Necessity and added value of EU action 

This proposal fully respects the principle of subsidiarity. The different, interlinked objectives of this 
proposal  cannot  be  sufficiently  achieved  by  the  Member  States  independently  but  can  rather,  by 
reason of the scale and effects of the action, be better achieved at EU level. Action at EU level is thus 
necessary.The problem identified has a cross border dimension that cannot be solved by the Member 
States on their own. Since the introduction of the EU parking card in 1998, the Member States have 
not undertaken initiatives to improve the convergence of their models. While the EU Disability Card 
pilot  project  worked  among the 8 participating  Member States, it lacked the EU-wide dimension, 
creating  significant  uncertainty  and  unequal  treatment  of  persons  with  disabilities  travelling  and 
visiting  different  Member  States.  As  the  pilot  project  card  and  its  model  are  voluntary,  the  same 
problems of divergence as with the parking card would likely develop over time. 

The necessity of EU action is directly linked to the cross-border nature of travel and related challenges 
faced by persons with disabilities travelling in the EU, thus the need to ensure an adequate coordinated 
approach among Member States in facilitating access to preferential conditions offered by services 
on  an  equal  basis  to  residents  in  their  country.  Lack  of  action  at  EU  level  would  likely  result  in 
Member States adopting different systems, resulting in continued difficulties with the recognition of 
disability cards and certificates, as well as of the EU parking card, across borders. Should the EU not 
intervene, current differences in national disability cards and certificates would likely also increase, 
and the different treatment of persons with disabilities across the Member States would remain or 
increase further, with adverse effects on the exercise of their free movement rights and their access 
to special conditions or preferential treatment in relation to services. 

EU  action  adds  value  by  introducing  a  mutually  recognised  instrument  (the  European  Disability 
Card),  facilitating  the  free  of  movement  for  persons  with  disabilities  in  the  EU  and  their  equal 
treatment when accessing services compared to residents with disabilities across Member States. The 
evaluation study on the pilot EU Disability Card showed that in the eight Member States participating 
in the project, the EU action has enabled mutual recognition of disability status for the purposes of 
accessing services across Member States that would not have been achieved by Member States acting 
alone.62 In this light, the intervention of the European Commission contributed to the implementation 
of the European Disability Strategy 2010-2020.63 Experiences from the pilot project and the Council 
recommendation show that an EU legal instrument, in this case a Directive, is necessary to ensure 
full implementation of the initiative, adopting the common EU-model and facilitating the access of 
persons with disabilities to preferential conditions.  

61 Article 21(2) TFEU  applies only if an action by the Union should prove necessary to attaint this objective and the 
Treaties have not provided the necessary powers. Depending on the precise scope of the initiative, Article 21(2) TFEU 
may be used to cover its parts that would not be ancilliary and would not fall under the legal basis mentioned above. 
62 European Commission, Directorate-General for Employment, Social Affairs and Inclusion, Chiattelli, C., Abbasciano, 
C., Schizzerotto, A., et al., (2021), Study assessing the implementation of the pilot action on the EU Disability Card and 
associated benefits: final report, available at: link. 
63 European Disability Strategy 2010-2020: A Renewed Commitment to a Barrier-Free Europe, /* COM/2010/0636 final 
*/, available at: link. 

14 

 
 
 
 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

General objective of the European Disability Card initiative 

To facilitate free movement and equal access to services for persons with disabilities in the EU.  

The  European  Disability  Card  initiative  intends  to  facilitate  free  movement  and  equal  access  to 
services of persons with disabilities in the EU. It will facilitate the recognition of the disability status 
for the purposes of accessing services across Member States. When accessing services covered by its 
scope,  European  Disability  Card  holders  would  benefit  from  the  same  preferential  conditions 
provided to persons with disabilities in the host Member State. The aim is to remove difference in 
treatment between residents and visitors with disabilities. This would in turn lead to greater equality 
and  legal  certainty.  It  should  be  acknowledged  that,  due  to  differences  in  national  disability 
assessments and consequently in the levels of disability recognised in different Member States, the 
initiative  cannot  address  the  issues  like  the  access  to  some  specific  benefits  that  are  reserved  for 
persons  with  specific  levels  of  disability  in  individual  Member  States  which  are  provided  in 
accordance  with  their  national/regional/local  rules,  procedures  and  pracitces.  The  scope  of  this 
initiative  is  those  persons  with  disabilities  who  have  a  recognised  disability  status  in  their  own 
Member State and are holders of the European Disability Card and are entitled to recognition and 
rights abroad. The EU does not have competence as regards harmonising the disability assessment, 
therefore options in this area are not considered.  Furthermore, as mentioned before, other specific 
EU initiatives address the issue of accessibility. 

In addition, the initiative intends to improve the functioning of the EU parking card for people with 
disabilities, improving its mutual recognition, preventing forgery and fraud. 

The initiative would decrease the uncertainties faced by persons with disabilities as to the recognition 
of  their  disability  cards  or  certificates,  and/or  EU  parking  cards  and  related  access  to  preferential 
conditions. These uncertainties and difficulties caused by non-recognition of disability status and/or 
EU parking cards are having negative impacts on people’s will to travel and visit other countries. The 
final goal of the initiative is therefore, increased mobility of persons with disabilities.  

Several scenarios of increasing participation in tourism are possible as described in section 2.4. It 
must be clear that the initiative is not intended to solve all the problems that persons with disabilities 
face  when  travelling  but  instead  is  focused  on  promoting  non  discriminatory  treatment  between 
persons with disabilities visiting a country and residents with disabilities when accessing preferential 
conditions  offered  by  service  providers.  The  access  to  preferential  conditions  will  compensate  to 
some extent the financial situation of persons with disabilities travelling. However, it is also not in 
the scope of the EDC to address financial affordability of travel. Moreover, as already mentioned, the 
initiative does not address the accessibility of built or virtual environments, which is addressed by 
other  EU  legislation  (i.e.  the  European  Accessibility  Act  namely  Directive  2019/882  and  related 
standards) and financial support via the EU funds (i.e. shared management funds Regulation (EU) 
2021/1060 requires accessibility). These factors are outside the scope of the initiative. Therefore, the 
initiative  is  not  aiming  to  fully  close  the  disability  travel  gap.  Estimated  modest  contributions  of 
individual  options  to  decreasing  the  travel  gap  and  the  value  added  to  the  market  for  accessible 
tourism are described further in section 6. 

The  European  Disability  Card  will  not  replace  national  disability  cards.  Its  scope  will  not  cover 
benefits  in  the  area  of  social  security  /  social  protection  (i.e.  (non-)contributory  cash  benefits  or 

15 

 
 
 
benefits in kind), access to which is  governed by national rules and, in a cross-border context, by 
Regulations (EC) No 883/200464 and No 987/200965 on the coordination of social security systems. 

Specific objectives 

1.  To facilitate mutual recognition of disability status when persons with disabilities travel to 

or visit other Member States.  

2.  To facilitate use and legal  certainty in the use  of the EU parking card for persons with 

disabilities. 

Both  objectives  intend  to  tackle  the  problem  of  non-recognition  of  national  disability  cards  or 
certificates and difficulties in the use of the EU parking card. The objective is it to provide for the 
tools/instrument  that  would  allow  persons  with  disabilities  to  benefit  from  the  same  preferential 
conditions provided to them in the host Member State and under the same conditions (for example in 
some cases being a resident is a condition to get access to benefits and this condition will remain as 
it applies to persons with disabilities also in the host Member State). The instrument must be secure 
and in line with current digitalisation developments.  

The  specific  objectives  are  consistent  with  the  EU  Treaties  and  other  EU  policies.  They  will 
contribute  to  the  implementation  of  the  European  Pillar  of  Social  Rights  and  the  Strategy  for  the 
Rights of Persons with Disabilities 2021-2030. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

In order to address the challenges identified in the problem assessment in Chapter 2, different options 
have been considered. 

•  The baseline scenario 

•  Policy area A: options aimed at facilitating mutual recognition of disability status in the EU in 

relation to access to services when visiting another Member State 

•  Policy area B: options aimed at facilitating mutual recognition of EU parking cards for persons 

with disabilities, issued based on the EU model 

•  Discarded options 

5.1.   What is the baseline from which options are assessed? 

The baseline scenario means no major policy action and leaving in place two current Cards: the EU 
parking  card  for  people  with  disabilities  based  on  the  1998  Council  recommendation  and  the  EU 
Disability Card adopted in eight Member States on a voluntary basis. The EU Disability Card system 
would  remain,  with  voluntary  inclusion  of  the  areas  of  culture,  leisure,  sports  and  transport,  and 
service providers are expected to continue to offer preferential conditions for persons with disabilities.    

64 Consolidated text: Regulation (EC) No 883/2004 of the European Parliament and of the Council of 29  April 2004 on 
the  coordination  of  social  security  systems  (Text  with  relevance  for  the  EEA  and  for  Switzerland)  Text  with  EEA 
relevance. Available at: link. 
65 Regulation (EC) No 987/2009 of the European Parliament and of the Council of 16 September 2009 laying down the 
procedure  for  implementing Regulation  (EC)  No  883/2004  on  the  coordination  of  social  security  systems  (Text  with 
relevance for the EEA and for Switzerland). Available at: link. 

16 

 
 
 
 
Regarding the use of the EU parking card, the differences in its layout, design and management modes 
across the Member States will continue to impair its mutual recognition. Over time these differences 
would  further  increase  due  to  technical  and  digital  developments  that  are  impacting  on  parking 
control, and prevention of fraud and forgery (inclusion of additional security features). 

5.2. Description of the policy options 

5.2.1.  Policy area A: Options aimed at facilitating mutual recognition of disability status in the EU 

in relation to access to services when visiting another Member State 

The proposed options consider introducing a model European Disability Card (EDC), building on the 
pilot. It also builds on other comparable instruments providing for an EU model format already in 
place: amongst others, the European Health Insurance Card, the Community model for national 
driving licences66 and the European Student Card. Uniformisation or standardisation of security 
standards, formats and specifications have been pursued in the area of travel and residence documents 
(e.g. for identity cards and passports issued to EU citizens or residence cards, residence permits and 
visas issued to third-country nationals).67  

The European Disability Card will not replace national disability cards or certificates, Member States 
remain free to continue issuing national cards as well should they choose to do so. 

•  Mandatory EDC model in all Member States for travelling and/or visiting purposes – 

selected sectors (Policy option A1) 

The initiative would propose  minimum common rules for the model EDC and conditions  for its 
issuing/applications: 

Format: The EDC shall have an EU common model both in digital and physical format. It should 
include some minimum security features such as: i) a QR code on the front and back of the card, 
which certifies the holder’s disability assessment; (ii) a hologram associated to a unique identified 
number to prevent card duplication; (iii) a relief structure in the form of scannable embossed alpha 
numerical information such as Braille printing. 

Eligibility: Persons eligible to receive the EDC shall include EU citizens with recognised disability 
status granted by the Member States of residence and based on this country’s own assessment criteria 
and  procedures,  including  validity/expiration.  The  EDC  would  not  replace  the  national  disability 
cards and certificates. 

66  In addition, in March 2023, the European Commission proposed updated requirements for driving licences and better 
cross-border enforcement of road traffic rules. The aim is to modernise driving licence rules, including the introduction 
of a digital driving licence valid throughout the EU which should help simplify the recognition of driving licences between 
Member States. 
67 Council Regulation (EC) No 1030/2002 laying down a uniform format for residence permits for third-country nationals; 
Regulation (EU) 2019/1157 on strengthening the security of identity cards of Union citizens and of residence documents 
issued to Union citizens and their family members exercising their right of free movemen; Council Regulation (EC) No 
1683/95 laying down a uniform format for visas;  Regulation (EU) 2019/1157 on strengthening the security of identity 
cards of Union citizens and of residence documents issued to Union citizens and their family members exercising their 
right of free movement; Council Regulation of 13 December 2004 on standards for security features and biometrics in 
passports and travel documents issued by Member States. 

17 

 
 
 
 
 
 
 
Scope: The EDC shall apply to the culture, leisure, sport and transport68 sectors following the positive 
results of the pilot project and recommendations to include all the sectors to ensure bigger impact as 
transport  was  included  only  in  two  pilot  countries.  Moreover,  the  EDC  shall  also  provide  that 
preferential conditions offered to personal assistants69 of residents with disabilities are, in accordance 
with  national  rules  and practices,  extended to  personal  assistants and/or accompanying persons of 
EDC holders when travelling and/or visiting across EU. 

•  Mandatory EDC model in all Member States for travelling and/or visiting purposes – 

all service sectors (Policy option A2) 

The initiative would propose  minimum common rules for the model EDC and conditions  for its 
issuing/applications. It would have the same provisions on format and eligibility as policy option 
A1, with the main difference in the scope of the initiative.  

Scope:  The  EDC  shall  apply  to  all  services  with  or  without  remuneration,  provided  by  private 
operators or public authorities, including passenger transport services, including the sectors of Policy 
Option  A1.  Hence  all  preferential  conditions  that  are  currently  offered  by  service  providers  in  a 
Member State to residents with disabilities will be covered. Moreover, the EDC shall provide that 
also  preferential  conditions  offered  to  personal  assistants  of  residents  with  disabilities  are,  in 
accordance with national rules and practices, extended to personal assistants and/or accompanying 
persons of EDC holders when travelling and/or visiting across EU. 

•  Accompanying measures applicable to policy options A1 and A2 

The  Member  States  shall  establish  a  national  accessible  website70  providing  as  a  minimum 
information  on:  (i)  who  is  eligible  for  the  EDC;  (ii)  how  to  obtain  the  EDC;  (iii)  preferential 
conditions available (those set by legislation) to persons with disabilities in the Member States. The 
national website should also include a Frequently Asked Questions (FAQ) section, as well as a section 
where cardholders can submit questions or complaints on the use of the EDC. The national websites 
shall be accessible for persons with disabilities following EU level accessibility standards and contain 
easy-to-read information. Hyperlinks to the national websites shall be included in the Your Europe 
Portal.  The  national  websites  shall  be  available  as  a  minimum  in  the  national  language(s)  of  the 
concerned Member State and in English, and shall be readable by translation tools.  

The Your Europe Portal71 will include a section dedicated to the EDC, including information on: 
(i) the description of the EDC initiative and the related aims, features and benefits; (ii) the hyperlinks 
to the EDC national websites in all Member States. 

68 Transport is the key sector for persons with disabilities and their independent mobility. Indeed, the vast majority of 
respondents to the public consultation believes that it is the most important sector to be included: 94.7% of respondents 
to standards questionnaire and 94% to easy-to-read questionnaire, which is together 3077. 
69  Personal assistants are often formally recognised in the Member States where they are legislated. 
70 In line with requirements of Web Accessibility Directive (Directive (EU) 2016/2102) and Accessibility Standard EN 
301 549 v 3.2.1 
71 The Commission’s official website “Your Europe Portal” provides practical information for persons looking to live, 
work and travel across the EU. The portal already includes a section focused on “transport and disability”, which consists 
of two sub-sections. The first one focuses on the rights of person with disabilities travelling in the EU, while the second 
sub-section  provides  information  on  the  use  of  the  EU  parking  card  for  person  with  disabilities.  Your  Europe  Portal 
available at: link. 

18 

 
 
 
 
 
An  EU-wide  awareness-raising  campaign  will  inform  all  stakeholders  (persons  with  disabilities 
and their personal assistants, accompanying persons (such as family and friends), service providers, 
national authorities, general public, etc.) about the EDC using advertisements and also social media.  

5.2.2.  Policy  area  B:  Options  aimed  at  facilitating  use  and  legal  certainty  in  the  use  of  the  EU 

parking card for persons with disabilities 

•  Option B1: Enhanced/reinforced voluntary EU parking card 

The  EU  parking  card  would  remain  voluntary.  To  improve  its  effectiveness,  Annex  I  to  the 
Recommendation  would  be  amended  so  that  the  EU  model  parking  card  is  complemented  with 
security features to prevent its fraud and forgery (e.g. QR code, hologram, barcode) and avoid paper 
versions. The Commission will support coordination between Member States by issuing EU common 
guidelines concerning the establishment of national databases of cardholders that are accessible 
to responsible authorities in charge of controlling the use of the parking card at the national level. 
These  guidelines  would  focus  on  publicly  available  information  accessible  for  persons  with 
disabilities (e.g. on an accessible website at national or local level) on: (i) where to get and use the 
EU parking card; (ii) how the EU parking card works; (iii) scope of rights associated. 

•  Option B2: Mandatory EU parking card model  

The EU parking card would become mandatory. A legislative act will be introduced repealing 
the current Council recommendation. As in Option B1, the model shall include minimum common 
rules on specific security features to prevent its fraud and forgery, digital features such as QR code, 
hologram,  barcode,  etc.  The  model  introduced  with  the  legislative  act  will  replace  existing  cards, 
issued on the basis of the Recommendation. The Member States shall retain the power to establish 
the eligibility criteria to receive the card as well as to determine the parking rights provided for the 
card at the national level. Thus the principle of subsidiarity will be respected. 

Member States shall establish national databases including, as a minimum, information on the identity 
of  cardholders  and  whether  the  card  is  currently  valid.  National  databases  shall  be  accessible  to 
enforcement authorities in  charge of controlling  the use of the card  at  the national  level.  Member 
States  shall  ensure  that  up  to  date  information  is  available  and  easily  accessible  for  persons  with 
disabilities (e.g. on a website at national or local level) on: (i) where to get and use the EU parking 
card; (ii) how the EU parking card works; (iii) scope of rights associated with the EU parking card. 

•  Accompanying measure for policy options B1 and B2 

The EU portal Your Europe that provides information on how to get and use the current parking 
cards that follow the EU parking card model recommendation would provide links to the national or 
local websites which provide information on the rights associated with the parking cards. 

19 

 
 
 
 
 
5.2.3.  Common accompanying measure for policy options A1, A2, B2 

The Commission will create a committee within the meaning of Regulation (EU) No 182/2011.72 
The committee will assist the Commission. It will be chaired by a representative of the Commission 
and composed of representatives of the Member States. 

5.2.4.  Options discarded at an early stage 

The design of options and the decision to discard certain options is strongly based on experience of 
the EDC pilot project, and on the experience of 98/376/EC Council Recommendation of 4 June 1998 
on a parking card for people with disabilities. The political feasibility of options and their relevance 
also played an important role as well as the views of stakeholders.  

The EDC pilot tested a purely voluntary approach, both as concerns the card design and the decision 
of service providers to participate. The Commission widely promoted the pilot, both to Member States 
and to stakeholders. The pilot was a success within the constraints of its design, which brought several 
limitations, such as only partial coverage of certain services within the selected sectors and of service 
providers. This required a central database to be created, updated and communicated to people with 
disabilities, who still lacked certainty as to the recognition of their status, as it was difficult to keep 
the database updated and the decision on the recognition of the disability Card remained voluntary. 
The options retained for detailed analysis in the IA report overcome these constraints, by ensuring 
predictability for persons with disabilities, legal certainty for all parties, and equality of treatment 
between residents and non-residents with disabilities.  

Experience of the pilot underpins the decision to discard, for example, the introduction of the EDC 
on a voluntary basis, as it would bring additional deviations in the standard (physical and/or digital) 
format of the Card over time (as happened with the Parking card) and associated difficulties for its 
recognition and use. If only few Member States adopt the card voluntarily, they can suffer from first 
mover disadvantage. They bear the costs of issuing the card, while it can be used only in a limited 
way. The full potential benefits for persons with disabilities can only be achieved if all Member States 
participate  at  the same time. The value added of  a mandatory approach is that all Member States 
simultaneously issue and accept the EDC from other Member States. 

Experience  of  the  pilot  also  highlighted  the  limits  of  service  providers  voluntarily  offering  their 
preferential  conditions  to  persons with  disabilities from  other Member  States,  which  resulted in  a 
limited number of participating services, high uncertainty for persons with disabilities, and relatively 
high administrative efforts for Member States to keep information updated. 

Options which did not address the core issue of equal treatment of persons with disabilities, regardless 
of where their disability is assessed, were not pursued (relevance of the options). While the decision 
by a service provider to grant preferential conditions to persons with disabilities remains voluntary 
(unless set by national law), once granted, the same preferential conditions should be available for all 
EDC holders.  

72 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the 
rules  and  general  principles  concerning  mechanisms  for  control  by  Member  States  of  the  Commission’s  exercise  of 
implementing powers. Available at: link. 

20 

 
 
 
 
Options  that  would  fail  to  gather  the  necessary  political  support  for  legislative  adoption  were 
discarded. While the EP resolution calls for a single EU disability definition, this would fall outside 
EU competence. When measured against proportionality, any attempt to introduce such a definition 
would need to go beyond only travel purposes, to include for example social security, a field in which 
it proves difficult to achieve EU level harmonisation. 

All options involving an obviously too heavy administrative burden were not pursued. For example, 
the  pilot  approach  of  the  EDC  involved  “selected  services,”  negotiated  with  each  provider  and 
updated in databases accessible to visitors from other Member States.  

The use of an EU-wide database of documents, presenting the design and security features of various 
national cards, was discarded, given the very high number of service providers across the EU whose 
staff would need to be trained in its use to understand cards or paper certificates from across the EU 
(moreover, not all Member States issue cards or certificates). Service providers would still have the 
discretion to extend or not preferential conditions to non-residents, meaning continued practical and 
legal uncertainty for persons with disabilities on recognition of their cards / certificates. 

A.  Discarded  options  related  to  Policy  area  A  (Policy  options  aimed  at  facilitating  mutual 
recognition of disability status in the EU) 

To introduce an EDC that applies to a list of selected internal market services73 identified as 
priority services 

The effectiveness of this option would largely depend on the establishment of a monitoring system 
to  track services  participating in  the initiative as  well as to  inform  persons with  disabilities about 
participating services and the preferential conditions. It would require the creation and updating of a 
website with all detailed information. However, such a system is not expected to be cost-effective as 
it would entail a disproportionate burden resulting from the regular monitoring of concerned services 
and the establishment of a comprehensive database, including information on preferential conditions 
available to persons with disabilities.   

To establish a Recommendation to introduce the EDC on a voluntary basis in all Member States 
(i.e. improving the baseline scenario) 

The success of this option would largely depend on the willingness of individual Member State to 
implement it. Only if all Member States adopt the voluntary EDC would its mutual recognition while 
travelling  or visiting  be ensured. However, based on the experience of the pilot  EDC, only  a  few 
Member  States  voluntarily  decided  to  adopt  the  EDC.  Even  with  additional  EU  coordination  and 
supporting mechanisms, it is unlikely that more Member States would adopt it.  

To create an EU-wide database outlining the design and security features of the various national 
cards 

Such a database was established for passports74. The database would improve knowledge of different 
formats of the national disability cards and certificates and the EU parking cards issued by different 

73 This option differs from policy option A1 as one refers to the “services” and the other to the “sectors”. 
74 https://www.consilium.europa.eu/prado/en/prado-start-page.html 

21 

 
 
 
 
 
 
countries. However, it would not solve the key problem, which is mutual recognition and willingness 
to  offer  the  same  benefits  and  preferential  conditions  available  to  residents  of  a  Member  State  to 
residents of other Member States. To ensure mutual recognition of the disability status and access to 
preferential  conditions,  including  the  parking  rights,  the  legislative  instrument  is  deemed  to  be 
necessary  also  based  on  experience  with  the  pilot  project  and  the  implementation  of  the 
Recommendation. In addition, managing the database would bring administrative burden. 

To replace national disability cards by the EDC  

The option to replace national disability cards by the EDC was discarded. Persons with disabilities 
who are holders of national cards and have no intention to travel abroad should be able to continue to 
use  their  cards.  Introducing  the  obligation  to  replace  all  national  cards  would  introduce  an 
unnecessarily large administrative burden.  It is not fit for purpose, as the objective of this initiative 
focuses on persons with disabilities who are travelling to and/or visiting other Member States. At the 
same time, Member States would be free to decide whether to progressively replace national cards 
with the EDC. 

B. Discarded option related to Policy Area B (Policy options aimed at facilitating use and legal 
certainty in the use of the EU parking card for persons with disabilities)  

To introduce minimum common requirements towards harmonising national rules regarding 
the rights and benefits granted to card holders 

Discarded due to lack of proportionality and legal base for harmonisation, as this option goes beyond 
what is necessary to achieve SO1 (i.e. ensuring mutual recognition of disability cards when persons 
with disabilities travel in the EU). This option may also raise concerns in terms of political feasibility 
and  implementation  since  the  rights  and  benefits  granted  by  the  parking  card  for  persons  with 
disabilities are set in Member States at national, regional or local level. 

C. Common discarded options for the Policy area A and B  

To establish a system of mutual recognition of disability status either by a common definition 
of disability and or common assessment criteria and procedures 

Discarded  due  to  lack  of  proportionality  and  legal  competence  to  harmonise,  as  this  option  goes 
beyond  what  is  necessary  to  achieve  SO1.  Moreover,  since  the  assessment  of  disability  status  is 
undertaken at the national, regional or even local level according to assessment criteria and related 
procedures enshrined in national legislation, this option could also raise concerns in terms of political 
feasibility and impact on social security benefits and taxation. 

To merge the EU parking card with the new EDC 

Discarded due to a lack of practical and technical feasibility. Indeed, the two cards have different 
eligibility  criteria  and  use,  hence  they  should  be  kept  as  two  distinct  cards.  Also,  stakeholders 
consulted  pointed  out  that  merging  the  two  cards  would  limit  the  possibility  of  persons  with 
disabilities  to  use  both  cards  simultaneously.  The  Member  States  have  also  underlined  that  the 
eligibility for the two cards differs at national level 

22 

 
 
 
5.2.5. Stakeholders’ views on policy options  

The European Parliament in its 2022 Resolution  strongly believes that the European Disability Card 
should be based on a binding EU legislative act that should cover a range of different areas beyond 
culture, leisure and sport. It especially stresses that the Card should also, by default, be usable for 
services provided at national, regional and local level, such as transport, have a dedicated EU website 
and  accessible  online  database  available  in  all  EU  languages,  including  specific  communication 
formats,  like  easy-to-read  language,  Braille  and  sign  language.  It  underlines  that  persons  with 
disabilities and their representative organisations have to be closely involved in the implementation 
of and communication on the Card. 

The  call  for  evidence  consultation  showed  that  out  of  the  272  respondents  the  following  were  in 
favour of an EDC that (i) is mutually recognised across the EU (97 EU Citizens, 20 CSOs, 1 SME, 1 
Other)  –  options  A1  and  A2;  and  (ii)  provides  for  access  to  same  preferential  conditions  already 
granted by Member States to residents with disabilities, regardless of the areas or services (21 EU 
Citizens,  20  CSOs,  7  Other)  –  option  A2.  Some  targeted  interviews  (expert,  1  CSO,  1  EU  body) 
showed less support for applying the card to all services (option A2).  

In the public consultation most respondents expressed the view that the EDC should be binding for 
all Member States, without the possibility of opting out: 867 of 999 EU citizens, 56 of 66 NGOs, 23 
of  29  public  authorities,  18  of  25  companies/business  associations,  20  of  23  academia/research 
institutions, 17 non-EU citizens, 3 consumer organisations, and 661 of 757 Persons with disabilities 
across all categories (options A1 and A2). More than 80% of the respondents agreed that EU action 
is needed to improve the implementation of the EU Parking card for persons with disabilities (options 
B1 and B2).75  

As concerns Member States’ views, all 7 Member States that sent position papers or the 16 Member 
States that spoke in the Social Protection Committee meeting of 3 April 2023 agreed on the existence 
of the problem, the need for EU action and the binding character of the initiative as the appropriate 
means to tackle it. There is also consensus among users and Member States that the EDC and the EU 
Parking  Card  should  be  kept  as  separate  cards  and  that  both  physical  and  digital  cards  should  be 
available to card holders. No other Member States expressed a different view on those matters. 

On 18 October 2022, the Commission adopted its 2023 Work programme  and announced in its Annex 
the adoption of the European Disability Card for 2023 as a legislative initiative with its related impact 
assessment. 

In the following discussions with Member States, the legislative nature of the initiative was stressed 
by the Commisison in its presentations while seeking feedback from stakeholders. The reflection on 
the initiative has been included in each 2022 and 2023 meeting of the Disability Platform, composed 
of  representatives  of  Member  States  (UNCRPD  focal  points  from  all  Member  States)  and  civil 
society, and has been further developed through discussion in a dedicated Sub-group of the Platform. 
In  addition,  the  Commission  discussed  the  initiative  with  Member  States  in  the  Social  Protection 
Committee meeting of 3 April 2023 and further during the meeting on the European Disability Card 
organised  by  Finland  on  17  May  2023  to  support  the  Commission's  preparations.  The  meeting 
conclusions made by Finland reflected well the positive reception of the EDC by Member States and 
highlighted that the EDC initiative is warmly welcomed. Recommendations include careful planning 

75 A synopsis report of the consultations is available in Annex 2. 

23 

 
 
 
 
of the extension of the services covered, no merger of the parking card for persons with disabilities 
with the EDC into a single card, and no coverage of social security and healthcare benefits. Seven 
Member States and one region have so far submitted a position paper (Denmark, Finland, France, 
Hungary, Italy, Poland, Sweden and Bavaria), all of them supportive and none of them expressing 
critical views of the - at the time forthcoming - legislative initiative.  

Where  Member  States  were  critical  and  clearly  opposed  was  the  harmonisation  of  disability 
assessment, giving as the key reason the national competences that in their view they have. Member 
States were also against including in the initiative measures which would oblige service providers to 
grant preferential  conditions to persons with disabilities. They were supportive of the initiative as 
described  in  the  Commission  Work  programme,  namely  “proposing  a  European  disability  card 
ensuring the mutual recognition of disability status across all Member States”. The Commission was 
also clear in its presentations that there was no intention to extend that mutual recognition to cover 
the  area  of  social  security,  and  this  was  welcomed  by  Member  States  given  that  social  security 
coordination is already regulated at EU level. In that context, at least three Member States expressed 
concerns about the different levels of disabilities recognised in some Member States. 

Similarly, there is also consensus among other stakeholders, particularly persons with disabilities and 
also EP and EESC, on the need for the EDC and on it being proposed in legislative form.  

The scope of the EDC (i.e. which services are covered) encounters more diverse views. Persons with 
disabilities  favour  the  widest  possible  scope,  as  do  the  EP  and  the  EESC,  while  Member  States’ 
opinions are more varied. Six Member States expressed their preference to cover those services from 
the pilot, while two others showed openness to extending and one region expressed concerns about 
including  transports. Organisations representing persons with  disabilities  would like  a wide scope 
that would be extended to accessing social security benefits while they await disability assessment in 
a  new  host  country.  This  view  is  also  supported  by  the  EESC.  There  is  strong  consensus  among 
Member States (at least 19 of them were explicit about it) and also civil society that the European 
parking card should not be merged with the new EDC. One measure of concrete success of the EDC 
pilot, showing the support of those Member States that participated, is illustrated by the high number 
of cards issued by the participating countries at their own initiative and costs after the end of the pilot 
funding, as shown in the table below:  

Table 2: The number of EU Disability Cards 

Nº 
Cards 
issued*  during 
Pilot  

Cards 
issued 
during  Pilot  as  % 
of 
coverage 
persons 
with 
disabilities 

Nº  cards 
issued 
until now  (i.e.  incl 
after Pilot) 

Cards  issued  until  now 
(i.e.  incl  after  Pilot)  as   
%  coverage  of  persons 
with disabilities 

BE  66,141 

11.07% 

154,655  

CY  2,110 

14.07% 

FI 

5,157 

1.71% 

5,123 

24,965 

24 

25.89% 

34.15% 

8.32% 

 
 
 
 
 
MT  8,157 

31.77% 

RO  14,111 

SI 

7,589 

1.63% 

4.46% 

25,669 

19,731 

22,794 

100% 

2.234% 

13.40% 

*It  is  assumed  that  all  persons  with  disabilities who  requested  the  Card  received  the  Card. 
Countries in the pilot set in advance the number of Cards they wanted to issue, and most did 
not intend to provide it to all persons recognised as disabled. The Card in Malta is also the 
national disability card, hence 100% coverage. 

5.2.6. Link between policy options and objectives  

The  policy  options  presented  above  all  aim  to  improve  the  access  to  services  of  persons  with 
disabilities when travelling to or visiting other Member States. In this way policy options in areas A 
and B, together with the accompanying measures, correspond to the general objective of the initiative 
to facilitate free movement and equal access to services for persons with disabilities. Policy options 
A1 and A2 provide for a mandatory EDC model to be binding for all Member States. These policy 
options will facilitate the mutual recognition of disability status when persons with disabilities travel 
to or visit other Member States (specific objective 1). Policy options B1 and B2 will both facilitate 
the use of the EU parking card for persons with disabilities, while policy option B2 will contribute to 
a greater extent to increasing the legal certainty in its use (specific objective 2). 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?   

The assessment of each group of policy options address their potential social, economic, digital and 
environmental impacts, impacts on the fundamental rights enshrined in the Charter, and impacts on 
competitiveness  and  SMEs.  Benefits  are  evaluated  qualitatively  and  –  whenever  possible  – 
quantitatively. Costs are monetised whenever possible and, if monetisation cannot be achieved, they 
are  evaluated  qualitatively  or  in  terms  of  their  expected  overall  magnitude.  All  criteria  and 
methodology are described in Annex 3 and Annex 4. 

It is estimated that measures considered under policy area A would likely have stronger impacts in 
those Member States that did not join the pilot EU Disability Card (but not limited to them, as Member 
States which joined the pilot would also strongly benefit from more Member States joining, as the 
benefits of the card can be considered compounded by the number of Member States which have it). 
While under the policy area B impacts are expected to be stronger in those Member States, which did 
not implement additional measures to facilitate the recognition of the parking card (e.g. establish a 
national database of cardholders, adding security features to the card format). 

It should be noted that the analysis of impacts is subject to a certain degree of uncertainty, given the 
general scarcity of data available on travelling of persons with disabilities, the low participation of 
service providers in the targeted surveys and the high number of assumptions applied. 

Firstly, the limited available data on tourism participation and behaviours of persons with disabilities 
seriously constrains the possibility to provide a comprehensive picture. The only available data on a 

25 

 
 
 
 
small subset of key dimensions of interest is given by the DG GROW report on accessible tourism76. 
However, the data dates back to 2012 and there are some concerns about its representativeness to the 
population of persons with disabilities. Secondly, there is limited quantitative evidence on the impacts 
of  the  policy  options  because  of  the  lack  of  data  on  participation  and  behaviour,  the  limited 
information on the specific monetary and especially non-monetary preferential conditions available 
to persons with disabilities, the relevant challenges in estimating the costs of the initiative for national 
authorities and local providers. There is limited information on costs incurred by the pilot Member 
States  during  the  implementation  of  the  pilot  EU  Disability  Card.  Costs  for  service  providers  are 
difficult to assess rigorously due to the low participation of service providers in the targeted survey 
on costs.    

6.1. Assessment of the baseline scenario  

Social impacts  

Under the baseline scenario, the travel gap existing between persons with disabilities and the general 
population may persist, widen further or reduce. The most pessimistic scenario (widening of the travel 
gap) takes into account the financial conditions of persons with disabilities that could worsen in the 
light of the energy transition and continued increase in the price of energy without policies aimed at 
counteracting their regressive effects.77 However, the most likely outcome is that the travel gap would 
remain constant.78 In this case, in the upper bound range 21 million persons with disabilities may be 
participating in tourism by 2030.  

Persons with disabilities will continue to face difficulties in accessing preferential conditions due to 
the limited mutual recognition of disability status. While additional Member States would remain free 
to join the pilot EU Disability Card this is unlikely to happen to a wide extent – at least in the short 
term – given that in the period since the implementation of the pilot no additional Member States has 
joined the initiative and only one (Croatia) is considering doing so. 

Consequently, limited changes in the participation in tourism of persons with disabilities are most 
likely.  Their  engagement  in  tourism  will  continue  to  be  less,  owing  to  the  high  uncertainty  and 
disproportionately higher costs they face relative to the general population when travelling to other 
Member  States,  having  consequences  on  their  mobility  and  restricting  their  personal  and  social 
development, and level of inclusion. Likewise, the level of uncertainty regarding the recognition of 
their EU parking card will remain high, especially when travelling to other Member States leading to 
recurrent parking difficulties  

Economic impacts 

Costs for national administrations 

The costs of the EDC for national administration are because the establishment of the card scheme, 
its  production  and  distribution,  the  setup  of  national  websites  and  the  related  awareness-raising 

76 DG GROW Report. 
77  Boyce,  J.  K.  (2018).  Carbon  pricing:  effectiveness  and  equity.  Ecological  Economics,  150,  52-61;  Köppl,  A.,  & 
Schratzenstaller, M. (2022). Carbon taxation: A review of the empirical literature. Journal of Economic Surveys. 
78 For details, see section 2.4 How likely is the problem to persist? 

26 

 
 
 
 
campaigns. They are assessed based on the pilot EU Disability Card. If other Member States would 
join the initiative, they are expected to incur similar costs. 

At least 190,000 EDC have been issued by 2023. The total implementation costs of the initiative have 
been estimated at between roughly 95,000 EUR and 530.000 EUR.79 Since most of the costs are fixed 
one-off costs80, the cost per Card diminishes as more Cards are being issued, approaching its unit 
production and delivery costs. 

The one-off cost of establishing the national website ranged roughly between 7,500 and 23,000 EUR. 
Awareness raising campaigns ranged from 20,000 to 70,000 EUR. The wide range of costs was due 
to differences in the implementation features chosen voluntarily by Member States. Variable costs 
such as production, delivery and updating of national websites were low. Production and delivery 
costs ranged between EUR 1.02 and 4.54 per card.81 The cost of updating the website was not always 
monitored or some Member States did not report any costs. Among those reporting a positive value 
(Belgium, Finland and Malta; for Slovenia the information was not provided), it ranged from about 
EUR 1,000 to 4,500 over the period 2016 – 2018.82  

It is important to note that only some of the population of persons with disabilities defined by Member 
States  as  eligible  for  the  card  will  actually  apply,  i.e.  those  persons  who  intend  to  travel  to  other 
Member States. Costs for national administrations therefore cannot be extrapolated from the basis of 
the  entire  population  of  persons  assessed  by  a  Member  States  as  having  a  disability;  they  will  in 
practice be much lower. 

For the EU parking card, under the baseline, the costs of updating the security formats and features 
of  national  parking  cards  would  mainly  consist  of  the  redesign  of  the  cards  and  the  printing  and 
distribution  of  the  new  format.  Some  Member  States  have  already  added  security  features  to  the 
standard EU parking card model83, therefore, it can be expected that more Member States will do so 
to  fight  fraud  and  forgery.  The  total  costs  will  depend  on  the  features  added  and  the  number  of 
Member States implementing changes, and cannot be quantified ex-ante. 

National authorities may incur additional costs to collect information and train staff on the different 
formats of the  EU parking cards in  place in  other Member States, even  though  such costs can be 
expected to be minor.  

Costs for persons with disabilities from not fully enjoying cost savings granted by the preferential 
conditions when travelling abroad are estimated to range from roughly EUR 7 to 30 per day for a 4-
day trip if travelling alone, or from EUR 20 to 60 per day if travelling with a personal assistant.84 
These  higher  costs  are  de  facto  foregone  benefits  for  persons  with  disabilities.  It  is  expected  that 

79 Study supporting the impact assessment: Excluding IT and EE, which had not started producing and distributing EDCs 
at the time of the evaluation study of the EU Disability Card pilot projects.  
80 Such as establishing the national website, database, etc. 
81 Study supporting the impact assessment: It appears that including a microchip increases unit costs while other features 
such as holograms or QR codes do not have a large impact on unit costs. 
82 Ibid. 
83 Ibid.: 10 Member States have already included holograms on their national parking cards to make forgery harder, while 
3 Member States also include a QR code (and 3 different Member States use a barcode instead) that can be scanned by 
authorities in charge of enforcing parking rights to check the validity of the card. Please also see section 3.3.2, Table 6. 
84 Ibid. Assessment is based on short, realistic travel routes that a person with disability might take when travelling to 
other Member States. 4-day trip is the standard length of an overnight trip in the EU, discounting one day for international 
travel. For details, see Annex 4. 

27 

 
 
 
 
almost half of persons with disabilities, travelling abroad experienced situation where they haven’t 
benefitted from preferential conditions.85 These costs do not include foregone non-monetary benefits 
that cannot be easily quantified. 

At the same time, EU parking card holders may also incur fines in case their card is not recognised 
in a (destination) Member State. The cost of parking fines varies depending on the Member State and 
can be substantial.86 Due to uncertainty in the recognition of the EU parking card, cardholders may 
opt for the purchase of parking spaces not reserved for them when travelling to other Member States. 
The costs of parking in off-street structures were estimated at around EUR 1,100 per parking space, 
per year in 2013.87 The average cost of parking spots for the general public use was estimated at EUR 
800 per space, per year. Adjusted per inflation and per day (instead of per year), this cost is estimated 
to be roughly EUR 4 per day, which is certainly a lower bound as shorter periods tend to be more 
expensive. Other estimates calculating the average price of parking in 32 European cities have put 
the number at about EUR 3 per hour.88 

Costs for service providers 

Service  providers  from  non-pilot  Member  States  offering  preferential  conditions  to  persons  with 
disabilities  from  other  Member  States  would  continue  to  incur  the  costs  associated  with  the 
difficulties in  verifying  the proof of disability given the differences in  national  disability cards or 
certificates and their lack of forgery and fraud control features. These costs are not quantifiable and 
rather involve time delays and extra burden costs. In addition, they may also miss out on financial 
and non-financial benefits due to the lower number of persons with disabilities from other Member 
States accessing their services.  

The service providers who joined the pilot EU Disability Card initiative will continue to benefit from 
the easy recognition of cardholders from the participating Member States but will still face such costs 
as  concerns  persons  with  disabilities  from  the  other  Member  States.  When  offering  preferential 
conditions  to  persons  with  disabilities  from  other  Member  States,  they  are  likely  to  have  direct 
financial  costs.  However,  this  impact  is  not  expected  to  be  significant,  given  that  customers  with 
disabilities  from  other  Member  States  appear  to  make  up  about  1%  of  the  total  client  base  and  a 
majority of the respondents reported low costs (below EUR 30 per customer).89 

Reduced earnings in the market for accessible tourism for the society and economy 

The limited participation in tourism of persons with disabilities would prevent the full development 
of the market for accessible tourism, the latter being an important component of the tourism industry. 
The average daily spending of persons with disabilities aged 15 to 64 and undertaking overnight trips 
in the EU was estimated at EUR 102 in 2012.90 The total direct economic contribution of accessible 

85 In the Public Consultation, 429 out of 757 (56%) persons with recognised disability answered that they have never been 
denied access to preferential conditions when travelling to other MS. 
86 Study supporting the impact assessment: Fine range between EUR 60 and 300 in Spain, EUR 40 and 80 in Greece, 
EUR 30 and 250 in Portugal and EUR 36 and 144 in Italy. In Germany, the violation of parking rules can result in fines 
ranging from EUR 35 to EUR 110 (estimated by a large provider of car rental services). 
87 Scope of Parking in Europe. Data Collection by the European Parking Association, 2013. Available at: link. 
88 Study supporting the impact assessment 
89 Study supporting the impact assessment based on the Survey targeted at costs for service providers. 
90 DG GROW Report 

28 

 
 
 
 
tourism at the EU level was estimated at EUR 62 billion, with an indirect multiplier of 1.84.91 This 
indirect  impact  includes  the  jobs  created  by  the  tourism  industry  by  the  travel  of  persons  with 
disabilities (around 1.6m persons employed across the EU) and gains for secondary markets related 
to  the  tourism  industry.  Under  the  baseline  scenario,  the  sector  will  fall  short  of  reaching  its  full 
potential.  Considering  a  constant  travel  gap  between  persons  with  disabilities  and  the  general 
population of at least 6%, the economic loss due to the reduced travel of persons with disabilities can 
be estimated at roughly EUR 3.72 billion in the whole EU in 2012 (EUR 4.5 billion in 2023).92 

Digital impacts 

Recent  technological  progress  can  be  expected  to  continue,  bringing  enhanced  digitalisation  for 
stakeholders such as public administrations, service providers and persons with disabilities. 

While  national  administrations  and  citizens  would  likely  benefit  from  EU  funds93  support, 
nevertheless some issues linked to limited digitalisation of national administrations may persist under 
the baseline scenario, at least in the short-term. Indeed, not all Member States have a digital registry 
of persons with recognised disabilities and not all competent authorities make adequate use of digital 
tools.  Still,  Member  States’  authorities  at  the  national  or  local  level  are  moving  to  adopt  such 
databases and improve enforcement of parking rights including for cardholders94. 

Environmental impacts 

Small recurrent or additional emissions can be expected as persons with disabilities travel, but less 
than the general population.95 These lower emissions, however, would be negligible because of the 
small share of persons with disabilities choosing to travel relative to the entire population of persons 
participating in tourism in the EU.  

Fundamental Rights 

Under  the  baseline  scenario,  certain  fundamental  rights  cannot  be  ensured  to  a  greater  extent  for 
persons with disabilities.  

•  Freedom of movement (Art. 45 EUCFR): the lack of mutual recognition of disability status across 
Member  States  for  persons  travelling  hinders  their  possibility  to  fully  enjoy  free  movement 
rights96. 

91 An indirect multiplier indicates the value added generated indirectly for a given 1 euro expense (investment, etc.). The 
basic idea is to measure how a given spending will “ripple” throughout the economy. 
92 Study supporting the impact assessment 
93 The EU’s digital strategy for the next years has pledged a EUR 250 billion investment to boost digitalisation from Next 
Generation EU, and aims at ensuring that 80% of the EU population has basic digital skills by 2030. 
94 Study supporting the impact assessment: in Belgium the national competent authority and municipalities are working 
on a central registration system for car plates, which would also include information on whether car owners are parking 
card holders, in the municipalities of Rome and Milan in Italy, enforcement of parking rights is  currently undergoing a 
digitalisation process which also foresees the implementation of databases of cardholders. 
95 Study supporting the impact assessment 
96 Study supporting the impact assessment: A majority of participants in the workshops with NCAs and CSOs suggested 
that persons with disabilities feel disadvantaged in their free movement, compared to citizens without disabilities. This 
was confirmed by a majority of respondents to the public consultation. The problem can become more significant for 
persons with disabilities who require a personal assistant: if the lack of recognition of the preferential condition for a 
personal assistant impede travel, this could be considered as hindering free movement. 

29 

 
 
 
 
• 

Integration  of  persons  with  disabilities  (Art.  26  EUCFR):  the  lack  of  mutual  recognition  of 
disability  status  would  continue  to  discourage  persons  with  disabilities  from  travelling  and 
participating in tourism across the EU, and this would have negative consequences on their full 
participation in society. 

•  Non-discrimination (Art. 21 EUCFR): some degree of discrimination and inequality in access to 
services would persist across the EU because persons with disabilities would continue to have 
limited  access  to  preferential  conditions  provided  by  services  in  across  the  EU  compared  to 
residents. A significant part of respondents to the public consultation and the targeted survey for 
persons with disabilities declared that they were aware of other persons with disabilities who were 
denied access to preferential conditions in other Member States. This may lead to persons with 
disabilities deciding not to use those services, leading to unequal outcomes.97 

Competitiveness and SMEs 

The baseline scenario is expected to have minor negative impacts on competitiveness and SMEs as 
the market for accessible tourism would be underdeveloped compared to its full potential. This would 
cause missed earnings for companies working in the sector, the great majority of which are SMEs 
according to the World Tourism Organisation.98 

Furthermore, for SMEs offering preferential conditions (17 out of 23 companies responding to the 
targeted survey on costs for service providers were SMEs) the time cost of verifying different national 
disability cards or certificates from other Member States, and the foregone earnings due to the smaller 
number of persons with disabilities travelling as a result of uncertainty, would have a larger impact, 
in proportion to total turnover.99 

6.2. Assessment of policy options aimed at facilitating mutual recognition of disability status in 
the EU in relation to access to services when visiting another Member State (Area A) 

Social impacts 

The policy options are expected to have moderate positive social impacts, larger in the case of option 
A2.  The  EDC  is  likely  to  increase  the  number  of  persons  with  disabilities  travelling  to  other 
Member States100. This impact will be achieved through reduced burden and costs and improved 
access to preferential conditions provided by some services. Under the more optimistic scenarios of 
increased participation in tourism101 this could be expected to range between 70 and 75% by 2030, 
thus growing by between 1.1 and 6.4 percentage points compared to the baseline. This will result in 
300,000 to  2 million additional persons with  disabilities participating  in tourism, compared to  the 
baseline.102  The  travel  gap  between  the  general  population  and  persons  with  disabilities  would 
decrease by 1.1 to 6.3 percentage points. However, as described above such an optimistic increase is 

97 Study supporting the impact assessment 
98 World Tourism Organization (UNWTO, Madrid, 2018), European Union Tourism Trends: “EU destinations counted 
608 thousand accommodation establishments in 2016, mostly small and medium-sized enterprises (SMEs)”. Available 
at: link. 
99 Study supporting the impact assessment 
100 Ibid.: This is evidenced by all the data collections performed in this study and also by the results of the Study assessing 
the implementation of the pilot action on the EU Disability Card and associated benefits. Available at: link. 
101 Figure 2 in chapter 2.4. 
102 Study supporting the impact assessment: Estimates were obtained by comparing different scenarios of changes of the 
travel gap based on developments from 2012 to 2019: DG GROW Report 

30 

 
 
 
 
not realistic as it would be possible only in case of significant EU-wide improvements to accessibility 
and financial affordability of travel for persons with disabilities, in addition to the removal of the 
uncertainty regarding the lack of mutual recognition of disability cards / certificates. 

Therefore, further calculations are made to provide more realistic scenarios that assess the potential 
impact of the policy options on the travel gap. For these calculations a specific question from the 
public  consultation  was  used,  which  asked  respondents  to  assess  to  what  extent  the  European 
Disability Card could increase the number of persons with disabilities travelling in the EU. It must 
be underlined that the estimates should be treated only as estimations and must be interpreted with 
caution. The methodology is described in detail in Annex 8 Based on the above, it is estimated that 
option A1 may reduce the 6.3 percentage points travel gap by between 1.32 and 1.94 percentage 
points. Option A2 would have stronger impact and is expected to reduce the travel gap by between 
2.8 and 4.12 percentage points.103 

Option A2 would strongly reduce the uncertainty for persons with disabilities. Indeed, in the public 
consultation, five sectors that were outside the scope of the option A1 were mentioned by respondents 
among the most frequently used: Phones and Internet (55% of respondents), Travel agencies (22.5%), 
Sports  centres  (13.4%),  Electricity  and  Gas  (12.7%),  Legal  assistance  (8.9%).  Very  similarly,  the 
respondents also indicated sectors outside those covered by option A1 as those they would like to see 
covered by the EDC: Phones and Internet (36.5%), Legal assistance (33.2%), Sports centres (26.7%), 
Travel agencies (23.6%), Electricity and Gas (17.9%), Postal Services (13.2%).  

Policy options A1 and A2 would increase take-up of cultural services, leisure and sports activities 
and transport for persons with disabilities. Almost half of participants with recognised disability in 
the public consultation highlighted that they have been denied access to preferential conditions when 
travelling to other Member States (307 out of 697). For instance, some museums explicitly state that 
foreign  national  disability  cards  or  certificates  “cannot  be  treated”.104  In  addition,  more  service 
providers are likely or very likely to offer preferential conditions also to customers with disabilities 
from other EU Member States if a uniform and reliable EU proof of disability status existed. Service 
providers consulted mentioned the difficulties in verifying the proof of disability status among the 
main reasons for not extending the provision of preferential conditions, which they would otherwise 
provide.105  

An important benefit for persons with disabilities would come from saving in the public and private 
transport sector. Transport is highly valued by persons with disabilities and perceived as crucial by 
CSOs to ensure mobility of persons with disabilities.106 Transport was mentioned as the first sector 
that they would like to see covered by the EDC by 94% of persons with recognised disabilities in the 
public consultation.107  

Accompanying measures are assessed qualitatively. They would enhance positive social impacts from 
the increased knowledge of preferential conditions also in the country of residence resulting from 
awareness raising campaigns and the websites providing information on the existence of the EDC 

103 Ibid. 
104 Study supporting the impact assessment, see Annex 4 for a case of Hungary in individual travellers' journeys. 
105 Study supporting the impact assessment based on Survey on costs targeted at service providers 
106 Only 2 MSs in the pilot EU Disability Card included this sector. Chiattelli, C., Abbasciano, C., Schizzerotto, A., et al., 
(2021), Study assessing the implementation of the pilot action on the EU Disability Card and associated benefits 
107 Study supporting the impact assessment, see Annex 2 for results of the public consultation 

31 

 
 
 
 
and  of  preferential  conditions.  Increased  take-up  of  services  in  sectors  such  as  culture  can  be 
beneficial for personal well-being, social cohesion and better participation in society.108 The actual 
magnitude of such impacts would depend on additional factors, such as the level of accessibility of 
the sectors involved.  

Economic impacts 

Policy options A1 and A2 would create both benefits (mainly in the form of cost savings) and costs 
for stakeholders, in particular service providers. It would also create cost for public adminsitrations 
that  heavily  subsidise  the  transport  sector.  However,  these  costs  would  be  compensated  by  the 
additional persons travelling accompanying persons with disabilities such as family and friends who 
will pay the travel themselves. 

Distributional impacts across Member States  

To explain the expected distributional impact of the initiative it is important to understand that the 
travel  pattern  of  persons  with  disabilities  does  not  necessarily  follow  traditional  tourism  patterns 
followed  by  the  general  population,  for  example  “summer  north/south  travel”.  Evidence  from  the 
evaluation of the pilot EDC109 showed that neighbouring countries are the first destination of choice 
for persons with disabilities since the geographical closeness makes travel easier and cheaper. The 
stakeholder consultations conducted in the context of the previous evaluation confirmed the need to 
extend the EDC to all Member States, and in particular to neighbouring countries of current pilot 
Member  States,  in  order  for  the  EDC  to  facilitate  the  cross-border  mobility  of  persons  with 
disabilities. Based on this evidence, it can be assumed that geographic proximity will affect travel 
patterns of cardholders of the new EDC. In turn, the distributional impacts of the new EDC will be 
equally distributed across all Member States as all of them have neighbouring countries, thus being 
potential destinations of persons with disabilities travelling across the EU.   

Impacts on persons with disabilities 

Improving access to preferential conditions for persons with disabilities travelling to other Member 
States would reduce their costs in comparison to baseline situation, but not necessarily completely 
eliminate them. Most monetary preferential conditions, such as reduced tariffs and tickets, are in the 
transport, culture, and leisure sectors. So both options A1 and A2 are likely to significantly reduce 
those costs for persons with disabilities. In a case in which the duration of the stay increases up to 2 
months, total savings are estimated at EUR 100 to 400.110  For option A2, benefits would be higher, 
as they include also other sectors and non-monetary benefits.  

Impacts on service providers 

Policy options A1 and A2 are likely to lead to benefits, i.e. cost savings for service providers already 
offering preferential conditions to persons with disabilities from other Member States as they won’t 
have  to  check  diverging  national  disability  cards  or  certificates  anymore.  12  out  of  18  service 

108  Anheier, H. K., List, R. A., Kononykhina, O., & Cohen, J. L. (2017). Cultural participation and inclusive societies: 
A thematic report based on the indicator framework on culture and democracy. Council of Europe. 
109 Chiattelli, C., Abbasciano, C., Schizzerotto, A., et al., (2021), Study assessing the implementation of the pilot action 
on the EU Disability Card and associated benefits. Available at: link. 
110 Study supporting the impact assessment, a detailed description of how the estimates of cost savings for persons with 
disabilities were obtained and elaborated is provided in Annex 3. 

32 

 
 
 
 
providers, who are in such situation, considered that a tool such as the EDC could simplify the process 
of recognition of disability status to a moderate, high or very high extent.111 Five service providers 
who do not yet offer preferential conditions to non-residents would expect a positive or no impact in 
terms of benefits to costs ratio; none was expecting a negative impact. Most expected at least some 
benefits  in  terms  of  visibility,  reputation,  quality  of  services,  perception  on  the  importance  of 
accessibility,  higher  volume  of  customers  from  the  EU,  insights  for  future  developments  of 
services.112  

The costs for service providers are not expected to be significant. Even in the most optimistic scenario, 
where the travel gap of persons with disabilities closes with respect to the general population, the 
growth in the number of persons with disabilities travelling would not be significant enough to impact 
the client base of service providers from other Member States, and the range of persons with disability 
would  remain  between  1  and  2%.    Furthermore,  costs  for  service  providers  are  potentially 
compensated  by  an  expansion  of  their  client  base  resulting  from  increased  accessibility  of  their 
services, improved visibility and reputation, or from access of additional customers accompanying 
persons with disabilities, such as family and friends, who are not the personal assistant and therefore 
do not benefit from preferential conditions.113 The example of the pilot EU Disability Card showed 
that the majority of service providers experienced benefits (monetary and non-monetary) which, at a 
minimum, outweighed costs.114 

The evidence from the evaluation of the pilot EDC showed that benefits clearly outweighed the costs 
for service providers. More specifically, the majority of service providers consulted during the pilot 
study stated that:  

•  They attracted new customers by joining the programme. Cardholders are often accompanied 
by additional paying visitors (e.g. friends, family members), who otherwise would not have 
used the services, with the result that service providers actually sell more tickets due to the 
EDC.  Consultations  with  service  providers  conducted  as  part  of  the  present  assignment 
support this: 18 out of 21 service providers reported that cardholders are joined on average by 
1-2 visitors paying a full ticket. 

•  The service providers gained positive visibility through the EDC. 

•  The  service  providers  improved  their  knowledge  regarding  accessibility  and  services  with 
inputs  from  persons  with  disabilities.  More  precisely,  they  affirmed  that  they  better  take 
account  of  persons  with  disabilities  in  their  services  and  have  gained  new  insights  for  the 
future development of their services. 

A specific assessment of costs of offering preferential conditions to persons with disabilities from 
other Member States was carried out for the transport sector, which is both the sector that offers the 
most preferential conditions to persons with disabilities and is most frequently linked to short-term 
stays. These calculations are outlined in Annex 4. Data on preferential conditions offered in a sample 

111 Study supporting the impact assessment based on Targeted survey 
112 Study supporting the impact assessment based on Survey on costs targeted at service providers  
113  Study  supporting  the  impact  assessment  based  on  Survey  on  costs  targeted  at  service  providers:  12  out  of  25 
respondents indicated that customers with disabilities are usually accompanied by at least one paying visitor (such as 
family and friends). 
114 Chiattelli, C., Abbasciano, C., Schizzerotto, A., et al., (2021), Study assessing the implementation of the pilot action 
on the EU Disability Card and associated benefits, Figure 23 and Figure 24. Available at: link. 

33 

 
 
 
 
of 10 countries was collected and assessed in terms of direct costs for transport service providers.115 
By considering the proportion of those who do not yet benefit from preferential conditions, the direct 
costs of offering preferential conditions in the transport sector to persons with disabilities from other 
Member States are estimated to be between 0.1 and 1.9 EUR per capita, up to 0.2 and 3.9 EUR per 
capita  when  extending  the  preferential  conditions  offered  to  personal  assistants,  where  the  range 
depends on the country in question, its tourist flows, and the extent of preferential conditions currently 
offered to nationals.116 

The Member States with the highest costs in transport, in absolute terms, are also the most populous 
ones, which are destinations of the majority of tourism trips in the EU and offer the most generous 
preferential conditions. For example, DE’s costs range between EUR 23.6 and 28 million for persons 
with  disabilites  (aged  15-65)  from  other  Member  States  (including  personal  assistants).  This 
represents 17.8% - 21.0% of the costs of offering the same preferential conditions to all persons aged 
65+. 

Similarly, costs for ES range between EUR 22 and 31 million.117 

The true cost is certainly closer to the lower bound of the estimates for several reasons: firstly, 44% 
is  the  proportion  of  persons  with  a  disability  responding  ever  being  denied  access  to  preferential 
conditions  abroad.  The  proportion  in  the  transport  sector  is  likely  to  be  significantly  lower,  in 
particular with respect to discounted tariffs; secondly, an additional mitigation of the costs comes 
from  the  fact  that  persons  with  disabilities  overlap  with  the  elderly  population,  which  often  also 
benefits from similar preferential conditions. 18 out of 23 service providers responding to the targeted 
survey  were  already  offering  preferential  conditions  to  persons  with  disabilities  from  other  EU 
Member States.118 

Additional adjustment costs for service providers, linked to the implementation of policy options A1 
and A2, may involve small labour costs to be incurred in order to train their staff on recognition. 
While the majority of respondents to the survey did not foresee, as a result of the introduction of the 
EDC, a significant change in such costs, about half of them envisage the possibility of a small increase 
in the cost of training staff for the provision of personalised services.119 While training staff is mostly 
a fixed cost, providing personalised service to the clients is rather a variable cost. 

115 It is important to underline that these costs refer to the direct potential, total burden for transport service providers 
(including  VAT),  irrespective  of  their  status  (public/private/mixed)  and,  if  public,  the  level  of  their  financing  (local, 
regional, national). Moreover, these estimates are very sensitive to two parameters: i) the travel propensity of persons 
with  disabilities  towards  a  given  Member  State,  which  is  unknown,  as  only  an  estimate  of  the  EU-average  of  travel 
propensity for persons with disability is available; ii) the share of persons with disabilities who currently already benefit 
from  preferential  conditions  when  abroad.  This  is  imprecisely  estimated,  due  to  lack  of  data,  and  is  likely  to  vary 
significantly by country and service provider. In the annex, for each of the ten countries on which data was collected, a 
lower and upper bound  range of direct total costs for transport services providers is given, assuming that currently either 
all or no persons with disabilities from abroad have access to preferential conditions.. 
116 Ibid. 
117 Ibid., see Annex 4 
118 Ibid. 
119 Study supporting the impact assessment based on Survey on costs targeted at service providers 

34 

 
 
 
 
Policy options A1 and A2 would also entail some administrative costs for service providers linked to 
yearly reporting on the type of preferential conditions offered (e.g. data collection, data storage, data 
export and communication with national authorities). The costs would not be significant.120 

In general, the adjustment, administrative costs and the cost savings per service provider are expected 
to be comparable for policy options A1 and A2. 

Impacts for national administrations 

The costs linked to the production and distribution of the EDC for Member States are expected to be 
the same for policy options A1 and A2. 19 Member States would have to establish an EDC scheme 
from  scratch  and  incur  such  costs.  An  ex-ante  evaluation  of  implementation  costs  of  this  kind  of 
initiative is made harder by lack of certainty on the actual implementation steps and the efficiency of 
national administrations in implementing the policy. In the EU Disability Card pilot project, costs 
ranged from 1.02 to 4.54 EUR per unit of production and delivery, and 90,000 to 535,000 EUR for 
the total implementation.121 The total estimated costs of producing and delivering the Card for the 19 
Member States under both options A1 and A2 are expected to fall within this range, and might be 
even lower given that the common Card format would reduce design costs. 

Further adjustment costs would arise from non-legislative accompanying measure for A1 and A2, i.e. 
the establishment of national EDC websites providing information on the Cards issued and the service 
providers offering preferential conditions. These costs are not expected to deviate significantly from 
those incurred by participants in the pilot initiative, where the fixed costs of setting up the websites 
ranged between 7,500 and 23,000 EUR per Member State. However, they may even be reduced if 
Member  States  follow  a  common  website  format.  The  costs  of  maintenance  of  the  websites  were 
negligible for Member States participating in the pilot, and never exceeded 5,000 EUR per year.  

It is important to indicate that  the experience with the EU Disability Card pilot did not show any 
major unintended consequences in the participating Member States. This can also be attributed to the 
fact that the mechanism envisaged in the proposal – i.e. the issuing of cards to individuals – is already 
usual  practice  in  all  Member  States.  Taking  into  account  the  proportionality  of  the  analysis,  for 
example  the  impact  on  the  transport  sector  is  very  relevant  to  tourism  and  has  a  large  number  of 
preferential conditions, and at the same time is also often subject to subsidies from the public budget. 
Based on the aggregated data on the costs  in comparison to turnover and, as demonstrated by the 
figures  in  annex  4,  the  total  costs  are  assessed  to  be  negligible  (and  by  extension  are  therefore 
negligible also for public service providers). 

Finally, additional costs would be incurred to run the awareness raising campaigns. The costs per 
Member State are not expected to deviate significantly from those incurred by participants in the pilot 
initiative, where they ranged between 21,000 and 70,000 EUR per Member State. Costs related to 
replying to questions, handling complaints and gathering data for the monitoring of implementation 
are not considered here as they are only a small fraction of total costs.  

Wider macroeconomic benefits in the market for accessible tourism 

120 Study supporting the impact assessment based on the online workshop with service providers, held on 11 May 2023. 
121 Chiattelli, C., Abbasciano, C., Schizzerotto, A., et al., (2021), Study assessing the implementation of the pilot action 
on the EU Disability Card and associated benefits, Section 6.2.3, Table 30. Available at: link.  

35 

 
 
 
 
A wider macroeconomic benefit of policy options A1 and A2 would involve an increase in turnover 
for  the  accessible  tourism  market.  The  mutual  recognition  of  disability  status  for  persons  with 
disabilities travelling in the EU would increase their demand for tourism products and cause the sector 
to  moderately  expand.  As  anticipated  in  chapter  6.1.  on  the  impacts  of  the  baseline  scenario,  this 
would  also  have  positive  indirect  effects,  such  as  advantages  for  secondary  markets.  The  overall 
aggregate economic impact reflected in the accessible tourism value added, is estimated to be in a 
range between 1 and 1.5 billion EUR for option A1 and between 2.1 and 3.1 billion EUR for option 
A2.122 It is important to underline that, given the way it is calculated, this figure includes the value 
added generated by persons with disabilities given all their activities and spending when travelling. 
As such, it is not limited to activities carried out within the specific sectors specified or not specified 
by the policy options (A1 or A2). In short, it has to be understood as the extra value added generated 
by all activities of persons with disabilities when travelling.  For each policy option, the impact is 
calculated by multiplying the impact in terms of the travel gap with the value added of the market 
due to travels from persons with disabilities obtained from the DG GROW report and adjusting it for 
inflation over the period 2012-2023.  

Digital impacts 

Policy options A1 and A2 would entail similar limited positive indirect digital impacts. One digital 
impact of the policy options would entail limited improvements in the digital skills of persons with 
disabilities as they would be incentivised to use digital tools such as the national and EU websites to 
obtain information on the rights granted to them by the Card, its eligibility criteria and the preferential 
conditions offered. This impact would be greater, the better the synergies with the Web Accessibility 
Directive mandating accessibility of websites of public sector bodies in the EU would be. 

A  second  digital  impact  would  be  linked  to  the  minimum  common  standards  to  be  followed  by 
national administrations in line with the policy option, including the establishment of a national EDC 
website. The implementation of these standards would entail some improved digitalisation of national 
public administrations in the field of social policy, compared to the baseline. This would also have 
beneficial  effects  on  data  collection  on  persons  with  disabilities,  which  is  insufficient  in  several 
Member States. 

The total EU27 one-off costs for public authorities to build an IT system for digital EDC are estimated 
to be EUR 1.67 million, with recurring maintenance costs estimated at around EUR 250,000 per year 
when issuing cards for all persons reporting “severe” limitations (this is the group of persons with 
disabilities who is likely to get EDCs).123 

122 Study supporting the impact assessment, see Annex 9. 
123 Study supporting the impact assessment. 

36 

 
 
 
 
Environmental impacts 

The environmental impacts would be twofold, but small. Firstly, the negative environmental impact 
of travel may increase due to an increased number of persons with disability travelling within the EU. 
Both options might however redirect some travel from cars to other means of transport, such as public 
transport,  as  it  would  become  easier  for  persons  with  disabilities  to  enjoy  preferential  conditions 
related to transport abroad. This effect is difficult to quantify but might partly offset the environmental 
impact of higher overall mobility of persons with disabilities. 

Secondly, the production of plastic cards is expected to leave an environmental footprint. This impact 
will  vary  depending  on  the  final  format  of  the  card  and  its  features.  Studies  estimate  the  carbon 
footprint of plastic cards similar to the EDC (such as cards used for public transport and access control 
schemes) at around 40g of CO2 equivalent.124 In this context, assuming a future production of EDCs 
in a range between 5 and 16 million,125 the overall environmental footprint would be in the range of 
200 to 640 tonnes of CO2 equivalent, comparable to the total yearly of emissions of around 60 EU 
residents.126 

In  conclusion,  both  policy  options  are  not  expected  to  have  significant  impacts  on  the 
environment. 

Fundamental rights 

Policy options A1 and A2 would have strong positive impacts on ensuring certain fundamental rights 
within the EU. 

•  Freedom of movement (Art. 45 EUCFR): the policy options would facilitate the free movement 
of persons with disabilities across the EU by reducing difficulties linked to the lack of mutual 
recognition of their disability status.  

•  Integration of persons with disabilities (Art. 26 EUCFR): the policy options would be beneficial 

to ensuring social inclusion and integration of persons with disabilities. 

•  Non-discrimination (Art. 21 EUCFR): the policy options would contribute to the principles of 
non-discrimination  and  equality  in  access  to  services.  The  preferential  conditions  and  the 
personalised services offered in several sectors to persons with disabilities are an important factor 
determining their choice to use such services, as they often suffer greater economic uncertainty 
and  has  special  accessibility  requirements.  This  positive  contribution  to  non-discrimination 
compared to the baseline would, however, be limited by the scope of option A1, only concerning 
the sectors of sports, leisure, culture and transport. In the remaining internal market services, the 

124 Uwe Trüggelmann, Carbon footprint of the Card Industry (TruCert Ltd). Available at: link. By comparison, according 
to the study, the environmental footprint of an average ID Card with more complex features stands at around 50g of CO 2 
equivalent. 
125 Study supporting the impact assessment: The estimates are obtained assuming that the population affected by the EDC 
is equivalent to the number of persons with severe disabilities, whose magnitude has been shown to be a valid proxy for 
the size of the population with recognised disability status. The range is obtained directly assuming a take-up of the Card 
ranging  between  20%  and  60%  of  all  persons  with  severe  disabilities  in  2021  in  the  19  Member  States  that  did  not 
participate in the pilot project, and should therefore be considered as an upper bound given that – according to the findings 
of the study evaluating the pilot project – the actual take-up of the Card may be lower. 
126 Greenhouse gas emission statistics – carbon footprints, Eurostat. Available at: link. According to Eurostat, the average 
amount of per person CO2 emissions in the EU was 7.1 tonnes in 2019. 

37 

 
 
 
 
barriers highlighted in this section would persist. The contribution to this fundamental right would 
be more far-reaching under option A2. 

SMEs and competitiveness 

Policy options A1 and A2 are not expected to have significant impacts on competitiveness and SMEs 
and those that will occur would likely be positive. 

In the targeted survey for service providers, 15 responding SMEs offering preferential conditions to 
persons with disabilities from the EU believed that the EDC would simplify the process of recognising 
the disability status of customers with disability from other Member States, meaning that this category 
of stakeholders would benefit from the options by reducing the time needed to check for the disability 
documents presented by their customers.127 Similarly, all respondents, irrespective if SMEs or large 
companies, believe that extending preferential conditions under the EDC would lead to non-negative 
overall impact in terms of benefits relative to costs.128 

Furthermore, SMEs may experience some positive returns deriving from the small positive economic 
impacts  of  the  policy  in  the  field  of  accessible  tourism,  as  described  in  the  section  on  economic 
impacts, given that many SMEs operate in the tourism sector.129 

6.3. Assessment of policy options aimed at facilitating use and legal certainty in the use of the 

EU parking card for persons with disabilities (Area B) 

Social impacts 

As compared to the baseline scenario, policy options B1 and B2 are expected to have positive social 
impacts, with the impact of B2 being larger. 

Participation in tourism of cardholders is likely to increase as a result of greater certainty regarding 
the full recognition of their EU parking cards when travelling to different Member States. The extent 
of this increase is difficult to quantify. For option B1 the increase is likely to be limited compared to 
baseline, given the voluntary nature of the option. On opposite, the mandatory nature of option B2 is 
expected to reduce uncertainty for persons with disabilities and hence boost their propensity to travel 
more. Thus the estimated impact of option B2 to reducing the travel gap ranges between 0.27 and 0.4 
percentage points.130 In both cases, enhanced participation in tourism would entail a series of positive 
social consequences, ranging from greater inclusion through increased take-up of cultural services, 
to social and personal development. In terms of total magnitude, social impacts related to increased 
participation in tourism are likely to be small compared to baseline, as the number of the EU parking 
card holders with disabilities constitute a small share of the EU population of persons with recognised 
disabilities.  

127 Study supporting the impact assessment based on Survey on costs targeted at service providers 
128 Study supporting the impact assessment based on Respondents to the online workshop with service providers held on 
11 May 2023. 
129 World Tourism Organization (UNWTO, Madrid, 2018), European Union Tourism Trends: “EU destinations counted 
608 thousand accommodation establishments in 2016, mostly small and medium-sized enterprises (SMEs)”. Available 
at: link. 
130 Study supporting the impact assessment, see Annex 8for explanation of methodology. 

38 

 
 
 
 
Benefits for persons with disabilities would be due to more accessible information on the EU parking 
card conditions, reducing time costs for obtaining the information.131 Cost savings would also come 
from the reduced / avoided fines132 caused by the lack of recognition of EU parking cards and by the 
lack of knowledge on the rights granted in different Member States.133 

Economic impacts 

Impacts for national administrations 

The  benefits  (cost  savings)  would  be  linked  to  a  reduction  in  the  enforcement  cost  for  public 
authorities due to implementation of the enhanced security features of the EU parking card. These 
cannot  be  quantified  precisely,  as  mainly  depending  on  the  time  savings  linked  to  homogeneous 
security features of EU parking cards. Furthermore, the establishment of national databases providing 
information  on  the  number  and  identity  of  residents  that  are  cardholders  would  be  especially 
beneficial  for  enforcement  authorities.134  The  presence  of  such  data  storing  systems  would  make 
enforcement of parking rights easier at the national level, facilitating controls on national cardholders. 
While the two policy options only recommend accessibility of the databases to national authorities 
within  each  Member  State,  it  can  be  expected  that  some  of  them  would  make  the  database  also 
accessible to other Member States thus leading to additional improvements compared to the baseline.  

The main adjustment costs of policy options B1 and B2 would be implementation costs for national 
administrations  to  update  the  card  to  reflect  the  revised  EU  model,  and  its  security  formats  and 
features.135 The total  costs  are  expected to  be minor for  national  administrations.  The majority of 
national authorities reported that the adoption of the EU parking card did not entail significant costs 
for authorities in charge of managing it and issuing it.136 The same can be assumed for the update of 
the card, for which the management system would not change. For option B1, total costs would be 
reduced, given the non-binding nature and the fact that some Member States already updated security 
features of their national parking cards. 10 Member States are already using a hologram to prevent 
forgery  of  the  Card,  and  in  addition,  3  are  using  a  QR  code  and  3  are  using  a  bar  code.  Further 
adjustment  costs  would  be  linked  to  the  establishment  of  the  national  database  of  cardholders, 
foreseen either by the guidelines of option B1 or the minimum requirements of option B2.137 These 
costs would be limited to the Member States not already in possession of such a database and would 
only be incurred by the Member States choosing to implement the updated Recommendation. 

131 Study supporting the impact assessment: 17 out of 24 respondents to the targeted survey for persons with disabilities 
reported that differences in the EU parking cards increased their costs for obtaining information about the different parking 
conditions granted. 
132 Study supporting the impact assessment, the cost of fines are included in Annex 3.  
133 Around 30 complaints received on the SOLVIT platform on the parking card were about fines received by cardholders 
who assumed that the rights granted by the EU parking card when travelling to other Member States were the same as 
those granted in their country of residence. This led to unnecessary costs for persons with disabilities. 
134 Study supporting the impact assessment based on Respondents to the online workshop with CSOs held on 22 March 
2023. 
135 Such as the acquisition of the equipment necessary to print the new cards, the hardware and software necessary to 
implement the new security features (for instance, in the case of QR codes as security features, to produce a QR code for 
each parking card and set up a platform through which these QR codes can be checked, such as the “Handi2Park” app 
used in Belgium, available at: link), and the costs of training authorities on the outlook and functioning of the new features. 
136 Study supporting the impact assessment based on Survey targeted at NCAs. 
137 These would include the cost of software necessary for the creation of the database and its operation, the cost of training 
staff on the functioning of the database, and the cost of staff in charge of technical oversight of its functioning. 

39 

 
 
 
 
For the national websites providing information on the parking card, costs are not expected to deviate 
significantly from those incurred in the context of the pilot EU Disability Card, which entailed the 
set-up of websites to provide information on the card (similarly to what would be carried out in the 
context of option B1, with the parking card). Dividing the costs between fixed set-up costs and annual 
maintenance costs of updating the websites, the fixed costs ranged between EUR 7,524 and EUR 
22,936 per Member State. The annual variable maintenance costs ranged between 0 and EUR 4,652 
per year.138  It should be considered that the final total costs resulting from these estimates would be 
an upper bound, as Member States may decide to incorporate dedicated pages providing information 
on the EDC in already existing national websites on the rights of persons with disabilities. 

Wider macroeconomic benefits in the market for accessible tourism 

The aggregate economic impacts of policy options B1 and B2 would be mainly linked to the potential 
increase in travelling patterns of cardholders, which would affect (although with a limited magnitude) 
the market for accessible tourism. These mechanisms are similar to those already described for the 
baseline and for policy options A1 and A2, but likely to be significantly smaller. The yearly value 
added for accessible tourism139 of option B2 is estimated at 0.2 - 0.3 billion EUR.140 

Digital impacts 

Policy options B1 and B2 are expected to have the same small digital impacts. The difference is that 
for  option  B1,  these  impacts  would  concern  only  the  Member  States  implementing  the  necessary 
measures  to  comply  with  the  updated  Recommendation.  For  option  B2,  they  would  be  more  far-
reaching as they would involve all Member States. Member States establishing national databases of 
cardholders, accessible to national enforcement authorities, will experience limited improvements in 
digitalisation and modernisation in the management of their national parking card schemes. For the 
Member States following the updated Recommendation, the databases have the potential of making 
the control of parking cards more efficient (as authorities could directly check the registration of the 
cardholders in the national database). At the same time, the availability of online information on the 
use  and  application  procedures  for  the  parking  card,  foreseen  by  another  of  the  accompanying 
measures of policy option B1, could encourage use of digital tool by persons with disabilities. For 
this digital impact to occur, however, accessibility of such digital platforms would have to be ensured. 

Environmental impacts 

The environmental impacts of policy options B1 and B2 are negative, but likely to be insignificant 
in magnitude compared to the baseline. The impact would be linked to increased travel by car of 
cardholders following greater certainty in the recognition of EU parking cards among Member States. 
Due to the relatively small numbers of cardholders across the EU, this impact can safely be assumed 
to be negligible. A further impact may be linked to the increased production of the EU parking cards 
to replace previous ones. However, as demonstrated for policy option A2 and considering the lower 
number of parking cards issued, this impact is likely to be insignificant, as it would be lower than the 
emissions produced by 60 EU residents on average in a year. 

138 Study supporting the impact assessment: some Member States reported no significant cost of maintenance. 
139 Accessible tourism widely understood as described in options A1 and A2. 
140 Ibid. See Annex 9. 

40 

 
 
 
 
Fundamental rights 

Policy options B1 and B2 would have strong positive impacts on ensuring certain fundamental rights 
within the EU. 

•  Freedom  of  movement  (Art.  45  EUCFR):  the  policy  options  entail  to  a  greater  extent  a 
facilitation of the free movement of persons with disabilities, as a result of greater certainty in the 
recognition of EU parking cards across the Member States.141  

•  Integration  of  persons  with  disabilities  (Art.  26  EUCFR):  increased  travel  propensity  of 
cardholders and their participation in tourism and subsequent take-up of cultural activities would 
positively contribute to social inclusion and integration to the society of persons with disabilities 
as compared to the baseline. 

Competitiveness and SMEs 

The policy options B1 and B2 are not expected to have any significant impact on competitiveness 
and SMEs. As discussed above, the increased participation of persons with disabilities in tourism due 
to more certainty regarding the recognition of EU parking cards across the EU would be beneficial 
for  the  accessible  tourism  market.  Tourism  is  a  sector  where  SMEs  are  prevalent.  The  impact, 
however, is likely to be very small in magnitude due to the relatively small number of cardholders 
compared to the number of persons with disabilities and the total EU population travelling. 

Summary of estimated impacts per option 

This  table  below  presents  the  figures  related  to  the  accessible  tourism  value  added  in  the  above 
sections  “Wider  macroeconomic  benefits  in  the  market  for  accessible  tourism”  in  two  scenarios, 
namely a more optimistic one assuming a higher reduction of the travel gap of 6.3 percentage points 
and  a  second  scenario  with  a  more  moderate  reduction.  Details  of  the  calculation  are  included  in 
Annex 9.  

Table 3: Estimated impact of the policy options in terms of travel  gap reductions and value 
added in the market for accessible tourism 

Policy 
Options 

Scenario  1  –  assuming  a  higher 
reduction of the travel gap 
Travel  gap reduction 
(percentage points) 

value 

Accessible 
tourism 
added  
1.5 billion EUR 
3.1 billion EUR 
- 
0.3 billion EUR 

Scenario  2  –  assuming  a  moderate 
reduction of  the travel gap  
Travel  gap reduction 
(percentage points) 

value 

Accessible 
tourism 
added 

1.32 
2.8 
negligible 
0.27 

1 billion EUR 
2.1 billion EUR 
- 
0.2 billion EUR 

A1 
A2 
B1 
B2 

1.94 
4.12 
negligible 
0.4 

141 Study supporting the impact assessment based on Survey targeted at NCAs and Survey targeted at EU CSOs, 20 of 25 
NCAs believed that the current weaknesses in the parking card reduce the possibility of persons with disability to exercise 
their right to free movement within the EU. See Annex 2. 

41 

 
 
 
 
 
7.  HOW DO THE OPTIONS COMPARE? 

The  options  for  each  policy  area  (A  and  B)  are  compared  against  the  baseline  for  the  criteria  of 
effectiveness,  efficiency  and  coherence.  When  rating  the  policy  options,  the  social,  economic, 
environmental,  digital  impact  and  the  impacts  on  fundamental  rights,  competitiveness  and  SMEs 
(details in Chapter 6) were all taken into account.  Based on this assessment, a preferred option is 
identified for both policy areas and then described in Chapter 8. 

Policy options are scored from “0” to “+++” (“---") depending on the direction of the impact. “+” (“-
“) represents a very small positive (negative) effect and “+++” (“---") a very large positive (negative) 
effect compared to the baseline. 0 means that the option would not constitute a significant deviation 
from the baseline scenario. The baseline scenario is rated 0.  For details see Annex 4. 

Effectiveness 

The key criteria to assess effectiveness is the extent to which they contribute to the objectives (Section 
5) and they ease the free movement of persons with disabilities within the EU by facilitating (i) mutual 
recognition of disability status when persons with disabilities travel to or visit other Member States 
(Policy area A) and (ii) use and legal certainty in the use of the EU parking card for persons with 
disabilities (Policy area B). Each policy area is assessed separately. See summary overview of the 
effectiveness in Table 3. 

Under Policy area A, both options score positively. By mandating the production and use of a EDC, 
both policy options would effectively create a tool that could be easily recognised across borders for 
the purposes of accessing services by persons with disabilities. The same format across the EU and 
the addition of security features will further enhance its acceptance by reducing risks of fraud and 
uncertainty about the validity of the card. All this will facilitate the mutual recognition of disability 
status of cardholders in other Member States, especially for those with invisible disabilities. Policy 
option A1 is quite effective. In addition to reducing uncertainty it increases access for persons with 
disabilities  to  preferential  conditions  abroad  by  ensuring  the  recognition  through  the  Card  in  the 
sectors that are very important for them: culture, leisure, sports and transport. Policy option A2 is the 
most effective. It would extend the validity of the EDC to all services offering preferential conditions 
(with or without remuneration). This would remove any uncertainty related to the access of provisions 
of  preferential  conditions  abroad,  even  if  most  of  the  preferential  conditions  are  found  in  sectors 
already covered by A1. The certainty of full mutual recognition is the main added benefit of option 
A2 relative to option A1, and the reason why the policy option has a higher score on effectiveness. 

Under  Policy  area  B,  both  options  score  positively.  Introduction  of  common  security  features 
following  the  updated  model  would  make  the  parking  card  more  uniform  across  Member  States, 
facilitating  its  use  and  recognition.  Some  aspects  of  policy  option  B1  would,  however,  limit  its 
effectiveness.  It  would  be  left  to  Member  States  to  decide  whether  to  adopt/implement  the  new 
security features and to adhere to the EU parking card model, as well as when this would be done. 
Thus, the divergences and uncertainty could/would remain. The effectiveness of policy option B2, on 
the other hand, is higher: by taking the form of a binding legislative instrument, the policy option 
would make minimum requirements regarding the EU common parking card model and its security 
format and features mandatory.  

The  accompanying  measures  would  enhance  the  effectiveness  of  all  options.  With  more/better 
information and awareness raising, cards will be easier recognised and used by all stakeholders.  

42 

 
 
 
Table 4 – Comparison of the effectiveness of options under Policy Areas A and B in relation to the baseline  

Specific objective 

Policy Option  Assessment 

Specific  Objective  1:  To 
facilitate  mutual 
recognition  of  disability  status  when  persons  with 
disabilities travel to or visit other Member States. 

Baseline 

Option A1 

Option A2 

Specific  Objective  2:  To  facilitate  use  and  legal 
certainty  in  the  use  of  the  EU  parking  card  for 
persons with disabilities. 

Option B1 

Option B2 

0 

++ 

+++ 

+ 

+++ 

Efficiency 

‘Efficiency’ refers to the assessment of the benefits of each option as opposed to its associated costs. 
As  only  some  benefits  can  be  monetized,  the  efficiency  is  operationalised  as  cost-effectiveness, 
looking  at  each  category  of  stakeholder.  Also  in  this  case,  all  policy  options  are  compared  to  the 
baseline scenario (section 6.1). Table 7 at the end of the Section summarises the efficiency scores of 
the policy options. 

Under Policy area A, both options score positively. For both options, resources will be required by 
national administrations to adapt to EU legislation on the EDC and set up the national schemes for 
correct design and implementation of the Card, including all the additional measures envisaged by 
the policy option. These costs are not expected to differ substantially between policy options A1 and 
A2. The costs for service providers offering preferential conditions would be minor for both policy 
options. In spite of incurring some costs, their expected benefits will offset the costs, as reported by 
all service providers involved in all dedicated data collections.  

As most of preferential conditions in terms of savings are offered in the sectors covered by option 
A1, the greater efficiency of option A2 relative to option A1 comes mostly from the larger reduction 
in uncertainty for persons with disability, which is expected to compound the positive impacts on 
their travel propensity. Removing any uncertainty related to the provision of preferential conditions, 
even  in  sectors  where  reduced  tariffs  and  discounts  are  less  relevant,  option  A2  achieves  greater 
benefits with comparable costs to option A1, and is therefore deemed more efficient. 

Under Policy area B, option B1 would not require Member States to make changes to their national 
parking  card  models.  Therefore,  the  increase  in  benefits  is  uncertain  and  would  likely  be  limited. 
Policy option B2, would entail higher costs compared to the baseline, as it would make the update of 
security features of the EU parking card mandatory for Member States. At the same time, the option 
would also lead to higher cost savings compared to the baseline.  

The  accompanying  measures  would  enhance  the  efficiency  of  all  options.  With  more/better 
information, cards will be easier recognised and used by all stakeholders.  

43 

 
 
 
 
Table 5 – Comparison of the efficiency of options under Policy Areas A and B in relation to the baseline 

Specific objective 

Policy Option 

Specific Objective 1: To facilitate mutual 
recognition  of  disability  status  when 
persons with disabilities travel to or visit 
other Member States. 

Baseline 

Option A1 

Option A2 

Specific Objective 2: To facilitate use and 
legal  certainty  in  the  use  of  the  EU 
parking card for persons with disabilities 

Option B1 

Option B2 

Rating 

0 

++ 

+++ 

0 

+ 

Coherence 

“Coherence”  refers to  the consistency of  each option with  the values, aims,  objectives and policy 
initiatives of the EU. The key ones identified are the EU disability acquis, fundamental rights of the 
EU, UNCRPD, the EPSR. Table 5 summarises the ratings of the policy options in terms of coherence. 

Under Policy area A, both options have the same positive rating. Both policy options would fit into a 
series of EU initiatives that have recently facilitated the movement of persons with disabilities in the 
EU. In this context, an initiative such as the EDC would fill a gap in current legislation. The highest 
degree of coherence of the policy options in reaching specific objective 1 would be reached, however, 
in combination with the pilot EU Disability Card initiative undertaken by the 8 EU Member States 
having already introduced an EDC scheme. Both policy options would absorb the mainstreamed pilot 
initiative and its goal of starting a process of mutual recognition of disability status, extending its 
effects to all EU Member States. Option A1 would maintain the scope of the pilot in terms of sectors, 
while  option  A2  would  extend  the  scope  to  all  services  in  the  internal  market.  Both  would 
consequently be assigned the same ranking. 

Also under Policy area B, both options are assigned the same ranking and are found to be coherent 
with the current EU policy scenarios in terms of parking rights for persons with disabilities.  

Table 6 – Overview of ratings of the baseline and policy options in terms of coherence 

Specific objective 

Policy Option 

Rating 

Specific  Objective  1:  To 
facilitate  mutual 
recognition of disability status when persons with 
disabilities travel to or visit other Member States. 

Baseline 

Option A1 

Option A2 

Specific Objective 2: To facilitate use and legal 
certainty  in  the  use  of  the  EU  parking  card  for 
persons with disabilities. 

Option B1 

Option B2 

0 

+++ 

+++ 

+++ 

+++ 

Subsidiarity and proportionality 

44 

 
 
 
 
 
 
“Subsidiarity and proportionality” refer to whether the policy options are appropriate and do not go 
beyond what is necessary to address the problems satisfactorily. Both policy options concerning the 
European Disability Card respect the principles of subsidiarity and proportionality, and are given the 
maximum  rating  in  relation  to  this  criterion.  They  create  an  instrument  that  acts  as  a  proof  of 
disability, but do not alter national definitions and assessment criteria for disability status. Hence, 
they do not go beyond what is necessary and appropriate for the EU action. This conclusion is based 
on the details provided in the subsidiarity grid in the accompanying document. 

Table 7 – Summary overview of ratings of the options  

Criteria/options 

Baseline 

Policy area A: 
mutual 
Facilitating 
recognition  of  disability 
status in the EU 

Policy area B: Facilitating use 
and legal certainty in the use 
of  the  EU  parking  card  for 
persons with disabilities 

Option A1 

Option A2  Option B1  Option B2 

Effectiveness 

Efficiency 

Coherence 

0 

0 

0 

++ 

++ 

+++ 

+++ 

+++ 

+++ 

+ 

0 

+++ 

+++ 

+ 

+++ 

Potential net benefits of the policy options  

To compute the net benefits of the policy options, a rather conservative approach is taken, considering 
in  the  calculations  the  lower  bound  of  the  accessible  tourism  value  added  impacts  and  taking  the 
upper bound of potential costs, wherever applicable. The increased value added, generated by persons 
with disability travelling more, comprises all the aggregated benefits of the policy options. The costs 
of providing preferential conditions, which are necessary as a result of the EDC, are included in total 
costs even though they represent at the same time a saving for persons with disabilities and would 
cancel each other out. Thus, the final estimate, given the available data and assumptions made,  is 
expected to be a lower bound estimate of the overall net benefit of the policy options.  See Annex 9 
for detailed quatification of the costs. 

Table 8 Total estimates of benefits, costs and net benefits of the policy options 

Policy 
Options 
A1 

A2 

B1 
B2 

Lower  bound 
accessible tourism value added 

total  benefit 

- 

Upper 
total costs  

bound 

Conservative 
benefit estimate 

net 

1 billion EUR 

2.1 billion EUR 

- 
0.2 billion EUR 

0.44 billion 
EUR 
0.53 billion 
EUR 
- 
0.14 billion 
EUR 

0.55 billion EUR 

1.56 billion EUR 

- 
0.056 billion EUR 

8.  PREFERRED OPTION 

Under  Policy  area  A,  the  preferred  option  is  A2  with  the  highest  overall  score  as  well  as  per 
criterion. While the option would have higher total costs compared to the baseline, the magnitude of 

45 

 
 
 
 
 
 
 
 
 
 
these  costs  would  be  limited  for  both  Member  States  and  service  providers,  and  would  be  partly 
compensated  by  cost  savings  for  service  providers  (including  potentially  higher  turnover  due  to 
paying persons accompanying persons with disabilities such as family and friends) and significant 
benefits for persons with disabilities. Option A2 entails higher benefits for persons with disabilities 
also due to the wider scope the EDC would have in terms of services, extending beyond the sectors 
of  sports,  leisure,  culture  and  transport.  At  the  same  time,  total  costs  for  service  providers  would 
increase but would also largely be offset by cost savings and benefits, while implementation costs for 
national administrations in terms of producing, distributing and advertising  the card would remain 
the same. Thanks to its wider scope, option A2 would also lead to improvements in the participation 
in tourism of persons with disabilities thus bringing more pronounced social and economic impacts. 

Under the policy area B, the preferred option is  B2. It is found to achieve the highest score in 
relation to specific objective 2. Option B2 is the most effective in ensuring the mutual recognition of 
EU parking cards, and this translates into its higher score even though it would be slightly more costly 
for Member States than option B1.  

A  combination  of  policy  option  A2  (the  introduction  of  an  EDC  in  all  Member  States  on  a 
mandatory basis) with option B2 (an EU legislative act to provide for the mutual recognition of 
EU parking cards based on a common EU model) is found as the most favourable and thus the 
preferred policy option. 

Option  A2  is  the  most  effective  at  facilitating  the  mutual  recognition  of  disability  status,  as  it 
mandates  the  creation  of  the  EDC  and  can  be  easily  recognised  across  Member  States.  The  EDC 
would eliminate uncertainty for both service providers having to check disability status of customers 
and for persons with disabilities travelling and/or visiting other Member States having to prove their 
disability  status.  Persons  with  disabilities  would  be  able  to  rely  on  a  homogeneous  card  showing 
disability status and valid at the EU level, and thus access preferential conditions across the EU.  

Option B2 is the most effective at facilitating the recognition of the EU parking cards. As a binding 
legislative instrument it makes mandatory the minimum requirements of the EU common parking 
card model  and its  security format and features.  The  common  format of  EU  parking cards would 
reduce uncertainty linked to their recognition in line with specific objective 2. This would encourage 
cardholders to travel to other Member States by car. It would also lead to cost savings, due to using 
public parking slots reserved for persons with disabilities rather than different parking spaces (e.g. 
private parking garages), which may be more costly and less accessible for cardholders. 

The main adjustment costs would be linked to the update of the security formats and features of the 
EU parking cards and to the set-up of national databases to monitor cardholders and enforce parking 
rights. Additional costs would also include the cost of setting up and maintaining national websites 
providing information on the EU parking card, foreseen as an accompanying measure. These would 
be similar to the same costs for option A2.142 

142 All these costs, as well as the benefits of option A2 and B2 are broken down, further detailed and quantified – whenever 
possible – in Annex 3 together with a table detailing the impacts of the measure on competitiveness and SMEs. Overview 
table for all options in added in Annex 8. 

46 

 
 
 
 
In summary, the above mentioned ranges of travel gap reductions for policy options A2 and B2 lead 
to a yearly value added in the market for accessible tourism, with estimates ranging from 2.8 to 4.12 
billion EUR for A2, and from 0.27 and 0.4 billion EUR for B2.143 

After  taking  account  of  the  costs  mentioned  above,  namely  of  offering  preferential  conditions, 
production of the cards, and other additional costs, the possible net benefits of the combination of the 
preferred options are shown below. 

 Table 9: Total conservative estimates for net benefits of the preferred policy options 

Policy Options  Conservative net benefit estimate 

A2 

B2 

1.56 billion EUR 

0.056 billion EUR 

Total (A2+B2) 

1.616 billion EUR 

Policy options A2 and B2 respect the principles of subsidiarity and proportionality of EU action. They 
do not go beyond what is necessary to address the problem identified and achieve specific objectives 
1 and 2. The measures would not impact on the definitions of disability by Member States, which 
would retain the power to determine disability status in accordance with their own assessment criteria 
and procedures enshrined in their national law. Policy option B2 would not affect Member States’ 
power  to  determine  the  parking  rights  granted  to  cardholders  at  the  national  level.  It  would  only 
require  common rules on the model and the security format and features of the EU  parking card, 
justified by the need to ensure full recognition of the card across Member States. 

For the legal bases described in section 3.1, the ordinary legislative procedure applies. Therefore, the 
preferred instrument is a Directive, as it is the common instrument to the legal bases concerned. 

One in one out 

The expected administrative costs for businesses will be marginal. Having one recognisable card 
would save administrative time used for informing staff about the rules on the acceptance of such 
cards, as well as regards handling complaints of persons with disabilities whose national disability 
card is not recognised abroad.  

Based on the evidence available, the European Disability Card does not bear a high cost on service 
providers who have so  far voluntarily participated in  the  pilot scheme. In contrast,  it appears that 
service providers have high economic and social returns due to their participation as they attract new 
customers and gain positive publicity. Possible, although limited, costs could arise from training their 
staff to recognise the Card and from monitoring the use of the card. Businesses might need to bear 
the costs of reduced income (e.g. museums that will charge reduced fees, or parking fees not collected 
from non-national holders of the European Disability Card). However it is not expected that the share 
of non-national disability card holders in the total number of people benefiting from similar discounts 

143 Study supporting the impact assessment 

47 

 
 
 
 
 
 
 
 
 
will be important enough to have a noticeable negative impact on the concerned businesses, and the 
initiative  is  expected  to  entice  more  persons  with  disabilities  to  travel  (jointly  with  friends  and 
family), thus raising the overall return for concerned businesses.  

Persons with disabilites are expected to benefit from the initiative, which will decrease uncertainty as 
to  whether  their  disability  cards/certificates  would  be  recognised  and  they  would  get  access  to 
preferential  conditions.  They  will  have  direct  monetary  benefits  from  preferential  conditions  and 
reduced risk of having to pay fines for lack of recognition of the European Parking Card or having to 
pay for a parking spot. 

9.  HOW WOULD ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

A monitoring framework has been designed with a view to tracking progress towards achieving the 
objectives. It includes a series of core indicators related to the objectives of the initiative. These and 
the related data sources are summarised in Annex 7, table 2.  

The  monitoring  framework  will  be  subject  to  further  adjustment  according  to  the  final  legal  and 
implementation requirements and timeline. The initiative could be evaluated 5 years after it enters 
into force in line with the Better Regulation Guidelines. This would take into account an eighteen-
month period of transposition by Member States, allow sufficient time to evaluate effects on national 
administrations and service providers, which may need some time to adapt to the new rules. 

48 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

Lead DG, Decide Planning/CWP references 

DG  EMPL,  Unit  D3,  has  a  lead  for  the  Impact  Assessment  on  the  European  Disability  Card.  An 
impact assessment was validated in the Decide Planning under reference PLAN/2022/1525. 

Work Programme reference: COM(2022) 548 final 

The Call for Evidence was published in November 2022. The Public Consultation was published in 
February 2023 and finished on 5 May 2023. 

Organisation and timing 

The impact assessment on the European Disability Card was coordinated by an Inter-Service Steering 
Group (ISSG) managed by the Secretariat General, which was established in 2022. Representatives 
from Secretariat General; DG for Employment, Social Affairs and Inclusion; Legal Service, DG for 
Mobility and Transport; DG for Competition; DG for Justice and Consumers; DG EAC; DG ARGI; 
DG for the Internal Market, Industry, Entrepreneurship and SMEs; DG Communications Networks, 
Content  and  Technology;  the  European  External  Action  Service;  DG  for  Neighbourhood  and 
Enlargement Negotiations; DG for Financial Stability, Financial Services and Capital Markets Union; 
were appointed to the Steering Group. 

In total, 7 meetings of the ISSG were organised to discuss this impact assessment (on 20 July and 12 
October 2022, 12 January, 12 May, 9 June, 19 June and 24 July 2023. The ISSG has in addition been 
consulted in writing on interim report and first draft of the final report of the Study supporting the 
impact assessment during Q1-2 2023. 

The Impact Assessment was assessed by the ISSG in two meetings: on 9 June and on 19 June 2023. 

Consultation of the RSB 

The draft impact assessment report was reviewed by the Regulatory Scrutiny Board (RSB) on 18 July 
2023.  The  RSB  delivered  a  positive  opinion  with  reservations  on  19  July  2023.  The  revisions 
introduced in response to the RSB opinion are summarised in the table below. 

49 

 
 
 
 
RSB’s requests for improvement 

Changes made in the IA 

Information  about  the  Member  States’ 
positions was included in the text, in section 
5.2.5. and thoroughly in Annex 2. 

The  chapter  on  impact  of  the  options  –  in 
particular sections 6.2 and 6.3 – was enriched 
by estimates  of the expected  contribution of 
different options to reducing the travel  gap. 
These  estimates  were  also  included  in  the 
tables with benefits and costs. 

The  limits  of  the  initiative  were  clarified  in 
section 4. It is made clear that the scope of the 
initiative  is  intended  not  to  solve  all  problems 
faced  by  persons  with  disabilities  when 
travelling  or  visiting  other  Member  States  but 
rather focus on mutual recognition of disability 
and  access  to  preferential  conditions  on  equal 
basis as residents with disabilities.  

(1)  The  report  is  not  sufficiently  clear  on 
Member  States’  views  and  support  for  the 
problems, and the need for EU legislative action. 
It does not explain on which issues, and why the 
views  of  different  categories  of  stakeholders 
differ.  

The  report  should  bring  out  more  clearly  the 
views of Member States on essential parts of this 
initiative. For example, it should explain to what 
extent  Member  States  support  the  problem 
analysis,  the  proportionality  and  EU  value-
added of policy options, and the justification for 
the  selection  of  the  preferred  option.  It  should 
explain  why  some  parts  of  stakeholder  groups 
do  not  support  some  options  or  measures 
contained therein. 

(2)  The  report  is  not  sufficiently  clear  on  the 
specific  part  of  the  ‘travel  gap’  that  will  be 
tackled by the options considered. It is not clear 
on the expected level of the value added to the 
market for accessible tourism for each option.  

The  report  should  clarify  upfront  that  the 
initiative  is  not  intended  to  solve  all  problems 
facing  disabled  people  when  traveling  but 
instead  is  focused  on  non  discrimination.  It 
should thus clarify the part and the root causes 
of the indicated ‘travel gap’ that will be tackled 
by the options considered in this report and the 
part  of  the  ‘travel  gap’  that  is  due  to  factors 
outside the scope of the initiative. On that basis, 
it should estimate the expected contribution of 
the  options  to  reduce  the  total  ‘travel  gap’ 
(which according to the report amounts to EUR 
4.5 billion of the total value added of the market 
for accessible tourism). It should explain to what 
extent  the  effective  delivery  of  the  options 
depends  on 
the  availability  of  potential 
complementary  measures  (such  as  financial 
support, availability of personal assistants, etc) 
which are outside the scope of this initiative. 

50 

 
 
 
 
(3)  The  report  is  not  sufficiently  clear  on  the 
impacts  on  public  authorities,  institutions  and 
public budgets and on the distributional impacts 
across Member States.  

public 

institutions, 

The  report  should  further  assess  the  impacts, 
costs  and  benefits  for  national  administrations 
and  public  authorities,  including  local  and 
regional 
reflecting 
differences  between  Member  States  as  well  as 
those likely to be most affected. It should assess 
the potential risk that due to the increased travel 
intensity  of  persons  with  disabilities,  public 
interest actors may face resources or budgetary 
in  additional 
challenges  (e.g. 
reserved parking capacity or price increases for 
subsidised  services).  It  should  discuss  more 
thoroughly  the  impacts  on  the  transport  sector 
the  presented 
and  ensure  consistency  of 
estimates throughout the analysis.  

investments 

It  should  analyse  distributional  impacts  across 
Member States, including potential substitution 
effects between domestic and intra-EU travel. 

(4) It does not sufficiently identify and present 
the quantitative cost and benefit estimates of all 
options  as  part  of 
the  effectiveness  and 
efficiency assessment when comparing options. 

The  report  should  better  present  and  integrate 
the available cost and benefit estimates into the 
efficiency  and  effectiveness  assessment  when 
comparing the options, thereby allowing a better 
understanding  of 
the 
efficiency scores between options. 

the  differences  of 

(5) The report should revise the One In, One Out 
section;  it  should  only  include  costs  and  cost 
savings to citizens and businesses. 

(6)  Annex  3  should  provide  the  benefits  and 
costs  of  the  preferred  option  in  an  integrated 
manner so that it is clear what the overall costs 
and  benefits  of  the  preferred  combination  of 
option are. All costs should be presented in total 
aggregate  (EU)  values  (no  cost  estimate  per 
capita, customer, card etc). 

Summary  information  on  costs  was  added 
into  chapter  7  and  new  Annex  9  on 
comparison of the options. The overall table 
on benefits and costs for all retained options 
was  complemented  by  other  benefits/costs 
and is placed in the same new Annex.  

Annex  3  was  revised  to  provide  clear 
overview  of  costs  and  benefits  for  the 
preferred options. 

Information  on  the  distributional  impacts 
was added into section 6.2. The text explains, 
based on the Pilot Project, the travel patterns of 
persons  with  disabilities  leading  to  an  even 
distributional impact among Member States. 

Annex  8  was  added  into  the  report  with 
detailed  tables  on  Comparative  overview  of 
impacts  and  related  ratings 
the 
effectiveness  and  efficiency  criteria,  and 
corresponding description. 

for 

The  One  In,  One  Out  section  at  the  end  of 
section 8 has been revised, only information 
about  costs  and  benefits  for  citizens  and 
businesses are included. 

Annex 3 was revised and presents all costs in 
total aggregate values. Moreover, the overall 
table  on  benefits  and  costs  for  all  retained 
options  was 
complemented  by  other 
benefits/costs and is placed in Annex 8. 

51 

 
 
 
 
 
 
 
 
(7) The competitiveness check (Annex 5) should 
be reviewed; it should better explain the impacts 
on  the  affected  EU  tourism  sectors  and  better 
justify  the  scoring  on  cost  and  price  and 
international elements. 

The competitiveness check that is included in 
Annex 5 was reviewed; estimated costs were 
added  (254  and  353  million  EUR  yearly  for 
A2,  roughly  40  million  EUR  to  55  million 
EUR yearly for B2) for the whole EU together 
with the narrative as concerns the impacts on 
the  EU  tourism  sectors  and  international 
elements. 

Evidence, sources and quality 

The  impact  assessment  is  based  on  several  sources,  using  both  quantitative  and  qualitative  data, 
collected from Member States, organisations of persons with disabilities, civil society. This includes: 

•  Contracted Study supporting the impact assessment carried out by an external, independent 

consultant; 

•  Stakeholder consultation activities (see Annex 2); 

•  The  Commission’s  experience  in  monitoring  and  implementing  the  rights  of  persons  with 

disabilities; 

•  Assessment  of  the  previous  pilot  project  on  the  EU  Disability  Card:  “Study  assessing  the 
implementation of the pilot action on the EU Disability Card and associated benefits”.144 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

INTRODUCTION 

This synopsis report outlines the consultations that were organised as part of the work on the initiative 
on  the  European  Disability  Card  (EDC)  and  the  European  parking  card  and  presents  their  main 
findings in support of the impact assessment.  

CONSULTATION STRATEGY  

Objectives 

144 
en/format-PDF/source-287685618  

https://op.europa.eu/en/publication-detail/-/publication/4adbe538-0a02-11ec-b5d3-01aa75ed71a1/language-

52 

 
 
 
 
 
 
 
 
 
The  objective  of  the  consultations  was  to  collect  factual  evidence  and  views  concerning  possible 
problems and necessary measures related to the free movement and mobility of persons with 
disabilities in the EU to support the preparation of the EDC initiative. 

In particular, the consultation aimed to: (1) gather service providers’ and the general public’s views 
on  the  initiative;  (2)  collect  opinions  and  evidence  on  the  problem  and  various  solutions  (policy 
options) to address it; and (3) create a robust and evidence-based analysis. 

Four key problem areas subject to the analysis are: (1) In the EU, around 85 million persons 16+ 
have some form of disability. They still face barriers to their full participation in society; (2) Persons 
with disabilities face hurdles that may prevent or deter them from moving freely, especially because 
there  is  no  mutual  recognition  of  disability  status  among  Member  States;  (3)  This  lack  of  mutual 
recognition  of  the  disability  status  (national  disability  cards  /  certificates)  may  create  barriers  in 
relation to access to preferential conditions for persons with disabilities provided by some services 
during their travel across borders; and (4) Differing formats of the European parking card hinder its 
recognition in other Member States. 

Stakeholders 

Across these four topics, a wide range of stakeholders operating at the international, EU and national 
levels were consulted: (i) those having an interest in the matter (e.g., national public authorities, 
service providers, NGOs): (ii) potential beneficiaries of EDC and/or European Parking Card (e.g., 
persons with disabilities, personal assistants); and (iii) experts (e.g., researchers, consultancies and 
advisors, international organisations). 

Consultation methods 

The  stakeholder  consultation  included:  (a)  a  public  consultation,  (b)  strategic  and  (c)  targeted 
interviews (10 interviews), (d) six targeted online surveys, (e) three online workshops, (f) six focus 
groups and (g) six case studies. Stakeholders could send comments on the Commission’s (h) Call for 
evidence.  Majority  of  the  consultation  activities  were  organised  by  an  external  contractor  in  the 
context  of  a  study  supporting  the  preparation  of  the  impact  assessment.  The  Commission  also 
consulted  Member  States’  authorities  and  CSO  representing  persons  with  disabilities,  which  are 
members of the Disability Platform. The discussions through meetings and its specific sub-group on 
EDC were key to obtain feedback for its fine tuning. 

The Commission’s minimum consultation standards have been met.  

Table A2.1: Overview of the stakeholders reached through each consultation tool/method 

Type of 
stakeholder 

Call for 
evidence 

PC 

Strat. 
interv. 

Online 
surveys 

Targ. Interv. 

Workshops 

Focus 
groups 

Case 
studies 

General public 



Persons 
disabilities 

with 

National 
competent 





 

 

 

 

 

 

53 

 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
authorities 
[other 
(NCAs) 
national 
public 
authorities (PAs)] 

level 
Society 

National 
Civil 
Organisations 
(CSOs) 

National 
providers 

service 

Civil 

EU-level 
Society 
Organisations 
(CSOs) 

EU-level  service 
providers 

EU  policymakers 
(Commission) 

EU bodies 

EU 
associations 

parking 

Researchers/acade
mics 













 

 



 

 

 

 

 

 

 

 

 

 

 

 

 

 

OVERVIEW OF CONSULTATION ACTIVITIES 

The call for evidence was open for consultation for four weeks from 23 November 2022 to 9 January 
2023 with the aim of gathering the views of relevant stakeholders on the Commiss’on's understanding 
of the problem and possible solutions and to share any relevant information that they may have on 
the initiative. It received 272 replies from different groups of stakeholders145, including EU citizens 
(188), CSOs (49), companies (8), public authorities (7), business associations (5), trade unions (2), 
non-EU citizens (2) and consumer organisations (1). Respondents were from 19 Member States: 
Belgium (77 replies), Germany (47) France (30), Italy (22) Spain (20), Finland (9), Ireland (8), the 
Netherlands (7), Austria (7), Poland (6), Slovakia (5) Portugal (5), Lithuania (4), Estonia (4), Sweden 
(3), Luxembourg (3), Greece (3), Romania (2), and Cyprus (2). In addition to the EU Member States, 
there were replies from the UK (3) and Switzerland (1). 

Public consultation was open for 12 weeks from 16 February 2023 until 5 May 2023 to ensure that 
the impact assessment and the proposal for a European Disability Card well reflects the general public 
views from a wide range of stakeholders across the EU. In particular, the consultation aimed to: (i) 
gather service providers’ and the general public’s views on the initiative, (ii) collect opinions and 
evidence on the problem and various solutions (policy options) to address it, (iii) and create a robust 

145 Detailed statistics are available here on the website of the webpage of the Call for evidence on the website of the 
European Commission   

54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and evidence-based analysis. The standard questionnaire received 1204 responses. It received 3361 
replies – in three different formats to ensure accessibility: (1) Standard questionnaire online via Have 
your Say: 1204 replies; (2) Easy-to-read format online via EU Survey: 2135 replies; (3) Accessible 
Word document via email: 22 replies. Across all the stakeholders’ categories, the majority (78%) 
of respondents were persons with disabilities (2632), most of them with a recognised disability 
(1932 respondents: 760 in the standard questionnaire + 12 in the accessible word documents + 1160 
in the easy-to-read version). Responses were received from all EU Member States.  

Strategic interviews  at  the beginning of the study explored the current  EU legislation and policy 
context, legislation, and policy initiatives in the field of disability, discussed the implementation of 
past EU initiatives (EU Disability Card pilot, European parking card for persons with disabilities), as 
well as the feasibility to introduce a mandatory EDC in all Member States. They were conducted with 
representatives of the Commission’s Directorates-General for Justice and Consumers (DG JUST) and 
for Mobility and Transport (DG MOVE). 

Ten targeted interviews were conducted with three EU bodies, two EU-level CSOs, two EU parking 
associations and an expert in the field of disability. The aim was to collect further evidence on gaps 
and issues affecting the exercise of free movement rights of persons with disabilities travelling for 
short-term stays in the EU, as well as stakeholders’ opinions on the EDC initiative. The interviews 
were conducted online via Teams, based on tailored guidelines. 

An  online survey  ran from  25 January 2023 to  19 February 2023146. The purpose was  (i)  collect 
information  on  if  and  how  preferential  conditions  are  offered  to  residents  and  non-residents  with 
disabilities accessing services in the Member States;  (ii) understand the main problems at stake at 
both  the EU and the national levels; as well  as (iii)  collect  inputs  on possible policy options. Six 
different  survey  questionnaires  were  used,  targeted  respectively  (i)  national  competent  authorities 
(NCAs): 25 replies from 15 Member States147, (ii) persons with disabilities: 24 replies from 4 Member 
States148,  (iii)  national  CSOs:  23  replies  from  11  Member  States149,  (iv)  EU-level  Civil  Society 
Organisations (CSOs): 10 replies150, (v) other national public authorities: 5 replies from 3 Member 
States151, and (vi) EU-level service providers associations and their national members: 2 replies from 
2 Member States152. An additional online survey was launched from 16-26 April 2023, due to the 
low number of service providers replying to the first online survey. This second questionnaire targeted 
607 service providers in all Member States and was focused on costs and benefits linked with the 
introduction of the EDC. In total, 23 responses were received from service providers operating 
in  13  Member  States153  in  the  following  sectors:  Cultural  Services  (6),  Public  Transport  (3), 
Amusement Parks (3), Private Transport (1), Parking (1), Travel Agencies (1), Services in the Field 

146 The surveys have been administered and centrally managed in the context of the supporting study using the Qualtrics 
tool 
147 Number of replies by MS: BE 3, CY 2, CZ 2, DE 1, EE 2, EL 1, ES 4, IT 1, LT 1, LU 3, MT 1, PL 1, RO 1, SE 1, SI 
1 
148 Number of replies by MS: FR 2, HR 8, MT 11, PT 3. 
149 Number of replies by MS: AT 3, CY 1, EL 1, FI 1, FR 1. 
150 EU-level CSOs do not represent any Member State. 
151 Number of replies by MS: BE 1, CZ 3, LV 1. 
152 Number of replies by MS: AT 1, BE 1. 
153 Number of replies by MS: BE 3, CY 1, DE 1, EE 2, ES 1, FI 1, HU 2, LU 1, LT 1, MT2, RO1, SI 5, SK 2. 

55 

 
 
 
 
of Tourism (1), Sports Centres (1), and other services154 (6). Most of the respondents reported high-
level administrative roles in their organizations (e.g., managers, directors, secretary generals etc.). 
The responses received are uniformly distributed with respect to the size of the firms: 6 Micro (1 to 
9 employees), 5 Small (10 to 49 employees), 5 Medium (50 to 249 employees) and 7 Large (250 or 
more). 

As concerns the low response rate to the online surveys, the contractor together with the European 
Commission made efforts to obtain replies from as many stakeholders as possible to the surveys. The 
contractor sent reminders and the Commission also sent reminders to encourage the stakeholders to 
take part in the surveys. Unfortunately, the response rate remained low. That is a particular issue for 
the transport sector, where the relevant stakeholders, including the main umbrella organisations were 
reached out to, however, apart from 3 public transport providers and 1 private transport provider from 
Austria, Germany and Romania, did not react. 

During  the  study,  three  online  workshops  were  organised.  The  aim  was  to  share  and  validate 
preliminary  results  from  the  study  and  to  discuss  (i)  the  problems  that  affect  the  exercise  of  free 
movement  rights  for persons with  disabilities in the EU,  (ii)  possible EU measures to  address  the 
identified problems and (iii) the likely impacts of these possible EU measures in terms of both positive 
and  negative  effects.  The  workshops  consisted  of  a  (i)  plenary  session  to  present  the  identified 
problems, the policy objectives, and the list of identified policy measures; (ii) break-out sessions with 
open questions and polls (section 3.4)  addressed and discussed with smaller groups of participants; 
and  (iii)  second  plenary  session  to  discuss  the  outcomes  of  the  break-out  sessions.  The  three 
workshops  involved  respectively 11 EU and national CSOs (22 March 2023), 29 national  public 
authorities that are members of the EU Disability Platform (23 March 2023), and 18 national service 
providers (11 May 2023).  

Originally,  the  consultation  strategy  included  six  focus  groups  with  services  providers  from 
selected Member States (i.e., Austria, Belgium, Finland, France, Italy, and Romania), with the aim to 
collect information on the likely impacts stemming from the adoption of the EDC, including potential 
costs  of  offering  preferential  conditions  to  persons  with  disabilities  from  other  Member  States. 
However, only service providers from Romania finally participated in a focus group held online on 
27 April 2023 in Romanian. It involved 14 service providers from sectors i.e., transport (9  public 
sector  and  1  private  sector);  culture  (3);  and  sports  (1).  As  mitigation  measure  to  low  number  of 
responses received to the focus group with service providers a workshop with service providers from 
all Member States was organised. 

Six case studies were performed on Austria, Belgium, Finland, France, Italy, and Romania to present 
different models and experiences on the implementation of the European parking card and to draw 
lessons and recommendations to improve its functioning. As part of the case studies, semi-structured 
1h-interviews were conducted online via Teams with: (i) Seven public authorities responsible for 
the European parking card’s entitlement, issuance, and delivery, either at local or national level in 
five Member States (AT, BE, FR, IT, RO); (ii) Seven CSOs representing or advocating the rights of 
persons  with  disabilities  in  five  Member  States  (AT,  BE,  FI,  FR,  IT);  and  (iii)  Four  parking 
associations in four Member States (BE, FI, FR, IT). The interview minutes were shared with the 
interviewees for review and to enable them to share any additional information.  

154 Other services: Accessibility consulting and services, Translation and Interpreting Services, Contribution to Education 
in Scientific and Technical Field, Tourism, Public Sector and one additional blank response 

56 

 
 
 
 
RESULTS OF THE CONSULTATION ACTIVITIES 

CALL FOR EVIDENCE 

Problems 

Problems  were  mainly  raised  by  EU  citizens  and  CSOs.  Lack  of  mutual  recognition  of  disability 
status limits recognition and acceptance of the national disability cards abroad and it is a great effort 
and time expenditure for persons with disabilities to plan travels (17 CSOs, 6 EU Citizens, 2 Other) 
and to use the card for accessing benefits, getting assistance and, more generally, enjoying their rights 
abroad (33 EU Citizens, 15 CSOs).  

Policy options  

Regarding  the  scope,  the  majority  of  respondents  were  in  favour  of  an  EDC  that  (i)  is  mutually 
recognised across the EU (97 EU Citizens, 20 CSOs, 1 SME, 1 Other); and (ii) provides for access to 
same  preferential  conditions  already  granted  by  Member  States  to  residents  with  disabilities, 
regardless of the areas or services (21 EU Citizens, 20 CSOs, 7 Other).  

Regarding the card’s design, respondents proposed the following features: (i) Double format, plastic 
and  digital,  including  a  QR  Code;  (ii)  A  common  pictogram,  including  the  logo  of  the  related 
disability type to make stakeholders  aware about  specific needs  (e.g., for cochlear implant users, 
captioning, speech-to-text); and (iii) a relief structure in the form of a scannable embossed alpha 
numerical information (as braille printing).155 

To further enhance the implementation and use of EDC, respondents proposed the establishment of 
the following mechanisms: 

-  An  EU  database/website  to  be  fed  by  the  national  authorities  responsible  for  defining  the 
eligibility criteria to receive the card and for issuing it, collecting information on the number of 
eligible persons and cards released and recording cases of fraudulent use of the card (23 CSOs, 3 
PAs, 1 EU Citizen and 1 SME). 

-  An EU-wide control system and an EU authority to oversee and monitor compliance with the 
EDC rules, working with national authorities to ensure proper implementation of the EDC by all 
the Member States and stakeholders (14 CSOs, 2 PAs, 1 EU Citizen, 1 Other). 

-  An EU-wide awareness-raising campaign to inform all the stakeholders involved (i.e., users, 
service providers, national authorities, general public) about the card, its features and benefits (16 
CSOs, 1 EU Citizen, 1 PA, 1 SME). 

Importantly,  some  respondents  claimed  that  the  EDC  should  be  introduced  through  a  binding 
legislation, preferably a regulation, to avoid differences in implementation of the EDC at national 
level (24 CSOs, 1 EU Citizens, 1 PA, 4 Other). 

Impacts 

155 Call for evidence’s detailed replies on the EDC card’s design: (i) double format: 23 CSOs, 6 EU Citizens, 1 PA, 2 
Other; (ii) A common pictogram, including the logo of the related disability type: 7 EU Citizens, 3 CSOs, 1 PA, 2 Other; 
(iii) a relief structure: 4 CSOs, 2 EU Citizens, 1 other. 

57 

 
 
 
 
On  one  side,  respondents  welcomed  the  initiative,  emphasising  that  the  adoption  of  a  mutually 
recognised EDC will (i) facilitate the freedom of movement for persons with disabilities in the EU, 
also  making  easier  travelling  in  EU  (92  EU  Citizens,  43  CSOs,  15  Other);  (ii)  improve  the 
independence and living conditions of persons with disabilities and their families (28 EU Citizens, 
12 CSOs, 3 PAs, 2 SMEs); and (iii) promote inclusion and more equal opportunities for persons 
with disabilities. 

On  the  other  side,  respondents  pointed  out  some  concerns  about  costs  incurred  by  service 
providers  with  respect  to  (i)  investments  into  infrastructure,  technologies,  people  and  skills, 
depending on the type of disability (6 CSOs, 2 EU Citizens, 5 Other); and (ii) Handling of sensitive 
customers data (11 CSOs and 4 EU Citizens,).  

PUBLIC CONSULTATION (by stakeholders groups) 

When reading the main results of this consultation, it is important to note that the total number of 
respondents  varies  across  the  questions  highlighted.  The  reason  is  because  the  easy-to-read 
questionnaire comprised fewer and more simplified questions than the standard one and elicited more 
responses. To help you navigate this report: 

•  Total number of respondents is clarified in each question. 
•  When the questions referred to were included in the easy-to-read version, the total number of 
respondents is: 2526 citizens, 245 NGO, 114 public authorities, 134 companies, 133 academic 
institutions, 22 non-EU citizens and 1932 persons with disabilities across categories. 

When the questions referred to were not included in the easy-to-read version, the total number of 
respondents is: 1009 citizens, 71 NGO, 33 public authorities, 26 companies, 23 academic institutions, 
22 non-EU citizens and 772 persons with disabilities across categories (respondents from the standard 
questionnaire + accessible word docs.) 

Users and Representative organisations 

Problems 

The majority (75% EU citizens, 73% Persons with disabilities, 77% NGO, 68% non-EU citizens) of 
respondents claimed that the lack of mutual recognition of disability status in the EU represents 
an obstacle for Persons with disabilities to exercise their free movement rights. According to half of 
representatives  from  NGOs  (38  of  71),  Persons  with  disabilities  are  discouraged  from  travelling 
because their disability status is not recognised.48% Persons with disabilities stated their disability 
status  is  not  recognised  across  Member  States.  33%  Persons  with  disabilities  specified  that  their 
disability card is not accepted when they travel across the EU.  

Regarding the factors perceived to highly hinder the free movement of Persons with disabilities in 
the EU: 

i.  Lack  of  publicly  available  information  on  preferential  conditions  for  Persons  with 
disabilities  (77%  EU  citizens,  75%  of  Persons  with  disabilities,  87%  NGO,  82%  non-EU 
citizens) 

ii.  Limited provision of preferential conditions offered by certain services to non-residents 

(65% EU citizens, 66% Persons with disabilities, 78% NGO, 90% non-EU citizens) 

58 

 
 
 
iii.  Different  treatment  of  non-residents  with  disabilities  compared  to  residents  with 
disabilities  (67%  EU  citizens,  66%  Persons  with  disabilities,  78%  NGO,  73%  non-EU 
citizens) 

European Parking Card 

The majority of respondents pointed out that the implementation of the European parking card 
for Persons with disabilities is significantly hindered by (1) Its limited mutual recognition across 
the Member States: (65% EU citizens, 62% Persons with disabilities, 70% NGO), and (2) National 
differences in terms of conditions attached to the card (e.g., validity period, conditions for priority 
parking, etc.): (60% EU citizens, 58% Persons with disabilities, 58% NGO, 59% non-EU citizens). 
Specifically, 22%156 Persons with disabilities highlighted they have problems when they use their 
European parking card. 

EU added value 

Almost  all  respondents  that  claimed  that  the  EU  action  is  needed  to:  (1)  Facilitating  mutual 
recognition of disability in the EU (94% EU citizens, 91% Persons with disabilities, 93% NGO, 
90% non-EU citizens); (2) Facilitating access to those services offering preferential conditions to 
Persons with disabilities (93% EU citizens, 91% Persons with disabilities, 86% NGO, 90% non-EU 
citizens);  (3)  Improving  the  implementation  of  the  European  Parking  Card  for  Persons  with 
disabilities (88% EU citizens, 83% Persons with disabilities, 83% NGO, 82% non-EU citizens). 

Policy options 

Most respondents think that the European Disability Card should be binding for all Member States, 
without the possibility of opting out (87% EU citizens, 87% Persons with disabilities, 85% NGO, 
77%  non-EU  citizens,  100%  consumer  organisations157).  The  majority  think  that  the  European 
Parking Card should be incorporated into the new European Disability Card (82% EU citizens, 
82% Persons with disabilities, 98% NGO158, 82% non-EU citizens, 88% consumer organisations). 
Most stated that the European Disability Card should have the form of both plastic and electronic 
(mobile phone application): 68% EU citizens, 69% Persons with disabilities, 98% NGO159, 68% non-
EU citizens, 59% consumer organisations). According to the vast majority of respondents, the main 
sectors that should be included in the European Disability Card are public transport (1821 of 3361), 
cultural activities (1566 of 3361) and parking (1534 of 3361). 

Impacts 

The majority (average of 85% and 100% of consumer organisations160) think that the introduction of 
the European Disability Card would have a strong impact on:  
- 

Increasing access  to services offering preferential conditions for  Persons  with disabilities 
when travelling in the EU (85% EU citizens, 84% Persons with disabilities, 85% NGO, 91% 
non-EU citizens). 

156 Not all persons with disabilities replied to this question in the easy-to-read version: 650 out of 1160. 
157 3 out of 3 consumer organisations (standard questionnaire + word docs). 17 replied to the public consultation. 
158 Not all NGOs replied to this question: 195 out of 245. 
159 Not all NGOs replied to this question: 195 out of 245. 
160 3 out of 3 consumer organisations (standard questionnaire + word docs). 17 replied to the public consultation. 

59 

 
 
 
 
 
-  Simplifying mutual recognition of preferential conditions for Persons with disabilities (85% 

- 

- 

EU citizens, 84% Persons with disabilities, 90% NGO, 82% non-EU citizens). 
Increasing  the  take  up  of  cultural,  leisure,  sports,  and  travel  services  of  Persons  with 
disabilities  when  travelling across  the EU (85% EU citizens, 84%  Persons  with  disabilities, 
86% NGO, 91% non-EU citizens). 
Increasing  the  opportunity  for  Persons  with  disabilities  to  exercise  fully  their  right  of 
travelling across the EU (84% EU citizens, 82% Persons with disabilities, 83% NGO, 91% non-
EU citizens). 

Most respondents (average of 75% and 2 of 3 consumer organisations) think that EDC will also have 
a strong impact on (1) increasing the frequency of travel of Persons with disabilities in the EU 
(68%  EU  citizens,  67%  Persons  with  disabilities,  77%  NGO,  91%  non-EU  citizens);  and  (2) 
increasing the number of Persons with disabilities travelling in the EU (67% EU citizens, 67% 
Persons with disabilities, 72% NGO, 86% non-EU citizens). 

Overall, respondents think that the introduction of European Disability Card would have no impact 
on (1) regulatory charges, e.g., fees, levies, and taxes, etc. (52% EU citizens, 53%  Persons with 
disabilities, 61% NGO, 46% non-EU citizens, 1 of 3 consumer organisations); and (2) indirect costs, 
e.g., price increases for the general public for services targeted by the card (53% EU citizens, 53% 
Persons with disabilities, 74% NGO, 41% non-EU citizens, 2 of 3 consumer organisations);  

Most  respondents  think  that  the  costs  entailed  by  the  European  Disability  Card  would  affect  the 
following stakeholders only from a small to a medium extent: 
-  Member States’ public administrations, e.g., on costs related to the delivery of the Card (72% 
EU citizens, 70% Persons with disabilities, 79% NGO, 69% non-EU citizens, 3 of 3 consumer 
organisations);  

-  Large companies e.g., on costs related to the provision of preferential conditions to EU tourists 
with  disabilities  (71%  EU  citizens,  70%  Persons  with  disabilities,  65%  NGO,  59%  non-EU 
citizens, 2 of 3 consumer organisations). 

-  SMEs  e.g.,  on  costs  related  to  the  provision  of  preferential  conditions  to  EU  tourists  with 
disabilities  (70%  EU  citizens,  69%  Persons  with  disabilities,  70%  NGO,  2  of  3  consumer 
organisations).  

-  Public  authorities  offering  preferential  conditions  for  Persons  with  disabilities  (68%  EU 
citizens,  66%  Persons  with  disabilities,  72%  NGO,  59%  non-EU  citizens,  2  of  3  consumer 
organisations). 

-  Civil society organisations, e.g., on costs related to the provision of support in using the Card-
to-Card  holders  with  particular  needs  (34%  EU  citizens,  33%  Persons  with  disabilities,  31% 
NGO, 64% non-EU citizens, 1 of 3 consumer organisations). 

-  Cultural venues and institutions (66% EU citizens, 64% Persons with disabilities, 72% NGO, 

50% non-EU citizens, 2 of 3 consumer organisations) 

Public authorities 

Problems 

The majority (72%) of respondents claimed that the lack of mutual recognition of disability status 
in the EU represents an obstacle for persons with disabilities to exercise their free movement rights. 
Regarding the factors perceived to highly hinder the free movement of persons with disabilities in 
the EU: 73% stated the lack of publicly available information on preferential conditions for Persons 
with disabilities; 60% stated different treatment of non-residents with disabilities compared to 

60 

 
 
 
residents  with  disabilities;  58%  stated  limited  provision  of  preferential  conditions  offered  by 
certain services to non-residents. 

European Parking Card 

Half of respondents pointed out that the implementation of the European parking card for persons 
with disabilities is significantly hindered by (1) Its limited mutual recognition across the Member 
States; and (2) National differences in terms of conditions attached to the card. 

EU added value 

The majority of respondents that claimed that the EU action is needed to: (1) Facilitating mutual 
recognition  of  disability  in  the  EU  (82%);  (2)  Facilitating  access  to  those  services  offering 
preferential conditions to persons with disabilities (67%); (3) Improving the implementation of the 
European Parking Card for Persons with disabilities (79%). 

Policy options 

The  majority  (73%)  think  that  the  European  Disability  Card  should  be  binding  for  all  Member 
States, without the possibility of opting out. 69% think that the European Parking Card should 
be  incorporated  into  the  new  European  Disability  Card.  Most  (71%)  stated  that  the  European 
Disability Card should have the form of both plastic and electronic (mobile phone application). 

Impacts 

Most respondents (almost 70%) think that the introduction of the European Disability Card would 
have a strong impact on:  

- 

Increasing access  to services offering preferential conditions for  Persons  with disabilities 
when travelling in the EU (61%). 

-  Simplifying  mutual  recognition  of  preferential  conditions  for  Persons  with  disabilities 

(70%). 

- 

- 

Increasing  the  take  up  of  cultural,  leisure,  sports,  and  travel  services  of  Persons  with 
disabilities when travelling across the EU (61%). 

Increasing  the  opportunity  for  Persons  with  disabilities  to  exercise  fully  their  right  of 
travelling across the EU (67%). 

Half of respondents think that EC will have a strong impact on increasing the number of Persons 
with disabilities travelling in the EU (52%). Other respondents think that EC will strongly increase 
the frequency of travel of Persons with disabilities in the EU (36%). 64% respondents think that 
the introduction of European Disability Card would have no impact on (1) regulatory charges, e.g., 
fees, levies,  and taxes,  etc.;  and  (2)  indirect costs, e.g., price increases for the general  public for 
services targeted by the card. 

Most  respondents  think  that  the  costs  entailed  by  the  European  Disability  Card  would  affect  the 
following stakeholders only from a small to a medium extent: 

-  Member States’ public administrations, e.g., on costs related to the delivery of the Card (57%).  

61 

 
 
 
 
-  Large companies e.g., on costs related to the provision of preferential conditions to EU tourists 

with disabilities (76%). 

-  SMEs  e.g.,  on  costs  related  to  the  provision  of  preferential  conditions  to  EU  tourists  with 

disabilities (76%).  

-  Public authorities offering preferential conditions for Persons with disabilities (57%). 

-  Civil society organisations, e.g., on costs related to the provision of support in using the Card-

to-Card holders with particular needs (45%). 

-  Cultural venues and institutions (73%) 

Service providers 

Problems 

65%  companies  claimed  that  the  lack  of  mutual  recognition  of  disability  status  in  the  EU 
represents an obstacle for persons with disabilities to exercise their free movement rights. 

EU added value 

More than half of respondents that claimed that the EU action is needed to: (1) Facilitating mutual 
recognition  of  disability  in  the  EU  (65%);  (2)  Facilitating  access  to  those  services  offering 
preferential conditions to persons with disabilities (58%); (3) Improving the implementation of the  

European Parking Card for Persons with disabilities (62%). 

Policy options 

The  majority  (73%)  think  that  the  European  Disability  Card  should  be  binding  for  all  Member 
States, without the possibility of opting out. 68%161 think that the European Parking Card should 
be  incorporated  into  the  new  European  Disability  Card.  Most  (88%)  stated  that  the  European 
Disability Card should have the form of both plastic and electronic (mobile phone application). 

Impacts 

More than half of the respondents think that the introduction of the European Disability Card would 
have a strong impact on:  
- 

Increasing access  to services offering preferential conditions for  Persons  with disabilities 
when travelling in the EU (58%). 

-  Simplifying  mutual  recognition  of  preferential  conditions  for  Persons  with  disabilities 

- 

- 

(62%). 
Increasing  the  take  up  of  cultural,  leisure,  sports,  and  travel  services  of  Persons  with 
disabilities when travelling across the EU (54%). 
Increasing  the  opportunity  for  Persons  with  disabilities  to  exercise  fully  their  right  of 
travelling across the EU (69%). 

161 Not all companies replied to this question: 112 out of 134. 

62 

 
 
 
 
 
 
Half of respondents think that EDC will strongly increase the frequency of travel of Persons with 
disabilities in the EU, and the number of Persons with disabilities travelling in the EU. Several 
respondents think that the introduction of European Disability Card would have  no impact on (1) 
regulatory  charges,  e.g.,  fees,  levies,  and  taxes,  etc.  (54%);  and  (2)  indirect  costs,  e.g.,  price 
increases for the general public for services targeted by the card (69%) 

Most  respondents  think  that  the  costs  entailed  by  the  European  Disability  Card  would  affect  the 
following stakeholders only from a small to a medium extent: 
-  Member States’ public administrations, e.g., on costs related to the delivery of the Card (69%).  
-  Large companies e.g., on costs related to the provision of preferential conditions to EU tourists 

with disabilities (77%). 

-  SMEs  e.g.,  on  costs  related  to  the  provision  of  preferential  conditions  to  EU  tourists  with 

disabilities (77%).  

-  Public authorities offering preferential conditions for Persons with disabilities (62%). 
-  Civil society organisations, e.g., on costs related to the provision of support in using the Card-

to-Card holders with particular needs (35%). 

-  Cultural venues and institutions (69%) 

Academic and research institutions 

Problems 

The majority (78%) of respondents claimed that the lack of mutual recognition of disability status 
in the EU represents an obstacle for Persons with disabilities to exercise their free movement rights.  

Regarding the factors perceived to highly hinder the free movement of Persons with disabilities in 
the EU: 

i.  Lack  of  publicly  available  information  on  preferential  conditions  for  Persons  with 

disabilities (74%) 

ii.  Different  treatment  of  non-residents  with  disabilities  compared  to  residents  with 

disabilities (70%) 

iii.  Limited provision of preferential conditions offered by certain services to non-residents 

(70%) 

European Parking Card 

The majority of respondents pointed out that the implementation of the European parking card 
for Persons with disabilities is significantly hindered by its limited mutual recognition across the 
Member States (70%). 

EU added value 

Almost  all  respondents  that  claimed  that  the  EU  action  is  needed  to:  (1)  Facilitating  mutual 
recognition  of  disability  in  the  EU  (91%);  (2)  Facilitating  access  to  those  services  offering 
preferential conditions to Persons with disabilities (96%); (3) Improving the implementation of the 
European Parking Card for Persons with disabilities (83%). 

Policy options 

63 

 
 
 
 
 
Most respondents think that the European Disability Card should be binding for all Member States, 
without  the  possibility  of  opting  out  (87%),  that  the  European  Parking  Card  should  be 
incorporated into the new European Disability Card (85%) and that the European Disability Card 
should have the form of both plastic and electronic (70%). 

Impacts 

Most respondents think that the introduction of the European Disability Card would have a strong 
impact on:  
- 

Increasing access  to services offering preferential conditions for  Persons  with disabilities 
when travelling in the EU (74%). 

-  Simplifying  mutual  recognition  of  preferential  conditions  for  Persons  with  disabilities 

- 

- 

(83%). 
Increasing  the  take  up  of  cultural,  leisure,  sports,  and  travel  services  of  Persons  with 
disabilities when travelling across the EU (65%). 
Increasing  the  opportunity  for  Persons  with  disabilities  to  exercise  fully  their  right  of 
travelling across the EU (78%). 

Half of respondents think that EDC will also have a strong impact on (1) increasing the frequency 
of travel of Persons with disabilities in the EU; and (2) increasing the number of Persons with 
disabilities travelling in the EU. Almost 60% of respondents think that the introduction of European 
Disability Card would have no impact on (1) regulatory charges, e.g., fees, levies, and taxes, etc.; 
and (2) indirect costs, e.g., price increases for the general public for services targeted by the card. 

Most  respondents  think  that  the  costs  entailed  by  the  European  Disability  Card  would  affect  the 
following stakeholders only from a small to a medium extent: 
-  Member States’ public administrations, e.g., on costs related to the delivery of the Card (70%) 
-  Large companies e.g., on costs related to the provision of preferential conditions to EU tourists 

with disabilities (70%) 

-  SMEs  e.g.,  on  costs  related  to  the  provision  of  preferential  conditions  to  EU  tourists  with 

disabilities (70%) 

-  Public authorities offering preferential conditions for Persons with disabilities (65%). 
-  Civil society organisations, e.g., on costs related to the provision of support in using the Card-

to-Card holders with particular needs (44%). 

-  Cultural venues and institutions (78%) 

Trade unions 

EU added value 

All  respondents  (4  of  4162)  claimed  that  the  EU  action  is  needed  to:  (1)  Facilitating  mutual 
recognition of disability in the EU; (2) Facilitating access to those services offering preferential 
conditions to Persons with disabilities; and (3) Improving the implementation of the European 
Parking Card for Persons with disabilities. 

162 4 out of 4 trade unions (standard questionnaire + word docs). 21 replied to the public consultation. 

64 

 
 
 
 
 
 
Policy options 

67% of respondents think that the European Parking Card should be incorporated into the new 
European Disability Card. 62% think that the European Disability Card should have the form of 
both plastic and electronic. 

Impacts 

All respondents (4 of 4163) think that the introduction of the European Disability Card would have a 
strong impact on:  (1) Increasing access  to services  offering preferential conditions for Persons 
with  disabilities  when  travelling  in  the  EU;  (2)  Simplifying  mutual  recognition  of  preferential 
conditions for Persons with disabilities; (3) Increasing the take up of cultural, leisure, sports, and 
travel  services  of  Persons  with  disabilities  when  travelling  across  the  EU;  (4)  Increasing  the 
opportunity for Persons with disabilities to exercise fully their right of travelling across the EU. 

Half  of  respondents  (2  of  4)164  think  that  EDC  will  also  have  a  strong  impact  on  increasing  the 
frequency of travel of Persons with disabilities in the EU. 3 of 4 respondents that will strongly 
increase the number of Persons with disabilities travelling in the EU. 3 of 4 respondents think 
that the introduction of European Disability Card would have no impact on regulatory charges, e.g., 
fees, levies, and taxes, etc. Half of respondents that it will have no impact on indirect costs, e.g., 
price increases for the general public for services targeted by the card. 

Half of respondents (2 of 4) think that the costs entailed by the European Disability Card would affect 
the  following  stakeholders  only  from  a  small  to  a  medium  extent  to  Member  States’  public 
administrations, (e.g., on costs related to the delivery of the Card; Large companies e.g., on costs 
related to the provision of preferential conditions to EU tourists with disabilities; SMEs e.g., on costs 
related  to  the  provision  of  preferential  conditions  to  EU  tourists  with  disabilities;  and  Public 
authorities offering preferential conditions for Persons with disabilities. 1 of 4 respondents think 
that it will only affect from a small to a medium extent to Civil society organisations, e.g., on costs 
related  to  the  provision  of  support  in  using  the  Card-to-Card  holders  with  particular  needs;  and 
Cultural venues and institutions. 

Main conclusions 

Problems 

The majority of academic institutions (78%), NGOs (77%), users165 and public authorities (72% both) 
agreed that the lack of mutual recognition of disability status in the EU represents an obstacle for 
Persons with disabilities to exercise their free movement rights. Only service providers (65%) and 
non-EU citizens (68%) agreed a bit below the average. 

Users and NGOs agreed the most that the factors perceived to highly hinder the free movement of 
Persons with disabilities in the EU are: (1) Lack of publicly available information on preferential 
conditions  for  Persons  with  disabilities  (87%  NGOs,  78%  users);  (2)  Limited  provision  of 
preferential conditions (78% NGOs, 74% users) offered by certain services to non-residents; and 
(3) Different treatment of non-residents with disabilities compared to residents with disabilities 

163 4 out of 4 trade unions (standard questionnaire + word docs). 21 replied to the public consultation. 
164 2 out of 4 trade unions (standard questionnaire + word docs). 21 replied to the public consultation. 
165 The category ‘users’ include: PwDs, EU citizens and non-citizens. 

65 

 
 
 
 
 
 
(78% NGOs, 69% users). Academic/research institutions agreed in a 71%, and public authorities in 
a 64%. 

European Parking Card 

Most  users,  CSOs  and  academic  institutions  (63%)  pointed  out  that  the  implementation  of  the 
European parking card for Persons with disabilities is significantly hindered by (1) Its limited mutual 
recognition across the Member States; and (2) National differences in terms of conditions attached 
to  the  card  (e.g.,  validity  period,  conditions  for  priority  parking,  etc.).  Half  of  public  authorities 
agreed with this. 

EU added value 

Almost  all  users,  CSOs  and  academic  institutions  agreed  that  the  EU  action  is  needed  to:  (1) 
Facilitating mutual recognition of disability in the EU  (92%); (2)  Facilitating access  to those 
services  offering  preferential  conditions  to  Persons  with  disabilities  (91%);  (3)  Improving  the 
implementation of the European Parking Card for Persons with disabilities (84%). 

The majority of public authorities (82%) agreed that the EU action is needed to facilitate mutual 
recognition  of  disability  in  the  EU;  most  of  them  (79%)  that  is  needed  for  improving  the 
implementation of the European Parking Card; and 67% agreed that is needed for facilitating access 
to those services offering preferential conditions to Persons with disabilities. 

63% of service providers agreed that the EU action is needed for those three actions; specially for 
facilitating mutual recognition of disability (65%); for improving the implementation of the European 
Parking Card (62%); and facilitating access to those services offering preferential conditions (58%). 

Policy options 

All consumer organisations166, and most of users, CSOs and academic institutions (87%) think that 
the EDC should be binding for all Member States, without the possibility of opting out. Public 
authorities and service providers agreed in a 73%. 

98%  of  NGOs,  88%  consumer  organisations  and  82%  of  users  think  that  the  European  Parking 
Card  should  be  incorporated  into  the  new  European  Disability  Card.  Public  authorities  and 
service providers agreed in a 68%. 

98% NGO167, 88% service providers and 71% public authorities stated that the European Disability 
Card should have the form of both plastic and electronic (mobile phone application). Users agreed 
in a 68%. 

According  to  the  vast  majority  of  respondents,  the  main  sectors  that  should  be  included  in  the 
European Disability Card are public transport (18021 of 3361), cultural activities (1566 of 3361) and 
parking (1534 of 3361). 

Impacts 

166 3 out of 3 consumer organisations (standard questionnaire + word docs). 17 replied to the public consultation. 
167 Not all NGOs replied to this question: 195 out of 245. 

66 

 
 
 
 
The majority of stakeholders agreed that the introduction of EDC would have the strongest impact on 
simplifying  mutual  recognition  of  preferential  conditions  for  Persons  with  disabilities  (85% 
users and NGOs; 83 academic institutions; 70% public authorities.) 

Service providers think that the strongest impact will be for increasing the opportunity for Persons 
with disabilities to exercise fully their right of travelling across the EU (69%). Users and NGOs 
agreed in an 85%. For academic institutions (78%), and public authorities (67%) this would be the 
2nd strongest impact. 

For  users  and  NGOs  (86%)  the  2nd  strongest  impact  would  be  in  the  increasing  the  take  up  of 
cultural, leisure, sports, and travel services of Persons with disabilities when travelling across 
the EU. Academic institutions agreed in an 65%; Public authorities in an 61% and service providers 
in an 54%. 

For  users  and  NGOs  (85%)  and  academic  institutions  (74%)  EDC  will  as  well  strongly  increase 
access to services offering preferential conditions for Persons with disabilities when travelling 
in the EU.  Public authorities agreed in a 61%; service providers in a 58%. 

75%  of  users  and  NGOs  think  that  EDC  will  also  have  a  strong  impact  on  (1)  increasing  the 
frequency  of  travel  of  Persons  with  disabilities  in  the  EU;  and  (2)  increasing  the  number  of 
Persons  with  disabilities  travelling  in  the  EU.  Half  of  public  authorities  and  service  providers 
agreed with the impact on the frequency of travel, but only 36% of public authorities agreed with the 
increasing of number of Persons with disabilities travelling. 

Overall, respondents think that the introduction of EDC would have no impact on (1) regulatory 
charges, e.g., fees, levies, and taxes, etc. (77% NGOs, 64% public authorities; 61% service providers; 
53% users); and (2) indirect costs, e.g., price increases for the general public for services targeted by 
the card (74% NGOs, 64% public authorities, 69% service providers; 53% users). 

Most respondents think that the costs entailed by the European Disability Card would affect, only 
from a small to a medium extent, to SMEs (72%), large companies (71%), Cultural venues and 
institutions  (70%),  Member  States’  public  administrations  (69%),  Public  authorities  offering 
preferential conditions for Persons with disabilities (64%) and NGOs (40%). 

Public authorities (76%) and service providers (77%) agreed that SMEs and large companies will be 
the most affected, but only from a small to a medium extent. NGOs (79%) and users (70%) think that 
it will be the Member States’s public administrations. Academic institutions (78%) think that it will 
be the cultural venues and institutions. 

PUBLIC CONSULTATION (by area of questions) 

Problems 

The majority of respondents claimed that the lack of mutual recognition of disability status in the 
EU represents an obstacle for persons with disabilities to exercise their free movement rights (754 of 
1009  EU  citizens,  55  of  71  NGOs,  24  of  33  public  authorities,  17  of  26  companies,  18  of  23 
academic/research institutions, 15 of 22 non-EU citizens, and 559 of 772 persons with disabilities 
across all categories). 

67 

 
 
 
 
354 of 772 persons with disabilities stated their disability status is not  recognised across  Member 
States. Moreover, 377 of 1160 specified that their disability card is not accepted when they travel 
across the EU.  

In  particular,  the  following  factors  were  mentioned  as  being  perceived  to  highly  hinder  the  free 
movement of persons with disabilities in the EU: 

iv.  Lack of publicly available information on preferential conditions for persons with 

disabilities (593 of 772 Persons with disabilities across all categories)168 

v.  Different  treatment  of  non-residents  with  disabilities  compared  to  residents  with 

disabilities (510 of 772 Persons with disabilities across all categories)169. 

vi.  Limited provision of preferential conditions offered by certain services to non-residents 

(505 of 772 Persons with disabilities across all categories)170 

Moreover, according to half of representatives from NGOs (38 of 71), persons with disabilities are 
discouraged from travelling because their disability status is not recognised. 

European Parking Card 

The  majority  of  respondents  (the  share  is  lower  for  public  authorities)  pointed  out  that  the 
implementation  of  the  European  parking  card  for  persons  with  disabilities  is  significantly 
hindered by: 

- 

Its limited mutual recognition across the Member States: (482 of 772 Persons with disabilities 
responding across all categories)171:  

-  National  differences  in  terms  of  conditions  attached  to  the  card  (e.g.,  validity  period, 
conditions for priority parking, etc.): (453 of 772 Persons with disabilities across all categories)172. 
Specifically, 140 of 650173 persons with disabilities highlighted they have problems when they use 
their European parking card. 

The necessity and added value of a possible EU action 

The majority of respondents claimed that EU action is needed for: 

-  Facilitating  mutual  recognition  of  disability  in  the  EU:  945  of  1009  EU  citizens,  66  of  71 
NGOs, 27 of 33 public authorities, 17 of 26 companies/businesses/business associations, 21 of 23 

168  PC  problem  (i)  Lack  of  information.  Detailed  replies:  777  of  1009  EU  citizens,  62  of  71  NGOs,  24  of  33  public 
authorities, 17 of 23 academic/research institutions, 18 of 22 non-EU citizens. 
169  PC  problem  (ii)  Different  treatment.  Detailed  replies:  684  of  1009  EU  citizens,  56  of  71  NGOs,  20  of  33  public 
authorities, 16 of 23 academic/research institutions, 16 of 22 non-EU citizens,  
170 PC problem (iii) Limited preferential conditions. Replies: 664 of 1009 EU citizens, 56 of 71 NGOs, 19 of 33 public 
authorities, 16 of 23 academic/research institutions, 20 of 22 non-EU citizens. 
171  European  parking  card problem.  Limited  mutual  recognition.  Detailed  replies:  665  of 1009  EU  citizens,  50  of  71 
NGOs, 15 of 33 public authorities, 16 of 23 academic/research institutions. 
172 European parking card problem. National differences. Detailed replies: 609 of 1009 EU citizens, 44 of 71 NGOs, 15 
of 33 public authorities, 13 non-EU citizens, 2 consumer organisations. 
173 Not all persons with disabilities replied to this question in the easy-to-read version: 650 out of 1160. 

68 

 
 
 
 
academia/research  institutions,  20  non-EU  citizens  and  4  of  4  trade  unions,  and  705  of  772 
Persons with disabilities across all categories. 

-  Facilitating  access  to  those  services  offering  preferential  conditions  to  persons  with 
disabilities: 935 of 1009 EU  citizens, 616 of 71 NGOs, 22 of 33 public authorities, 15 of 26 
companies/business associations, 20 of 23 academia/research institutions, 20 non-EU citizens and 
4 of 4 trade unions, and 702 of 772 Persons with disabilities across all categories. 
Improving the implementation of the European Parking Card for persons with disabilities: 
844  of  1009  EU  citizens,  59  of  71  NGOs,  26  of  33  public  authorities,  16  of  26 
companies/businesses/business associations, 19 of 23 academia/research institutions, 18 non-EU 
citizens and 4 of 4 trade unions, and 639 of 772 Persons with disabilities across all categories.. 

- 

Policy options 

Most respondents think that the European Disability Card should be binding for all Member States, 
without the possibility of opting out: 874 of 1009 EU citizens, 60 of 71 NGOs, 24 of 33 public 
authorities,  19  of  26  companies/business  associations,  20  of  23  academia/research  institutions,  17 
non-EU  citizens,  3  consumer  organisations,  and  669  of  769  persons  with  disabilities  across  all 
categories; 

Also, most respondents think that the European Parking Card should be incorporated into the 
new European Disability Card: 2083 of 2526 EU citizens, 192 of 195174 NGOs, 78 of 114 public 
authorities, 107 of 112175 companies/business associations, 113 of 133 academia/research institutions, 
18 of 22 non-EU citizens, 14 of 21 trade unions, 15 of 17 consumer organisations, and 1592 of 1932 
persons with disabilities across all categories.  

The  majority  stated  that  the  European  Disability  Card  should  have  the  form  of  both  plastic  and 
electronic (mobile phone application) card: 1724 of 2526 EU citizens, 191 of 195176 NGOs, 81 of 
114 public authorities, 99 of 112177 companies/business associations, 93 of 133 academia/research 
institutions, 15 of 22 non-EU citizens, 13 of 21 trade unions, 10 of 17 consumer organisations, and 
1333 of 1932 Persons with disabilities across all categories. . 

According  to  the  vast  majority  of  respondents,  the  main  sectors  that  should  be  included  in  the 
European Disability Card are public transport (18021 of 3361), cultural activities (1566 of 3361) and 
parking (1534 of 3361). 

Impacts 

Overall, respondents think that the introduction of the European Disability Card would have a strong 
impact on:  

174 Not all NGOs replied to this question: 195 out of 245 
175 Not all companies replied to this question: 112 out of 134 
176 Not all NGOs replied to this question: 195 out of 245 
177 Not all companies replied to this question: 112 out of 134 

69 

 
 
 
 
- 

Increasing  access  to  services  offering  preferential  conditions  for persons  with  disabilities 
when travelling in the EU (860 of 1009 EU citizens, 60 of 71 NGOs, 20 of 33 public authorities, 
15 of 26 companies/businesses/business associations, 17 of 23 academic/research institutions, 20 
of 22 non-EU citizens, 4 of 4 trade unions, 3 of 3 consumer organisations, and 650 of 772 persons 
with disabilities across all categories). 

- 

- 

-  Simplifying mutual recognition of preferential conditions for persons with disabilities (861 
of  1009  EU  citizens,  64  of  71  NGOs,  23  of  33  public  authorities,  16  of  26 
companies/businesses/business  associations,  19  of  23  academic/research  institutions,  18  of  22 
non-EU citizens, 4 of 4 trade unions, 3 of 3 consumer organisations, and 652 of 772persons with 
disabilities across all categories). 
Increasing  the  take  up  of  cultural,  leisure,  sports,  and  travel  services  of  persons  with 
disabilities when travelling across the EU (856 of 1009 EU citizens, 61 of 71 NGOs, 20 of 33 
public  authorities,  14  of  26  companies/businesses/business  associations,  15  of  23 
academic/research institutions, 20 of 22 non-EU citizens, 4 of 4 trade unions, 3 of 3 consumer 
organisations, and 650 of 772persons with disabilities across all categories). 
Increasing  the  opportunity  for  persons  with  disabilities  to  exercise  fully  their  right  of 
travelling across the EU (846 of 1009 EU citizens, 59 of 71 NGOs, 22 of 33 public authorities, 
18 of 26 companies/businesses/business associations, 18 of 23 academic/research institutions, 20 
of 22 non-EU citizens, 4 of 4 trade unions, 3 of 3 consumer organisations, and 634 of 772 persons 
with disabilities across all categories). 
Increasing the frequency of travel of persons with disabilities in the EU (687 of 1009 EU 
citizens,  55  of  71  NGOs,  12  of  33  public  authorities,  13  of  26  companies/businesses/business 
associations,  12  of  23  academic/research  institutions,  20  of  22  non-EU  citizens,  2  of  4  trade 
unions,  2  of  3  consumer  organisations,  and  518  of  772    persons  with  disabilities  across  all 
categories); and  
Increasing  the  number  of  persons  with  disabilities  travelling  in  the  EU  (679  of  1009  EU 
citizens,  51  of  71  NGOs,  17  of  33  public  authorities,  14  of  26  companies/businesses/business 
associations,  13  of  23  academic/research  institutions,  19  of  22  non-EU  citizens,  3  of  4  trade 
unions,  2  of  3  consumer  organisations,  and  519  of  772  persons  with  disabilities  across  all 
categories). 

- 

- 

Overall, respondents think that the introduction of European Disability Card would have no impact 
on (1) regulatory charges, e.g., fees, levies, and taxes, etc. (528 of 1009 EU citizens, 43 of 71 NGOs, 
21  of  33  public  authorities,  14  of  26  companies/businesses/business  associations,  13  of  23 
academic/research  institutions,  10  of  22  non-EU  citizens,  3  of  4  trade  unions,  1  of  3  consumer 
organisations, and 408 of 772 persons with disabilities), and (2) indirect costs, e.g., price increases 
for the general public for services targeted by the card (535 of 1009 EU citizens, 45 of 71 NGOs, 21 
of  33  public  authorities,  18  of  26  companies/businesses/business  associations,  14  of  23 
academic/research  institutions,  9  of  22  non-EU  citizens,  2  of  4  trade  unions,  2  of  3  consumer 
organisations, and 410 of 772 persons with disabilities across all categories). 

Most  respondents  think  that  the  costs  entailed  by  the  European  Disability  Card  would  affect  the 
following stakeholders only from a small to a medium extent: 

70 

 
 
 
-  Member States’ public administrations, e.g., on costs related to the delivery of the Card (725 
of  1009  EU  citizens,  56  of  71  NGOs,  19  of  33  public  authorities,  18  of  26 
companies/businesses/business  associations,  16  of  23  academic/research  institutions,  15  of  22 
non-EU citizens, 2 of 4 trade unions, 3 of 3 consumer organisations, and 539 of 772 persons with 
disabilities across all categories). 

-  Large companies e.g., on costs related to the provision of preferential conditions to EU tourists 
with disabilities (719 of 1009 EU citizens, 46 of 71 NGOs, 25 of 33 public authorities, 20 of 26 
companies/businesses/business  associations,  16  of  23  academic/research  institutions,  13  of  22 
non-EU citizens, 2 of 4 trade unions, 2 of 3 consumer organisations, and 543 of 772 persons with 
disabilities across all categories). 

-  SMEs  e.g.,  on  costs  related  to  the  provision  of  preferential  conditions  to  EU  tourists  with 
disabilities  (710  of  1009  EU  citizens,  50  of  71  NGOs,  25  of  33  public  authorities,  20  of  26 
companies/businesses/business  associations,  16  of  23  academic/research  institutions,  16  of  22 
non-EU citizens, 2 of 4 trade unions, 2 of 3 consumer organisations, and 534 of 772 persons with 
disabilities across all categories, respectively). 

-  Public authorities offering preferential conditions for persons with disabilities (687 of 1009 
EU citizens, 51 of 71 NGOs, 19 of 33 public authorities, 16 of 26 companies/businesses/business 
associations,  15  of  23  academic/research  institutions,  14  of  22  non-EU  citizens,  2  of  4  trade 
unions,  2  of  3  consumer  organisations,  and  508  of  772    persons  with  disabilities  across  all 
categories). 

-  Civil society organisations, e.g., on costs related to the provision of support in using the Card-
to-Card holders with particular needs (340 of 1009 EU citizens, 22 of 71 NGOs, 15 of 33 public 
authorities,  9  of  26  companies/businesses/business  associations,  10  of  23  academic/research 
institutions, 6 of 22 non-EU citizens, 1 of 4 trade unions, 1 of 3 consumer organisations, and 255 
of 772 persons with disabilities across all categories). 

-  Cultural venues and institutions (670 of 1009 EU citizens, 51 of 71 NGOs, 24 of 33 public 
authorities,  18  of  26  companies/businesses/business  associations,  18  of  23  academic/research 
institutions, 11 of 22 non-EU citizens, 1 of 4 trade unions, 2 of 3 consumer organisations, and 496 
of 772 persons with disabilities across all categories). 

STRATEGIC INTERVIEWS 

The key concerns discussed during the strategic interviews were: 

- 

Identifying the EU legal basis to justify the EDC:  in  particular, whether it should be based 
either on Article 21 of the Treaty on the Functioning of the European Union (TFEU)178 on the 
right of EU citizens to move and reside freely within the EU territory or on Article 56 TFEU on 
the freedom to provide services within the EU (in case of services for remuneration). For that, the 
envisaged EU intervention should be supported by 

o  evidence  of  the  problems  faced  by  persons  with  disabilities,  and  possibly  magnitude 

thereof, whether they are mainly related to free movement or not 

178 Consolidated version of the Treaty on the Functioning of the European Union. Available at: link. 

71 

 
 
 
 
 
o  questioning whether the services in the scope of the EDC are for remuneration or not. 

-  Addressing extra cost and concerns for transport service providers: The application of EDC 
to access preferential conditions in the transport sector for persons with disabilities, might produce 
concerns and costs for transport service providers when they are requested to extend preferential 
conditions also to non-nationals with disabilities. These costs and concerns need to be carefully 
considered. 

-  Tackle fraud at local level when using European parking card for persons with disabilities, 
specifically, frauds relate to persons who e.g., cheated to demonstrate the disability status or that 
use  the  card  of  another  person  when  they  are  not  entitled  to  hold  the  Card.  Therefore,  some 
mechanisms should be introduced to prevent fraudulent activities and to ensure that cardholders 
genuinely hold the card based on their recognised disability status.  

TARGETED INTERVIEWS 

Problems   

The  target  interviews  provided  consistency  to  the  results  compiled  with  the  larger  consultation 
activities planned (call for evidence and public consultation). In this sense, again, the lack of mutual 
recognition of national disability cards and related consequences are the main concern for 3 of 3 
EU bodies, two of 3 EU CSOs and one academic expert. Among them, one EU body and one EU 
CSO highlighted that persons with disabilities are discouraged to travel for short-term stays as 
they are unsure regarding whether, and what type of, preferential conditions will be available to them 
in the host Member State. Then, one of 3 EU body and one academic expert stated that limited access 
to services offering preferential conditions for non-residents with disabilities de facto represents an 
obstacle to the exercise of their free movement rights and the right to receive services in the EU. 

Moreover, in consistence with the strategic interviews, one of two EU Parking association claimed 
that the problem of frauds and forgeries of the European parking card have a strong impact on 
the  right  of  persons  with  disabilities  to  easily  access  different  premises,  as  persons  using  fake 
European parking card take away the spaces  reserved for persons with  disabilities.  Moreover, the 
lack of cross-national database on parking cards’ design or on parking cards’ holders prevents 
a proper monitoring, as enforcers in charge of checking the validity of the European parking card are 
not  always  aware  of  how  a  real  European  parking  card  looks  like.  The  progress  of  technology 
exposes  the  European  parking  cards  to  more  and  more  sophisticated  frauds  and  forgeries. 
Hence, the current paper format needs an update. 

The necessity and added value of a possible EU action  

The majority of stakeholders’ (three of three EU bodies, two of three EU CSOs and one academic 
expert) considered that the action at the EU level is necessary, with introduction of a system of 
mutual  recognition  of  disability  status  in  the  EU  by  means  of  an  EU  Disability  Card  (EDC). 
Moreover,  the  two  EU  parking  associations  agreed  on  updating  the  parking  card  with  digital 
components is a key aspect of the initiative, and an area where the EU can bring added value with 
very concrete solutions. 

Policy options  

In terms of policy options for the EDC, there was less support, comparing when consulting to persons 
with disabilities, to make it mandatory for all services, while service providers could choose the 

72 

 
 
 
type  of  preferential  conditions  to  offer.  This  was  supported  by  the  disability  expert,  and  one 
interviewee from the EU CSOs and from the EU body. 

On the European parking card, there was a call not to merge the EDC with the European parking 
card by interviewees from the EU CSOs and disability expert. In addition, the importance of a fraud-
proof  European  parking  card  and  a  database  solution  that  would  link  vehicle  to  a  European 
parking card was highlighted by the disability expert, and one interviewee from the EU CSOs and 
from the EU body.   

ONLINE SURVEYS  

Problems 

20 out of 24 Persons with disabilities and 10 of 25 NCAs stated that the proof of disability is normally 
needed to get access to preferential conditions.  According to 20 out of 25 NCAs, 17 out of 23 national 
CSOs and nine out of 10 EU-level  CSOs, national  disability cards and certificates are not  always 
recognised  in  other  Member  States  which  represents  an  obstacle  for  persons  with  disabilities  to 
exercise their free movement rights and to access preferential conditions when using certain services 
abroad. 

When preferential conditions are not offered, the costs of travelling sustained by persons with 
disability increase to a large extent (19 NCAs, 14 national CSOs, 11 persons with disabilities, 9 
EU-level CSOs, and 3 other relevant public authorities). 

As concerns the European parking card, some NCAs (13), persons with disabilities (11). national 
CSOs  (9),  EU-level  CSOs  (6),  and  other  public  authorities  (2)  consider  that  the  correct 
implementation  of  the  European  parking  card  is  hindered  by  its  limited  recognition  across  the 
Member States. Several stakeholders’ groups (NCAs, national CSOs and EU level CSOs) pointed out 
that the card’s mutual recognition across the Member States is hindered by national differences in 
validity period of the card, card design and rights granted by the card.  

The necessity and added value of a possible EU action  

The majority of respondents (22 NCAs, 22 national CSOs, 21 persons with disabilities, 10 EU-level 
CSOs  and  3  other  relevant  public  authorities)  argued  that  the  EU  intervention  would  have 
particularly added value compared to what individual countries could do towards facilitating 
mutual recognition of disability status among Member States. In their view, an EU intervention would 
be necessary to: 

•  Facilitate access to services offering preferential conditions for persons with disabilities in all 
the Member States (23 NCAs, 21 national CSOs, 22 persons with disabilities, 9 EU-level CSOs). 
•  Ensure that persons with disabilities are offered the same preferential conditions as residents 
of the country to which they travel to (22 NCAs, 22 national CSOs, 20 persons with disabilities, 
10 EU-level CSOs and 3 other relevant public authorities). 

•  Improve the implementation of the European parking card for persons with disabilities (22 
persons  with  disabilities,  21  NCAs,  21  national  CSOs,  8  EU-level  CSOs  and  4  other  relevant 
public authorities). 

Policy options  

73 

 
 
 
The majority of respondents support the introduction of a binding EDC in all the Member States 
(24 out of 24 persons with disabilities, 19 out of 23 national CSOs and 18 out of 25 NCAs). The 
majority of respondents claimed that: 
-  The EDC should have both an electronic and a plastic format (17 national CSOs, 16 NCAs, 12 

persons with disabilities, eight EU-level CSOs and four other relevant public authorities).  

-  The holders of a national disability card or certificate should be automatically entitled to the 

EDC (23 national CSOs, 22 persons with disabilities and 22 NCAs). 

-  Specific security features shall be added on the card (e.g., holograms, QR code, barcode, etc.) 
to prevent forgery and fraud of the EDC (22 NCAs, 21 national CSOs, 10 EU-level CSOs and 4 
other relevant public authorities). 

-  A  common  EU  platform  where  users  can  get  information  on  the  preferential  conditions  and 
services offered in each Member State (22 persons with disabilities, 22 NCAs, 22 national CSOs 
and 4 other relevant public authorities). 

-  An EU-wide awareness-raising campaign to inform relevant stakeholders about the card, its 
features, and benefits (22 national CSOs, 21 NCAs, 10 EU-level CSOs and 4 other relevant public 
authorities).  

The majority of persons with disabilities and national CSOs (15 out of 24 persons with disabilities, 
15 out of 23 national CSOs) believe that the eligibility criteria to receive the European parking card 
and the EDC should be the same. As to the merging of the European parking card with the new EDC, 
16 persons with disabilities think that the two cards shall be merged, whilst 11 NCAs and 3 EU-
level CSOs representatives believe that the two cards shall be kept separate. 

Impacts 

The majority of respondents believe that the EDC would facilitate (i) the exercise of free movement 
(22  NCAs,  21  national  CSOs  and  4  other  relevant  public  authorities);  (ii)  the  right  to  receive 
preferential conditions when accessing certain services (23 NCAs, 21 national CSOs and 4 other 
relevant public authorities). 

Indeed, it is expected that the EDC would increase: (i) the number of persons with disabilities 
travelling in the EU and (ii) the frequency of travelling (21 NCAs, 21 national CSOs, 4 EU-level 
CSOs and 4 other relevant public authorities); (iii) the length of staying abroad (22 national CSOs, 
15 NCAs, 3 EU-level CSOs and 3 other relevant public authorities,); (iv) the number of persons 
with  disabilities  using  certain  services  when  travelling  to  other  Member  States  (20  NCAs,  18 
national CSOs 3 EU-level CSOs and 3 other relevant public authorities,); (v) the take up by persons 
with disabilities of cultural, leisure, sports, and travel services (23 NCAs, 22 national CSOs, 9 
EU-level CSOs and 4 other relevant public authorities).  

As concerns the cost entailed by the EDC, most service providers (7) highlighted that the introduction 
of  the  EDC  will  not  bring  significant  change  in  the  costs  related  to  recruiting  additional  or 
specialised staff; or keeping track of the number of customers with disabilities accessing preferential 
conditions with the EDC (8 service providers). However, about half of respondents (12) consider that 
there will be a small increase in the cost of training staff for the provision of personalised services. 

Overall, the majority of service providers (18) stated that the cost of offering preferential conditions 
to persons with disabilities would be relatively low. Moreover, the 23 service providers responding 
to  the  survey  agreed  that  such  costs  are  offset  and  even  exceeded  by  the  returns  in  terms  of 
service providers’ visibility, reputation, attracting new customers and other benefits.  

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As concerns the European parking card, according to the majority of respondents, specific security 
features (e.g., holograms, QR codes, barcodes, etc.) shall be added to the EU-model with the aim to 
tackling (i) forgeries (19 national CSOs, 16 NCAs, 7 EU-level CSOs and 2 other PAs) and (ii) frauds 
(15 national CSOs, 13 NCAs, 6 EU-level CSOs and 3 other PAs). 

In  terms  of  the  efficiency  of  the  European  parking  cards,  although  some  NCAs  and  other  public 
authorities claim  that the European parking card  entails  costs for national authorities in  charge of 
managing and issuing the card in the Member States (11 of 25 NCAs and 3 of 5 PA)179 the majority 
of respondents believes that the benefits linked with the adoption of the European parking card 
have overcome the related costs. 

To  conclude,  public  authorities  and  CSOs  have  divergent  opinions  regarding  the  costs  of 
merging the EDC and the European parking card. More specifically, in case the two cards are 
merged NCAs, and other relevant public authorities expect: 

-  A  slight  increase  in  indirect  costs  i.e.,  the  final  price  for  the  general  public  to  use  services 

covered by the card would be higher (9 NCAs). 

-  A decrease in costs related to the issuance of the Card e.g., managing application procedures, 
producing the cards, delivering the cards (11 NCAs and 5 other relevant public authorities). 
-  A decrease in costs related to the monitoring (e.g., keep track of the number of cards issued) 
(9 NCAs) and reporting (e.g., storing information concerning the card use) its implementation 
(7 NCAs). 

-  A decrease in enforcement costs e.g., inspections, handling complaints, forgery controls (4 other 

relevant public authorities).  

WORKSHOPS 

Problems  

Participants  in  the  workshop  (seven  of  11  CSOs  and  17  of  19  NCAs  representatives  think  that 
differences  in  terms  of  format  and  features  of  national  disability  cards  and  certificates 
contribute to the limited recognition of disability status across the Member States, particularly 
in the case of invisible disabilities (one CSO). Importantly, six national service providers complained 
that they are not familiar with all national disability certificates issued above, hence they often end 
up not to accept them, particularly when information is provided in foreign languages. 
Seven out of eight CSOs and 12 out of 20 NCAs representatives think that persons with disabilities 
are  discouraged  from  travelling  abroad  as  a  consequence  of  the  limited  recognition  of  the 
national disability cards or certificates across  the Member States.180 Likewise, they think that 
persons with disabilities are discouraged from travelling abroad because they have no certainty 
regarding their access to preferential conditions offered across the Member States. 

Seven out of eight CSOs and 14 out of 19 NCAs representatives find that national differences in 
terms of design and functioning of the European parking card hinder its mutual recognition 
across  the  Member  States.  Due  to  the  limited  recognition  of  their  European  parking  card  abroad, 

179 11 out of 25 NCAs replying to Q3.11, 3 out of 5 other PAs replying to Q3.11. 
180 Seven out of eight CSOs replying to Q5 and 12 out of 20 NCAs replying to Q3; Seven out of nine representatives of 
CSOs replying to Q2. 

75 

 
 
 
 
persons with disabilities feel discouraged from travelling abroad (five out of six CSO and 17 
out of 20 NCAS). 

Policy options 

Participants in the workshops stated that the EDC should include common security features, which 
would prevent fraudulent use of the card (3 of 11 CSO and 1 of 29 NCA). As for the  format, the 
majority of participants in the workshops argued that the EDC should be available both in digital 
(including a QR Code) and physical (i.e., plastic) format. 181 

Participants (8 of 11 CSO  and 3 of 29 NCAs) argued that the introduction of the EDC should be 
accompanied by the establishment of an accessible and easy-to-read EU database/website about the 
(i) number of EDC released, (ii) number of persons entitled to obtain the EDC, (iii) notices about 
cases of fraudulent use of the EDC, (iv) number and type of service provider offering preferential 
conditions, (v) practical details regarding where to get and use the EDC as a resource to support the 
card and its effective implementation, provided that information included in the website is verified 
(e.g.  if  the  providers  are  indeed  providing  preferential  conditions  and  in  an  accessible  way)  and 
frequently updated (1 of 11 CSO and 1 of 29 NCA). Moreover, the uptake and use of the EDC should 
be supported by an EU-wide awareness-raising campaign, (6 NCAs and three CSO) as well as by 
an  EU-wide  control  system/authority  in  charge  of  monitoring  and  coordinating  the  EDC 
implementation across the Member States (6 of 29 NCAs and 4 of 11 CSO). 

Finally, as concerns the European parking card, six out of seven CSOs and six out of 11 NCAs 
representatives participants in the workshops agreed that to avoid fraud and forgery and address new 
ways of controlling parking rights an update of Council Recommendation 98/376/EC (notably its 
Annex I) would be necessary. 

Impacts 

Participants in the three workshops strongly agreed on the introduction of a common model EDC 
that would enable its mutual recognition by public authorities and service providers across the EU 
(10 of 29 NCAs and 4 of 11 CSO). Indeed, participants believe that the obligation for the Member 
States to grant the same preferential conditions to all EU citizens with disabilities will have a 
positive impact on the free movement of persons with disabilities in the EU (16 of 16 NCA and 7 of 
7 CSO). Overall impacts would be even greater in case the mandatory provision of preferential 
conditions  is  extended  to  personal  assistants  of  persons  with  disabilities.182  Also,  four  of  20 
service providers remarked that introduction of a common EDC will contribute to reduce costs and 
burdens associated with the assessment of different national disability cards in circulation. 

The totality of NCAs representatives (29 of 29) and most of CSO (8 of 11) think that the European 
parking card should not be merged with the new EDC. In this regard, participants argued that 
having just one card, would be complicated. The card should be left in the car for its use as a parking 
card, while it could also be necessary as proof of disability to be shown to the service provider in 
order  to  get  preferential  conditions  e.g.,  in  a  museum  (3  of  11  CSO  and  1  of  29  NCA).  Another 
argument against merging the two cards is the difference in eligibility criteria (3 of 11 CSO and 1 of 
29 NCA), as persons eligible for the parking card are not always the same as those eligible for the 

181 One CSO representative; Two CSOs representatives and two NCAs representatives. 
182 Seven out of eight CSOs representatives replying to Q8 and 15 out of 16 NCAs representatives replying to Q6. 

76 

 
 
 
 
EDC.  In  case  the  two  cards  are  merged,  a  single  authority  would  be  in  charge  of  managing  a 
significant  increased  number  of  persons  entitled  to  get  the  card,  and  delivery  procedures  may  be 
lengthened (1 of 29 NCA). 

FOCUS GROUPS  

Overall,  participants  highlighted  that  the  lack  of  mutual  recognition  of  disability  status  in  the  EU 
generates  significant  administrative  burdens  related  to  the  assessment  of  the  validity  of  the 
different national disability cards. Yet, participating service providers were very positive about 
the permanent introduction of the EDC, stating that it would eliminate administrative barriers to 
mutual recognition and increase access of persons with disabilities to services.  
According  to  participants,  the  EDC  would  reduce  the  additional  costs  and  administrative 
burdens  faced  by  service  providers  when  offering  preferential  conditions  to  non-residents  with 
disabilities. Moreover, participants  also  agree that  offering preferential  conditions  to  persons with 
disabilities from other Member States would improve the reputation of their organisation. Finally, 
all  the  participating  service  providers  remarked  the  necessity  to  organise  EU-wide  awareness-
raising campaign, in all EU languages, with the aim to inform service providers and to promote the 
use of the EDC across the EU.  

CASE STUDIES 

Problems 

Interviewees pointed out that, at national level, misuses of the European parking card still happen 
regularly, in particular frauds and forgeries. Moreover, at  local/regional  level, there are different 
parking and traffic rights granted to cardholders, and lack of information about these different 
conditions, which often results in fines received by persons with disabilities assuming they could use 
their card as they do in their municipality/region. Indeed, according to CSOs, the lack of information 
on the different rules related to the parking card and advantages granted to cardholders in the different 
Member States is a significant issue also at cross-border level, which often leads to uncertainty and 
undue fines. 

Policy options 

Some recommendations to improve the use of the European parking card were provided, among 
which: 

- 

Improving the parking card model with digital features (e.g., hologram, QR code) to address 
the fraud and forgery and to allow the recognition by the car plates scan or at the park meter. 
-  Establishing national databases of parking card holders to check the validity of the cards and 

making them interoperable at EU-level to facilitate cross-border checks. 

-  Establishing  an  EU-wide,  uniformly  accessible  website  where  users  can  find  the  rights 

associated with their parking card in each Member State. 

Finally, there was unanimity in the fact that EDC should not be merged with the EU parking 
card, as the scope of the two instruments is too diverse. Only one parking association representative 
interviewed was in favour of merging them if a common database of card holders will be accessible 
for parking rights controllers. 

SUMMARY OVERVIEW OF RESULTS FOR KEY IA ELEMENTS 

77 

 
 
 
PROBLEMS 

The European Commission bases its initiative on two problems (i) lack of mutual recognition of 
disability status as depriving persons with disabilities of an important facilitation of free movement 
and concerning (ii) the fraudulent actions in the use of the European parking card.  

There  was  clear  consensus  amongst  all  stakeholders  (i.e  Persons  with  disabilities,  EU  level 
stakeholders, national authorities, CSOs, service providers) consulted trough different consultation 
activities  (i.e.,  online  survey,  public  consultation,  targeted  interviews,  workshops)  that  national 
disability  cards  are  not  always  accepted  when  persons  with  disabilities  travel  across  Member 
States.  

Consulted stakeholders across stakeholders’ groups largely agree on a discouragement from travel 
due to  the lack of access to  preferential conditions  for services  and thus  an  increase of costs  for 
travelling  for  persons  with  disabilities.  In  addition,  through  the  Call  for  evidence,  and  later 
reaffirmed in the targeted interviews and the workshop, the lack of information on the preferential 
conditions available in the host country was identified as well as an obstacle for travelling of persons 
with disabilities, as they feel discouraged because of the uncertainty. 

The focus group further identified significant administrative burdens related to  assessment of the 
validity of the different national disability cards. In that sense, participating  service providers 
were  very  positive  about  the  introduction  of  EDC,  stating  that  it  would  eliminate  these 
administrative barriers and would increase access of persons with disabilities to services. 

Regarding  the European Parking Card, consulted stakeholders across all categories largely  agreed 
that  the  current  situation  where  different  formats,  designs  and  rules  are  provided  for  its 
implementation of at national, regional, and local level, hinder mutual recognition and increase 
the risk for fraudulent actions. The lack of a cross-national database causes that enforcers in charge 
of checking the validity of the European parking card are not always aware of how a real European 
parking card looks like. The public consultation and the online surveys additionally show that the 
differences in the validity period of the European parking cards also create concerns about the 
mutual recognition of the cards. 

THE NECESSITY AND ADDED VALUE OF A POSSIBLE EU ACTION 

The perception of the need for EU action and the EU added value was positive overall among the 
range of stakeholders consulted on both the implementation of EDC and the European Parking Card. 
Particularly,  respondents  to  the  online  survey  from  all  the  consulted  categories  (i.e.  Persons  with 
disabilities, NCA, CSOs and service providers) agreed that EU intervention would have particularly 
added  value  compared  to  what  individual  countries  could  do  towards  facilitating  mutual 
recognition of disability status among Member States. 

In  that  sense  stakeholders  across  all  consultation  activities  consider  that  EDC  will  facilitate  the 
mutual recognition of disability status among EU Member States. In addition, through most of the 
consultation activities (public consultation, online surveys, targeted interviews, and focus group) the 
action  at  the  EU  level  is  likely  to  contribute  to  facilitating  the  access  to  services  offering 
preferential conditions to persons with disabilities.  

There was  clear  consensus amongst  all stakeholders consulted (i.e., persons with  disabilities, EU-
level  stakeholders,  NCAs  and  other  public  authorities,  EU-level  and  national  CSOs, 

78 

 
 
 
companies/business associations and trade unions) that the key  added value of  action at  EU level 
would  be  improving  the  implementation  of  the  European  Parking  card  for  persons  with 
disabilities. 

POLICY OPTIONS 

The  majority  of  consulted  stakeholders  support  a  binding  legal  instrument  for  the  European 
Disability Card. Especially participants of the public consultation suggested  no option for opting 
out. In addition, during the online survey, Persons with Disabilities, CSOs, and NCAs identified, that 
the holders of a national disability card or certificate should be automatically entitled to the EDC. 
However, there was a less positive view by the targeted interviews on the binding character of the 
EDC, while service providers could choose the type of preferential conditions to offer.  

The  online  survey,  the  workshops  and  the  case  studies  identified  the  need  of  including  specific 
security features on the card to prevent its fraudulent use. Furthermore, there is an overall consensus 
through stakeholders (evidenced in the call for evidence, online surveys, and workshops) that a digital 
and physical format of the card is needed. 

There  was  a  wide  consensus  by  national  and  EU-Level  CSOs,  NCAs,  and  other  relevant  public 
authorities  on  accompanying  measures  such  as  an  (i)  awareness  raising  campaign,  (ii)  an  EU 
platform with info of preferential conditions and services offered in each Member State. Some 
NCAs  and  CSOs  supported  an  EU-wide  control  system/authority  to  monitor  the  EDC 
implementation. 

Finally, there is a clear dichotomy on merging the European parking card with the new EDC. On one 
side, there is an overall consensus across ‘institutional’ stakeholders (all case studies, EU-level CSOs, 
NCAs) that the European parking card should not be merged with the new EDC. However, the 
majority of respondents, from all stakeholder categories to the public consultation, as the tool showing 
the most the interests of EU-citizens with disabilities, agreed that the European parking card should 
be incorporated into the new EDC. 

IMPACTS 

First,  there  is  a  clear  consensus  among  stakeholders  consulted  through  the  different  consultation 
activities on welcoming the EDC initiative, emphasising that the adoption of a mutually recognised 
EDC will facilitate (i) the freedom of movement for persons with disabilities in the EU and (ii) the 
right to receive preferential conditions when accessing certain services. Moreover, stakeholders 
agreed (specially EU citizens, NCA and CSO through the public consultation and the online 
surveys) that EDC would increase: (iii) the number of persons with disabilities travelling in the 
EU and those using certain services; (iv) the frequency and length of staying abroad; (v) and the 
take up by persons with disabilities of cultural, leisure, sports, and travel services. 

On the other side, a key concern identified is related with the costs incurred by the implementation 
of the EDC. Overall, the majority of service providers stated that the cost of offering preferential 
conditions to persons with disabilities would be relatively low. As well, all respondents of the online 
surveys agreed that such costs are offset and even exceeded by the returns in terms of service 
providers’ visibility, reputation, attracting new customers and other benefits.  

Regarding specific costs, service providers (online surveys) highlighted  (i) cost of training staff; 
CSOs (call for evidence) highlighted the (ii) investments into infrastructure, technologies, people, 

79 

 
 
 
and skills; and (iii) handling of sensitive customers data; and according to the strategic interviews, 
special attention should be put on the extra cost for (iv) service providers on transport, when they 
are  requested  to  extend  preferential  conditions  also  to  non-nationals  with  disabilities.  Overall 
respondents in the public consultation think that EDC would have no impact on regulatory charges, 
e.g., fees, levies, and taxes, and indirect costs e.g., price increases for the general public for services 
targeted by the card.In terms of the efficiency of the European parking cards, although some NCAs 
and other public authorities claim that the European parking card entails costs for national authorities 
in charge of managing and issuing the card the majority of respondents in the online surveys believes 
that  the  benefits  linked  with  the  adoption  of  the  European  parking  card  have  overcome  the 
related  costs.  To  conclude,  public  authorities  and  CSOs  have  divergent opinions  regarding  the 
costs of merging the EDC and the European parking card. 

Finally,  most respondents  of the public consultation agreed that the costs entailed by EDC would 
affect  the  following  stakeholders  by  a  small  to  a  medium  extent:  (1)  Member  States’  public 
administrations  and public authorities offering preferential  conditions  for  persons with  disabilities 
(17 of 29 public authorities) (2) Large companies and SMEs (19 of 25 companies, 2 of 4 trade unions, 
2 of 3 consumer organisations) (3)  Civil  society organisations (20 of 66  NGOs), and  (6)  Cultural 
venues and institutions (50 of 66 NGO, 21 of 29 public authorities, 2 of 3 consumer organisations). 

CONSULTATION WITH AND POSITIONS OF MEMBER STATES 

Disability Platform and its Sub-group on European Disability Card 

The  initiative  and  the  state  of  play  of  its  implementation  was  presented  in  each  meeting  of  the 
Disability  Platform  in  2022-2023.  The  Disability  Platform  is  an  advisory  group  of  the  European 
Commission in the area of disability, composed by representatives of Member States and civil society. 

In addition, the Sub-group on European Disability Card was created and met twice on 20 May 2022 
and 15 May 2023, when the state of play was discussed and Member States and civil society could 
express their opinions on particular issues. It includes 11 Member States (CY, CZ, EL, DK, HU, IT, 
MT, NL, PL, PT, SI) and four organisations representing persons with disabilities (Autism Europe, 
European Blind Union, European Disability Forum, European Union of the Deaf). 

Since the adoption of the Commission Work programme 2023 in October 2022, the Commission in 
its  presentations  and  discussions  in  the  meetings  below  made  clear  the  legislative  nature  of  the 
initiative. 

Positions of Member States 

Meeting of the Social Protection Committee in Stockholm on 3 April 2023 

The European Disability Card initiative was one point on the agenda: 

The Commission presented the building blocks of the forthcoming proposal and the preliminary 
results of the ongoing consultations and invited a discussion, in particular on the potential scope of 
the European Disability Card, its possible digitalisation, as well as potential for integration with 
the EU parking card. 

80 

 
 
 
In the ensuing discussion, several delegations shared their positive experience with the pilot project, 
launched in 2018.  The early involvement of civil society organisations and other stakeholders in the 
development of the card was pointed out as a key success factor. 

All intervening 16 Member States supported the introduction of the card. The majority expressed a 
preference for retaining the scope of the Card to the areas already covered by the pilot project 
(leisure,  culture,  sport  and  transport).  One  Member  State  is  in  favour  of  limiting  the  scope  by 
excluding transport.  Some indicated a level of flexibility in expanding the scope to other elements 
(services) that enable the inclusion of persons with disabilities, and emphasised a strong preference 
for  voluntary  participation  of  the  service  providers,  as  well  as  expressing  some  cost-related 
concerns. Several Member States indicated they would not support the expansion of the scope 
to the provision of benefits in social security.              

There was consensus among all of the intervening 16 Member States that the EU Disability and EU 
Parking Cards should be kept separate and that both physical and digital cards should be issued 
to the card beneficiaries, to ensure equal access  and limit the impact of the digital gap for certain 
users.  Several Member States emphasise the need for proper oversight to avoid possible abuse, and 
raised the issue of data protection. 

Meeting with Member States organised by Finland on 17 May 2023 

On 17 May 2023 Finland, which is taking part in the pilot EU Disability Card and has expressed a 
strong interest in the initiative, organised a meeting of Member States to discuss the initiative. The 
meeting  conclusions  made  by  Finland  highlight  that  the  EDC  initiative  is  warmly  welcomed. 
Recommendations include careful planning of the extension of the services covered, no merger of the 
parking card for persons with disabilities with the EDC into a single card, and no coverage of social 
security and healthcare benefits. Member States’ positions expressed during the meeting are described 
in more detailed below. 

Position papers of Member States 

Seven  Member  States  and  one  region  have  so  far  submitted  a  position  paper  (Denmark,  Finland, 
France, Hungary, Italy, Poland, Sweden and Bavaria), all of them supportive of an  EU legislative 
initiative. 

Denmark: 

•  Focus on facilitating access to preferential conditions and discounts for people with disabilities 
on  short-term  stays  in  other  Member  States,  within  the  areas  of  culture,  leisure,  sport  and 
transport. 

•  No harmonisation or common disability definition at EU level, assessing and granting disability 

status remains a national competence. 

•  Well-defined  and  limited  scope  that  respects  national  competences  and  the  principle  of 

subsidiarity.  

•  No  inclusion  of  education,  housing,  employment,  social  security  and  social  protection,  and 
benefits and services that require pre-authorisation or demand more thorough assessments of the 
specific individual’s needs. 

81 

 
 
 
•  Voluntary application for the card by persons with disbailities and service providers should be 
able to decide freely on the range of preferential conditions and discounts they offer to people 
with disabilities, including cardholders. 

•  Format - physical and supplementary digital version. The Commission should develop and make 

mutually recognised digital version of the card available.  

•  Separate European Disability and EU parking card. 

•  Careful consideration to be paid to financial costs and administrative burdens imposed on Member 

States and businesses. Member States to decide if the card should be free of charge. 

•  No obligation for public subsidies to cover potential extra costs of businesses.  

•  Data collection limited to the operation of the EU Disability Card.  

Finland: 

•  An EU-wide Disability Card can positively impact on the equality and inclusion of persons with 
disabilities when they travel from one Member State to another; on raising awareness of the rights 
of persons with disabilities, including among service providers 

•  Scope: transport, culture, leisure and sport.  

•  The implementation, use and legal coverage of the card and the criteria for issuing it should be 

defined at national level in line with the piloted model.  

•  Voluntary application for the card by persons with disabilities. 

•  National competence – disability assessment and definition. 

•  To  involve  persons  with  disabilities  and  disability  organisations  in  the  development  of  the 

Disability Card at all stages.  

•  Accessibility of the card and of information on the card and on how it can be used in different 

countries. 

•  Easy application for the card. 

•  Format: plastic form and digital application. Digital card to be compatible with other EU-level 

digital solutions; attention to be paid to protection and the secure processing of data.  

•  Separate EU parking card and European Disability Card. 

France: 

•  The definition and mutual recognition of disability status is a national competence together with 

disability assessment 

•  FR welcome the EDC initiative for 

o  Promoting freedom of movement and equal treatment for Persons with disabilities when 

accessing to culture, leisure, sport and transport. 

o  Better reconciliation among national and EU objectives and concretization of EU values 

promoting equality for vulnerable population 

o  Encouraging rights granted at national level, as these would apply to all national and EU 

citizens 

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•  Since  2017,  FR  has  three  types  of  disability  cards:  “stationement”  (Parking  Card),  “priorité” 
(people  with  less  than  80%  of  disability,  with  priority  access  to  transport  and  queues),  and 
“invalidité” (people with minimum of 80% disability, receiving invalidity pension, similar to the 
“priorité” card with some additional reductions in transports and tax benefits.) 

•  FR support to have only one card, including the national disability card and the future EDC 

o  This card would be issued by Member States or local authorities 

o  Common graphic format and security system at EU level 

o  That can be used at national and EU level 

•  Having a EDC different from the national disability card would 

o  force Persons with disabilities to make an additional effort to get the EDC 

o  reserve the rights of the EDC only to those who had sufficiently anticipated their trip 

o  be seen as a regression for Persons with disabilities who can currently use their national 

card in other Member States 

o  make difficult to prohibit the use of the EDC to nationals in their own  Member States, 
thereby making it unnecessary to possess national card which would carry the same rights. 

•  The European Parking Card must be kept separated from EDC 

•  The EDC must distinguish two categories of beneficiaries: 

o  Persons with disabilities that needs someone accompanying to get around. Then, e.g., in 

public transport the accompanying person does not have to pay the ticket. 

o  Persons with disabilities that can travel alone and then e.g., they cannot be accompanied 

free of charge 

•  The future EDC would have to be accompanied by an active and accessible communication to 

know the rights attached to it. 

•  The specific conditions for the EDC and the European Parking Card may vary between Member 

States and withing each State. 

o  Beneficiaries must be easily and clearly informed of these differences. 

•  Both physical and digital EDC must be developed. 

•  Security to avoid fraud is key. For the physical card, a QR code for the verification of the card is 
put  as  a  good  example  (as  it  happens  now  with  the  FR  “carte  mobilité  inclusion”)  For  the 
digitalisation, an electronic signature can guarantee the identification of the issuing body and the 
integrity of the data contained.  

•  The EDC must be easy to use for Persons with disabilities in their daily life. 

Hungary: 

•  The definition and mutual recognition of disability status is a national competence together with 

disability assessment.  

•  The card should have a  well-defined,  clear and limited  scope, which should support access  to 
preferential conditions and benefits for persons with disabilities during their short stays in other 

83 

 
 
 
 
Member States. The European Disability Card should be adapted to national service structures 
and systems. 

•  A single card EU to allow for mutual recognition of the cards.  

•  To prepare a list of discounts and possible services linked to the card, which would be subject to 

a decision of the Member States. 

•  Format - hybrid solution - plastic form and digital application. 

•  Voluntary application for the card by persons with disabilities. 

•  Necessary  careful  consideration  to  the  financial  costs  and  administrative  burden  imposed  on 

Member States. 

•  Separate cards - the EU parking card and European Disability Card.  

Italy: 

•  Welcomed a legislative proposal on a European Disability Card.  

•  Scope: transport, culture, sports, entertainment, and leisure. Each Member State should engage 
with potential public and private providers, thus allowing to broaden the range of benefits and 
concessions for the provision of goods and services. 

•  The criteria for issuing the card to be identified at national level.  

•  Mutual recognition of the card regardless of the different criteria adopted by each Member State 

for the issuance of the card.  

•  Necessary involvement of persons with disabilities and their organisation in the development of 

the card at all stages.  

•  Format: plastic  and digital.  Any digital card should  be compatible with  other EU-level  digital 

solutions. Particular attention should be given to data protection.  

•  Separate EU parking card and European Disability Card. 

•  Accessible,  easy,  and  comprehensive  information  on  the  card  and  on  how  it  can  be  used  in 

different member states.  

Poland:  

•  No harmonisation of disability status and assessment systems across the EU, national competence 

to grant disability status should remain; 

•  Scope of the Card: preferential conditions and discounts in the area of culture, recreation, sport 

and transport, respecting the regulations in individual EU countries;                               

•  Member State to decide on the scope of rights on its territory, while maintaining the differentiation 

of rights to discounts and preferential rates at the national and local level; 

•  The Card should not cover health, employment, education, social security, social protection or 

housing; 

•  Two separate cards: the European Disability Card and the EU Parking Card; 

•  National competence for granting and issuing the Card; 

•  Format: physical and electronic, a person with a disability could choose a format; 

84 

 
 
 
•  EU funds should available for issuing and implementing the Card; 

•  EU and national bodies to coordinate the implementation;  

•  The transposition period: at least 2 years;  

• 

Indicating the degree of disability on the Card should be considered, as discounts and preferential 
rates often depend on the degree of disability, especially for transport, to avoid unequal treatment 
of nationals with moderate or mild disabilities. 

Sweden: 

•  There is currently no specific card for all persons with disabilities in use in Sweden and therefore 
no official criteria in place on which the issuing of such a card could be based. Given the structure 
of Sweden’s disability policy, persons with disabilities are not registered based on their disability. 

•  The recognition of disability status is and must be a matter of national competence. 

•  Adequate room should be left for Member States to adjust the implementation of the initiative to 

national circumstances.  

•  The  scope  of  a  potential  European  Disability  Card  would  have  to  be  clear  and  limited  to  be 
effective. This is not least important as the functioning of a card will require mutual recognition 
of disability status based on national assessments.  

•  The financial and administrative burden for Member States is kept proportionate to the purpose 

of the initiative. 

Bavaria: 

•  To respect  subsidiarity  –  disability status  can  continue to  be recognized  only  at  national  level 
(including the issuing of national identity cards/certificates). As the European Commission rightly 
points out in its invitation to comment on an impact assessment, the concept of ‘disability’ must 
not be harmonized at EU level. In addition, according to the European Commission, the scope of 
a possible EU disability card should not cover social security benefits to which access is governed 
by national rules and, in a cross-border context, by the regulations on the coordination of social 
security systems. 

•  Proportionality – preference for Council recommendation or Directive. 

•  Facilitating  the  free  movement  of  persons  with  disabilities  in  the  EU  -  could  help  to  further 
promote the inclusion of persons with disabilities in everyday life; could result to equal benefiting 
from the same benefits; to increase social acceptance as a uniform EU disability card could  be 
used to prove the existence of a disability. Such a uniform Europe-wide possibility of proving the 
existence of a disability could be greatly facilitated for persons with obstacles, particularly when 
carrying out cross-border activities and travelling to other Member States. 

•  Limitation  of  the  scope  to  short-term  stays  of  up  to  three  months,  particularly  for  touristic 

purposes and the scope should be narrowly defined. 

•  Voluntary granting of advantages by service providers - for the Member States and the providers 
of services to determine whether favourable treatment and compensation for disadvantages are 
granted.  

85 

 
 
 
 
•  No (indirect) harmonisation of the concept of disability and coverage of social security – but there 
is a risk for Germany as concerns public transport – free transport falling under social protection. 

•  Risk of discrimination against nationals because different criteria are used in different Member 

States and different benefits are assigned to different levels of disability. 

ANNEX 3: WHO IS AFFECTED AND HOW? 

Practical Implications of the Initiative 

The practical implications and key obligations to implement the initiative for both NCAs and service 
providers are indicated in Table 1 below, how these translate into costs is detailed in section 1.2; how 
the initiative would impact small and medium enterprises is in Section 1.4.  

Table 1 - Type of actions undertaken by NCA and service providers 

Actions 

NCA 

Service providers 

Management  of 
application process  

the 

X 

Production of the card  X 

Delivery of the card 

Establishment  of  the 
website  

X 

X 

X 

collection 

to 
the  use  of 

Data 
monitor 
EDC 
Providing  benefits  to 
non-residents 
with 
disabilities  
[1] Type of preferential conditions available to persons with disabilities per each sectors: Data shall be regularly 
(e.g.  on  a  yearly  basis)  collected  and  shared  by  each  service  provider.  The  monitoring  exercise  shall  be 
mandatory  at  least  for  service  providers  requested  by  law  to  offer  preferential  conditions  to  persons  with 
disabilities. As for preferential conditions offered on a voluntary basis, service providers may decide whether 
monitor and share such data. 

x 

Summary of costs and benefits 

The Tables below provide a detailed assessment of the benefits and the costs of the preferred policy 
options A2 (the introduction of the EU Disability Card in all Member States on a mandatory basis for 
all services in the internal market offering preferential conditions to nationals with disabilities) with 
option B2 (an EU legislative act to provide for the mutual recognition of EU parking cards) identified 
following the comparison of the policy options. Benefits and costs are quantified whenever possible, 
and when this is not possible, a qualitative justification and an explanation is provided. Furthermore, 

86 

 
 
 
 
 
  
  
  
  
  
  
and in line with the approach of a Cost-Effectiveness Analysis, benefits are provided in monetary 
terms only when this is appropriate given the nature of the benefit being assessed. 

Summary of costs and benefits of policy option A2 

Table 2 – Overview of Benefits (total for all provisions) – Preferred Option A2 and B2 

Description 

Amount 

Comments 

Direct benefits 

Improved  welfare  Increase 
in  individual  and  societal 
welfare  
Enhanced  participation 
in 
short term  travelsof persons 
with disabilities 

Reduction of the travel 
gap  for  Persons  with 
disabilities of between 
2.8 
4.12 
and 
percentage points 

Improved  market  efficiency 
–  Cost  savings  for  persons 
with disabilities travelling 

Ranging between EUR 
30  and  EUR  120  in 
total  for  persons  with 
disabilities 
travelling 
for  stays  of  about  4 
days,  between  EUR 
100 and 400 in total for 
with 
persons 
travelling 
disabilities 
for about 2 months 

The  reduced  uncertainty  regarding  the 
recognition  of  disability  status  and  the 
subsequent  provision  of  preferential 
conditions  and  personalised  services  to 
persons  with  disabilities  travelling  for 
short-term stays is expected to lead to an 
increase in both the share and number of 
persons with  disabilities  travelling  in  the 
EU.  While  the  exact  increase  cannot  be 
quantified,  it  was  estimated183,  based  on 
existing  data on persons with  disabilities 
184 and the evolution of travel patterns in 
the general population185. This will in turn 
have  a  positive  societal  impact  through 
improvements 
the  culture,  social 
integration  and  personal  development  of 
persons with disabilities.  

in 

travelling 

Cost savings for persons with disabilities 
currently  being  denied  preferential 
conditions  when 
to  other 
Member States (or not travelling abroad), 
estimated  at  about  44%  according  to  the 
results of the Public Consultations. These 
costs savingswere identified through case 
studies  of  individual  travellers  journeys. 
These  were  elaborated  as  the  potential 
direct monetary savings coming from the 
preferential  conditions  already  provided 
by  service  providers,  across  different 
travel  scenarios.  The  process  leading  to 

183 See Annex 9, Calculation of the travel gap for a detailed overview of the procedure in cacultating the travel gap 
184 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. Estimates on the economic contribution of accessible tourism 
to the EU economy are included in Section 6 of the report. 
185 Eurostat database, tour_dem_toage. Available at: link. 

87 

 
 
 
 
n.a. 

n.a. 

Improved  market  efficiency 
–  Cost  savings  and  general 
reduction in hassle costs for 
persons with disabilities and 
service providers 

Improved  market  efficiency 
–  Improved  information  on 
the  preferential  conditions 
to  persons  with 
offered 
disabilities 

Indirect benefits 

Wider 
macroeconomic 
benefits  –  Benefits  in  the 
accessible 
market 
tourism 

for 

Value  added  in  the 
market  for  accessible 
tourism:  the  estimates 
range  from  2.1  to  3.1 
billion EUR 

88 

the  elaboration  of  the  journeys  and  the 
sources used are detailed in Annex 4. 

By  reducing  the  difficulty  and  the  time 
cost  for  service  providers  to  check  the 
different  national  disability  cards,  the 
EDC would increase efficiency also on the 
side of service providers. . 
Option  A2 entails enhanced provision  of 
information to persons with disabilities on 
the types of preferential conditions offered 
to  them,    via    as  the  set  up  of  national 
websites and the use of awareness raising 
campaigns  (foreseen  as  non-legislative 
flanking  measures)  The 
increased 
awareness  on  the  preferential  conditions 
available  and  on  the  benefits  offered  by 
the EDC would improve efficiency in the 
tourism  of  persons  with 
sector  of 
disabilities, by allowing them to plan short 
term stays with more information at their 
disposal. 

The increased participation in tourism of 
persons  with  disabilities  resulting  from 
option  A2  would  have  positive  indirect 
benefits  in  the  market  for  accessible 
turnover  would 
tourism,  whose 
total 
increase  as  a  result  of 
the  policy. 
Estimates of the total output of this sector 
in  2012  put  the  total  value  added  of  the 
sector  to  the  EU  economy  at  about  62 
bllion  EUR  in  2012,  with  an  indirect 
multiplier  of  1.84.  Considering 
the 
presence of a travel gap, i.e. a difference 
in 
the 
travelling  propensity  between 
general  population  and  persons  with 
disability,  estimated  at  around  6%  in  the 
EU, a complete closure of the gap, which 
would imply 2 million more persons with 
disabilities  travelling  in  the  EU,  would 
entail  an  increase  of  the  estimates  range 
from 2.1 to 3.1 billion EUR. This can be 
used as an upper bound: the actual gain is 
likely to be at a level significantly below 
this  threshold,  as  uncertainty  regarding 
preferential  conditions  is  not  the  only 
driver  of  the  travel  gap  between  persons 

 
 
 
Other non-monetary benefits 
– Protection of fundamental 
rights 

n.a. 

in 

the 

the 

and 

general 

integration 

disabilities 

with 
population186. 
Freedom  of  movement:  the  removal  of 
barriers  linked  to  the  lack  of  mutual 
recognition  of  disability  status  across 
Member States would encourage persons 
with disabilities to travel, facilitating free 
movement. 
Integration of persons with disabilities: 
increased  participation 
tourism  of 
persons with disabilities would contribute 
in 
to  ensuring  a  deeper 
European society. 
Non-discrimination: 
removal  of 
uncertainty surrounding the recognition of 
disability  status  abroad  and  subsequent 
access  to  preferential  conditions  would 
help  ensure  equal  access  to  services  for 
persons  with  disabilities  and  avoid  any 
potential  for  discrimination  due  to  only 
nationals  being  able  to  access  these 
conditions in their Member State. 
Respects  of  elderly  rights  (art.  25 
ECFR): the certainty of having access to 
preferential conditions when using certain 
the 
services  abroad  would  facilitate 
travelling of the elderlies across the EU as 
they  will  be  granted  with  the  same 
assistance  and  support  provided 
to 
elderlies  with  disabilities  in  the  host 
Member States 
Access  to  service  of  general  economic 
interest  (art.  36  ECFR):  the  mandatory 
provisions  of  preferential  conditions  for 
using  certain  services  abroad  would 
contribute 
and 
territorial  cohesion  of  the  Union  as  EU 
citizens  with  disabilities  would  be 
incentivised  to  travel  across  the  Member 
States 
Freedom to conduct a business (art. 16 
ECFR):  in  accordance  with  Union  law 
and national laws and practices: the EDC 

towards 

social 

the 

186 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. Estimates on the economic contribution of accessible tourism 
to the EU economy are included in Section 6 of the report. 

89 

 
 
 
 
would  not  oblige  service  providers  not 
offering  any  preferential  conditions  to 
persons with disabilities to do that, hence 
the  freedom  to  conduct  a  business  as 
established by Article 16 is recognised. 

Source: Study supporting the impact assessment 

Table 3 – Overview of costs – Preferred option A2 

Description 

Amount 

Stakeholders 

Comment 

Activity 

Type of cost  One-off 

Recurrent 

Production 
and  delivery 
of EDCs 

Direct 
adjustment 
costs 

n.a. 

Between 
EUR  1  and 
EUR  5  per 
Card.  Cost 
are likely to 
decrease  as 
production 
is scaled up 

Administrations  The 

costs 

of 
production 
and 
delivery  can  be 
estimated based on 
those  incurred  by 
Member 
States 
participating in the 
project.187 
pilot 
These  costs  are 
included  here  as 
fixed  costs,  but 
they  are  likely  to 
significantly 
decrease 
once 
is 
production 
scaled  up  as  the 
number  of  EDCs 
increases. 

Establishme
nt  of  an  IT 
system 
for 
digital 
the 
EDC 

Maintenanc
e  of  an  IT 
system 
for 
the 
digital 
EDC 

1.67 
million 
EUR 
for 
the  whole 
EU 

n.a. 

n.a. 

Public 
authorities 

Public 
authorities 

249,757 
per 
EUR 
year for the 
whole EU 

Provision  of 
preferential 
conditions 

Direct 
adjustment 
cost 

n.a. 

Service 
providers 

In 
transport 

the 

The  majority  of 
respondents  in  the 
targeted survey on 

187 European Commission, Directorate-General for Employment, Social Affairs and Inclusion, Chiattelli, C., Abbasciano, 
C., Schizzerotto, A., et al., (2021), Study assessing the implementation of the pilot action on the EU Disability Card and 
associated benefits: final report. Table 30. Available at: link. Data on costs in the study on the Pilot action were obtained 
following desk research and consultation with the DCNOs. 

90 

 
 
 
 
 
 
 
 
 
 
 
Description 

persons 

Activity 
to 
with 
disabilities 
from  other 
Member 
States 

Amount 

Stakeholders 

Comment 

Type of cost  One-off 

range 

Recurrent 
sector,    the 
total  yearly 
costs in  the 
transport 
sector  are 
estimated 
to 
between 
and 
116 
161 million 
EUR, 
accounting 
only 
for 
to 
0.05% 
0.08% 
of 
the 
turnover  of 
(non-air) 
passenger 
transport 

costs  for  service 
providers  reported 
a  small  cost  of 
offering 
preferential 
conditions. 
Moreover,  service 
providers 
that 
indicated 
with 
persons 
from 
disabilities 
other 
Member 
States  represent  a 
very small portion 
of 
client 
base188 

their 

For  the  transport 
sector,  where  the 
significant 
most 
preferential 
conditions 
are 
found  and  being 
closely  related  to 
short  term  stays, 
costs are estimated 
as  having  to  offer 
preferential 
conditions  to  the 
44%  of  PwD  who 
has  reported  ever 
being 
denied 
preferential 
conditions  when 
travelling  abroad. 
The  actual  costs 
are likely closer to 
the  lower  bound, 

188 Study supporting the impact assessment based on Survey on costs targeted at service providers, Q8 – Can you please 
estimate, on a monthly basis on average, what share of your customers is represented by customers with disabilities from 
other EU Member States, travelling for short-term stays (less than 3 months)? Q38 - In a month, can you estimate the 
average cost per person of offering preferential conditions to customers with disabilities? Please consider costs of offering 
discounted prices (which would be equivalent to the average amount of the discount), personalised services (e.g. guided 
tours, personal assistance, priority lines) and any other costs which you incur for each customer with disabilities). 

91 

 
 
 
 
 
 
 
Description 

Amount 

Stakeholders 

Comment 

Activity 

Type of cost  One-off 

Recurrent 

due to  the overlap 
the  elderly 
with 
population. 

Collecting 
on 
information 
service  providers 
and  number  of 
cards. 
Costs of providing 
information 
to 
service providers. 

Source: Study supporting the impact assessment 

Summary of costs and benefits of policy option B2 

Table 4 – Overview of Benefits (total for all provisions) – Preferred Option B2 

Description 

Amount 

Comments 

Direct benefits 

Improved 
– 
welfare 
Increase 
in 
societal welfare 
due to enhanced 
participation  in 
tourism 
of 
persons  with 
disabilities 

Reduction  of 
travel  gap  for 
Persons  with 
disabilities 
between  0.27 
0.4 
and 
percentage 
points 

 Starting  from 
4 EUR per day 
189 

Improved 
market 
efficiency 
– 
Cost savings for 
persons  with 
disabilities 
travelling 

The reduced uncertainty regarding the full recognition of EU 
parking  cards  for  cardholders  travelling  to  other  Member 
States,  resulting  from  option  B2,  is  expected  to  lead  to  an 
increase in the number of persons with disabilities travelling in 
the  EU.  While  the  exact  increase  cannot  be  quantified,  it  is 
likely to be small as parking card holders are a portion of the 
total population of persons with disabilities, and travelling by 
car is one of the possible means of transport used by persons 
participating in tourism. Nevertheless, increased participation 
in  tourism  would  have  positive  consequences  in  terms  of 
increased  personal  development,  social  inclusion  and  culture 
for the cardholders involved. 

Option B2 would increase certainty regarding the recognition 
of  EU  parking  cards  for  persons  with  disabilities  travelling 
abroad.  As  a  consequence,  cardholders  who  may  have 
previously sought for different parking solutions, for fear their 
parking card may not be recognised, would now be more likely 
to  rely  on  parking  slots  reserved  to  them.  These  potential 
savings are quantified based on the average cost of parking in 
the  European  Parking 
the  EU,  estimated 

in  2013  by 

189  European  Parking  Association  (EPA,  2013),  The  Scope  of  Parking  in  Europe.  Available  at:  link.  The  aggregate 
estimates provided refer to the following set of countries: AT, BE, HR, DK. EE, FI, FR, DE, HU, IE, IT, LU. NL, NO, 
PL, RS, SK, ES, SE, CH, UK. 

92 

 
 
 
 
 
 
 
 
 
 
 
 
Association. The average cost of parking spots for the general 
public  use  was  instead  estimated  at  EUR  800  per  space,  per 
year. Adjusted per inflation and per day (instead of per year), 
this  cost  is  estimated  to  be  roughly  4  euro  per  day,  which  is 
certainly  a  lower  bound  as  shorter  periods  tend  to  be  more 
expensive.  Other  estimates  calculating  the  average  price  of 
parking  in  32  European  cities  have  put  the  number  at  about 
EUR 3 per hour. 

– 

Improved 
market 
efficiency 
Improved 
information  on 
parking 
the 
rights 
of 
cardholders 

Savings can be 
quantified  as 
generally 
below  EUR 
300  in  terms 
of 
avoided 
parking  fines 
across 
the 
EU190 

Option B2 entails enhanced provision of information on how 
the  EU  parking  card  works  and  the  scope  of  the  rights 
associated with the EU parking card. Increased knowledge on 
these  aspects  may  reduce  improper  use  of  the  Card  and, 
subsequently,  fines  (in  SOLVIT,  several  complaints  on  the 
parking  card  concerned  fines  received  by  cardholders  who 
believed that the rights granted by the EU parking card when 
travelling  to  other  Member  States  were  the  same  as  those 
granted in their country of origin). 

Indirect benefits 

Wider 
macroeconomic 
benefits 
– 
Benefits  in  the 
for 
market 
accessible 
tourism 

non-

– 
of 

Other 
monetary 
benefits 
Protection 
fundamental 
rights 

Value  added 
in  the  market 
for  accessible 
tourism: range 
0.2 
from 
billion EUR to 
0.3 
billion 
EUR 

n.a. 

Similarly to policy option A2, option B2 is expected to have 
indirect impacts on the market for tourism through an increased 
number  of  persons  with  disabilities  travelling.  The  total 
magnitude of this indirect impact is, however, expected to be 
small due to the smaller number of cardholders compared to the 
wider population of persons with disabilities. 

Freedom of movement: the removal of barriers linked to the 
lack of mutual recognition of EU parking cards across 
Member States would encourage persons with disabilities to 
travel, facilitating free movement. 
Integration of persons with disabilities: increased 
participation in tourism of persons with disabilities would 
contribute to ensuring a deeper integration in European 
society. 
Non-discrimination: the removal of uncertainty surrounding 
the recognition of EU parking card would help ensure equal 
access to services for persons with disabilities and avoid any 
potential for discrimination due to only nationals being able to 
access these conditions. 

Source: Study supporting the impact assessment 

190 Fine range between EUR 60 and 300 in Spain, EUR 40 and 80 in Greece, EUR 30 and 250 in Portugal and EUR 36 
and 144 in Italy. In Germany, the violation of parking rules can result in fines ranging from EUR 35 to EUR 110 (estimated 
by a large provider of car rental services). 

93 

 
 
 
 
 
Table 5 – Overview of costs – Preferred option B2 

Description 

Amount 

Stakeholders 

Comment 

Activity 

Type of cost  One-off 

Recurrent 

Update 
security 
features 

of 

Direct 
adjustment 
costs 

n.a. 

Negligible  Administrations  These 

for 

costs 
include  the  costs 
updating 
of 
features 
security 
only 
the 
Member 
States 
who  have  not  yet 
done so and would 
to  comply 
have 
with 
new 
the 
legislation. 

Direct 
adjustment 
costs 

Direct 
adjustment 
costs 

of 

Set-up 
national 
database  of 
cardholders 

of 

Set-up 
websites 
with 
information 
on 
the 
parking card 

n.a. 

Negligible  Administrations 

 Negligible 

 Negligible 

Administrations  As Member States 
already  have  an 
EU  parking  card 
website,  the  only 
costs 
are 
associated  with 
updating 
the 
information 

Source: Study supporting the impact assessment  

Relevant Sustainable Development Goals 

Table 6 – Overview of relevant Sustainable Development Goals10 – Preferred Option 

Relevant SDG 

Goal  8  –  Decent  work 
and  economic  growth. 
Target  8.9:  devise  and 
implement  policies  to 
sustainable 
promote 
tourism 
that  creates 
jobs and promotes local 
culture and products. 

Expected  progress  towards  the 
Goal 
Both policy options A2 and B2 are 
expected to bring about an increase 
in  tourism  participation  of  persons 
with disabilities, through a reduction 
in the travel gap between the general 
population 
persons  with 
disabilities.  As  a  consequence,  the 
travel  propensity  of  persons  with 
disabilities can be expected to range 
between  70  and  75%  by  2030  as  a 
result  of  the  measures.  This  would 

and 

Comments 

The  evolution  of  travel  patterns 
over  the  next  10-15  years  is 
increasing 
given 
uncertain 
pressure to  deal  with  the climate 
emergency. In any case, the travel 
propensity  of  persons  with 
to 
disability 
diverge  from  that  of  the  general 
population 
(which  has  been 
growing  over  the  past  10  years) 
and  the  both  policy  options  A2 

is  not  expected 

94 

 
 
 
 
 
 
 
 
 
also  have  a  positive  impact  on  the 
total  turnover  of  the  market  for 
accessible tourism. 

Goal  10  –  Reduced 
inequality. Target 10.2: 
empower  and  promote 
the  social,  economic 
and  political  inclusion 
of  all,  irrespective  of 
age, 
sex,  disability, 
race,  ethnicity,  origin, 
religion or economic or 
status.  Target 
other 
equal 
ensure 
10.3: 
opportunity  and  reduce 
inequalities of outcome, 
including 
by 
eliminating 
discriminatory 
laws, 
policies  and  practices 
and 
promoting 
appropriate  legislation, 
policies  and  action  in 
this regard. 

Goal  11  –  Sustainable 
cities and communities. 
Target  11.2:  provide 
access 
safe, 
to 
affordable,  accessible 
and 
sustainable 
transport  systems  for 
road 
improving 
all, 
by 
notably 
safety, 

disabilities 

their  participation 

Policy  option  A2  would  encourage 
the social and economic inclusion of 
by 
persons  with 
improving 
in 
tourism  across  the  EU.  On  the  one 
hand, 
the  policy  option  would 
consist  in  direct  monetary  savings 
for  persons  with  disability,  which 
would  reduce 
their  costs  when 
travelling  to  other  member  states. 
This 
reduce 
expected 
inequality, as persons with disability 
are overly represented in the lowest 
the 
income  brackets.  Moreover, 
reduction in uncertainty is expected 
to  further  increase  their  economic 
and social integration, as uncertainty 
can  be  a  driver  of  poor  economic 
decisions.  

to 

is 

persons  with 

the  provision  of 
By  ensuring 
preferential  conditions  in  internal 
market services, including transport, 
for 
disabilities 
travelling  to  other  Member  States 
for  short-term  stays,  option  A2 
would  contribute 
improving 
access  to  affordable  transport  for 
this  group  of  citizens.  Access  to 

to 

95 

service 

providers, 

regardless  of 

and B2 are expected to help close 
the  travel  gap  with  the  general 
population 
the 
overall trend. 
The  option  would  achieve  this 
progress by removing some of the 
financial  barriers  discouraging 
persons  with  disabilities  from 
reducing 
(by 
travelling 
uncertainty 
the 
regarding 
provision 
preferential 
of 
conditions, many of which are of 
a  financial  nature),  in  a  context 
where  persons  with  disabilities 
have  reported  that  their  decision 
not to travel is deeply influenced 
by  financial  concerns11.  Part  of 
the cost of this measure would fall 
in 
onto 
particular  in  those  sectors  where 
preferential conditions to persons 
with  disability  are  more  present 
(e.g.,  transport,  culture,  leisure). 
However, 
are 
these 
estimated to relatively minor, as: 
i)  persons  with  disability  are  a 
relatively  small  share  of 
the 
population  and  with  lower  travel 
propensity,  ii)  many  (e.g.,  the 
elderly) already enjoy preferential 
conditions even if their disability 
card is not recognised, iii) the cost 
for  service  providers  is  expected 
to  partly  offset  by  paying 
customers travelling with persons 
with disability and by the savings 
in terms of time/human resources 
in  having  to  check  the  different 
national cards. 
An  estimate  of  the  costs  for 
transport  service  providers  are 
outlined in the report in Annex 4. 
The  costs  are  expected  to  vary 
across  countries,  and  estimate 
range from a few million to more 
than  100  million  EUR  for  some 
countries.  The  uncertainty  in  the 
actual value is due to absence of 

costs 

 
 
 
public 
expanding 
transport,  with  special 
attention to the needs of 
those 
in  vulnerable 
women, 
situations, 
children,  persons  with 
disabilities  and  older 
person.  

Goal  6  – Peace, justice 
and  strong  institutions. 
Target  16b:  promote 
and 
non-
enforce 
discriminatory laws and 
policies  for  sustainable 
development. 

easier 

access 

affordable  and  accessible  transport 
would also be improved by the full 
recognition  of  national  parking 
cards  for  cardholders 
travelling 
abroad  by  car,  a  consequence  of 
policy option B2. 
to 
By 
giving 
in  public 
preferential  conditions 
transport,  policy  option  A2  would 
also  partly  redirect  some  travel 
towards  more  sustainable  means  of 
transportation. 
Option  A2  would 
the 
potential  discrimination  associated 
preferential 
to 
conditions only to national residents 
with  disabilities,  by  mandating 
service 
offering 
providers 
preferential conditions in the EU to 
also  offer  them  to  persons  with 
disabilities 
from  other  Member 
States. 

remove 

offer 

the 

of 

from 

data on the proportion of persons 
with  disability  who  currently 
benefit 
preferential 
conditions.  As  explained  above, 
these  costs  are  expected  to  be 
partly  offset  by  a  higher  number 
of paying customers and by time 
savings in checking the cards. 

The  policy  option  would  also 
allow to monitor more easily the 
enforcement  than  the  status  quo, 
where it is difficult to keep track 
of  what  preferential  conditions 
are  offered  to  travelling  persons 
with disabilities. 

Source: Study supporting the impact assessment  

SMEs test 

(1) Identification of affected businesses 

Table 7 – SMEs test 

See  Annex  6  for  a 
services 
mapping  of 
providing 
preferential 
conditions in the EU 

The initiative targets all service providers (public and private firms) 
offering  preferential  conditions  to  persons  with  disabilities,  in  all 
internal market services, covered by the preferred option A2 and the 
parking sector covered by the preferred option B2.  
While  SMEs  are  represented  in  these  categories,  they  are  not 
specifically targeted by the initiative. SMEs are likely to be over-
represented in some sectors in scope (e.g. leisure, culture, tourism 
services) than in others, where preferential conditions are provided 
primarily by large public providers (as in the transport sector). The 
precise share of SMEs is not possible to asses given the fact that 
systematic data is not collected by the Member States regarding the 
offer of preferential conditions. While in some sectors preferential 
conditions  are  mandated  by  law,  in  most  they  are  the  voluntary 
decision of service providers. 
SMEs  are  going  to  be  impacted  directly  and  indirectly  by  the 
initiative, generating several benefits and some costs. Costs are not 
expected to be proportionally more substantial than for large firms.     

(2) Consultation of SME stakeholders 

96 

 
 
 
SME's  representatives  have  been  consulted  in  several  of  the  data 
collection conducted as part of the Study.  
17 of the 23 service providers who responded to the targeted survey 
focused on costs are SMEs – 7 Micro, 5 Small, and 5 Medium. 15 
of  them  offer  preferential  conditions  to  persons  with  disabilities 
from other Member States, the vast majority on a voluntary basis. 
There  was  a  consensus  on  the  fact  that  extending  preferential 
conditions  to  persons  with  disabilities  from  other  Member  States 
did  not  result  on  an  on  overall  negative  impact  (benefits  minus 
costs),  expressed  by  both  SMEs  and  large  service  providers.12 
Actually, almost half of experienced positive returns from it.  
Likewise,  there  were  several  SMEs  and  two  representatives  of 
Business  Europe  among  the  participants  in  the  workshop13 
conducted with service providers. The findings of the survey were 
confirmed  during  the  workshop.  The  initiative  is  expected  to 
simplify the process of verifying proofs of disability and as a result 
bring cost savings. 

(3) Assessment of the impact on SMEs 

SMEs  may  experience  some  positive  returns  deriving  from  the 
small  positive  economic  impacts  of  the  policy  in  the  field  of 
accessible  tourism  given  that  many  SMEs  operate  in  the  tourism 
sector.  According  to  the  World  Tourism  Organisation,  the  wide 
majority of accommodation establishment in the EU tourism sector 
in 2016 were in the hands of SMEs.14  
Furthermore,  as  clearly  evidence  by  the  survey,  SMEs  and  large 
firms  alike  experienced  or  expect  that  the  benefits  of  providing 
preferential  conditions  to  persons  with  disabilities  from  other 
Member States to at a minimum offset fully the small increase in 
costs (e.g. cost of service, training personnel, administrative costs, 
reporting costs etc.). Persons with disabilities travelling from other 
Member  States  were  estimated  to  be  a  very  small  share  of  their 
overall customers (the modal response being less than 1%) 

(4) Minimising negative impacts on SMEs 

of 

See  Annex  2  for  the 
description 
the 
stakeholders  contacted, 
methodology and results 
of 
consultations 
methods 

See  chapter  6  on  the 
economic 
expected 
impacts  of  the  retained 
and 
policy 
chapter 
the 
the 
efficiency 
retained  policy  options 
and  chapter  8  on  the 
the 
description 
preferred policy options 

options; 
on 
of 

of 

7 

SME competitiveness is not expected to be significantly impacted relative to other business.  

Source: Study supporting the impact assessment  

ANNEX 4: ANALYTICAL METHODS 

Introduction 

97 

 
 
 
 
 
 
The assessment of the policy options requires the choice of analytical methods to evaluate the effects 
of each policy option (in relation to the specific objectives identified) and their general impacts. In 
this  context,  a  Multi-Criteria  Decision  Analysis  is  applied  to  assess  the  different  policy  options 
(including the baseline, policy options EDC: A1 and A2, and policy options PARK: B1 and B2). The 
method is described in detail in the next sub-sections. 

Annex 4 outlines the analytical methods that have been used as part of the impact assessment.  

The Multi Criteria Decision Analysis (MCDA), Tool #62 of the BRT. The Multi-Criteria Decision 
Analysis (MCDA) is a tool for the qualitative analysis and comparison of a complex set of alternatives 
concerning the extent to which various measures achieve their objectives, are efficient, coherent etc. 
The  MCDA  is  based  on  qualitative  ratings  and  rankings  with  quantitative  data  supporting  the 
assessment. 

• 

the Cost-Effectiveness Analysis (CEA). The CEA draws upon monetised data on costs (e.g. 
in EUR) and compares them with quantitative or qualitative information on benefits. It is used 
in case monetised information on benefits is not available or ambiguous, if monetisation is 
not reasonably possible or the nature of benefits is qualitative by definition (e.g. perceptions 
or attitudes). It is used to decide upon resource allocations between different measures. The 
information that feeds into the CEA is:  

o  Individual travelers’ journeys: these are obtained by estimating fictious journeys of 4 
days or 2 months in selected destinations, and researching what are the preferential 
conditions available to PwD (whether travelling with or without personals assistants). 
These are then aggregated up to potential savings per day and over the trip.    

o  Calculation of the travel gap: outlines how the travel gap for person with disability 
with respect to the general population is calculated, by using data from the report for 
DG  Grow.  This  is  the  only  data  that  allows  to  calculate  travel  propensity  for  the 
relevant population, although some assumptions are required, as outlined in the annex. 

o  Detailed  assessment  of  costs  for  the  transport  sector:  detailed  data  on  preferential 
conditions in the transport sector is obtained for 10 countries, and a lower and upper 
bound of the costs of offering preferential conditions to persons with disability from 
other Member States is obtained. The lower bound is estimated assuming all persons 
with disability already travelling already benefit from preferential conditions. On the 
contrary, the upper bound is obtained assuming no preferential conditions are offered 
to non-residents from other member states.  

•  Final ranking matrix. In this matrix, the sums of the weights for all criteria in relation to which 
a given policy option performs better than other policy options are indicated. As the preferred 
policy  options  always  dominate  the  other  across  all  dimensions  (they  are  either  equal  or 
superior), no weighting scheme is discussed as this would lead to the same preferred policy 
options. 

Multi-Criteria Decision Analysis (MCDA) 

The Multi-Criteria Decision Analysis (MCDA) is a tool for the qualitative analysis and comparison 
of  a  complex  set  of  alternatives  concerning  the  extent  to  which  various  measures  achieve  their 

98 

 
 
 
objectives, are efficient, coherent etc. The MCDA is based on qualitative ratings and rankings with 
quantitative data supporting the assessment.  

Clearly, for the MCDA to take place efficiently, the policy alternatives need to be sufficiently detailed 
(e.g. including comprehensive sub-options) and understood in order to have a comprehensive view 
for the assessment in relation to the evaluation criteria. The listing and description of such policy 
options is carried out in Section 6 of the Final report. Furthermore, the assessment vis-à-vis the criteria 
needs to be sufficiently detailed in order to provide distinct ratings for each of the elements of the 
alternative measures. 

The  MCDA  is  a  qualitative  tool,  and  thus  always  subject  to  scrutiny  concerning  the  implicit  and 
explicit judgments made during the assessment process. Therefore, it is crucial for the application of 
the MCDA to be transparent about the data used and the sources, as well as how specific data have 
fed into and shaped the analysis. In the Final report, the assumptions made to provide a certain rating 
and the data sources employed are always made clear and referenced. 

Each policy option is analysed and scored relative to the baseline scenario against the assessment 
criteria provided in Table 1 below. The baseline scenario is, by definition, rated with “0” in relation 
to each of the criteria. The other policy options, on the other hand, are scored on a scale from 1 to 3 
in terms of their positive impacts, where 1 represents a very small positive impact and 3 a very large 
positive impact compared to the baseline. In the same vein, -1 represents a very small negative impact 
and -3 a very large negative impact, again using the baseline as a benchmark. A score of “0” means 
that the option would not constitute a significant deviation from the baseline scenario, with which it 
would share the impacts. The scores help distinguish the relative strengths of the option in light of 
the different criteria considered. In the main report, in the Tables of chapter 7, such scores are always 
accompanied by a detailed assessment of the rationale behind the rating assigned, and a breakdown 
of  the  different  types  of  effects  and  impacts,  each  with  its  own  magnitude.  Table  1  below  is  an 
illustrative assessment table, which was used as a model for the MCDA. 

Table 1 – Illustrative assessment table for the Policy Options 

Rate 

Summary of assessment 

Criteria 
Evaluation of effects 
Effectiveness 

0/3 

Efficiency 

0/3 

Necessity  

0/3 

Coherence  

0/3 

Subsidiarity  and 
proportionality 
Types of impacts 

0/3 

Description of the extent to which the policy option can be expected 
to achieve the identified policy objectives 
Description of the costs of the initiative and its ability to efficiently 
mobilise  resources  for  the  achievement  of  the  identified  policy 
objectives 
Description  of  the  extent  to  which  the  policy  option  is  necessary, 
given the existing problems and their likely evolution in the baseline 
scenario 
Consistency  assessment  of  the  provisions  proposed  by  the  policy 
option with objectives of the intervention and EU objectives in other 
relevant policy areas 
Description of whether the policy option is appropriate and does not 
go beyond what is necessary to address the problem satisfactorily 

99 

 
 
 
Social impacts 

0/3 

Economic 
impacts 

0/3 

Digital impacts 

0/3 

to  cooperate, 

Description of the likely social impacts. These may include changes 
in relation to: 
Impact  on  the  mobility  of  persons  with  disabilities  and  their 
assistants across the EU both on the extensive margin (increase in 
the  number  of  people  who  travel)  and  the  intensive  margin  (the 
frequency of travels, change in the choice of destination countries); 
Participation in cultural, leisure and sports manifestations and access 
to  such  resources  of  persons  with  disabilities  and  their  assistants, 
especially across the EU; 
Cross-border provision of services; 
Member  States  competent  authorities'  ability 
coordinate and exchange good practices;  
Communication  and  collaboration  with  civil  society  organisations 
and with service providers offering benefits and special conditions 
and available benefits to other Member States;  
Service providers’ cross-country communication and collaboration: 
share good practice relating to disability, joints services etc. 
Description  of  the  likely  economic  impacts.  These  may  include 
changes in relation to: 
Functioning of the internal market; 
Non-discriminatory cross-border provision and access to goods and 
services; 
Administrative  burden  on  businesses,  especially  SMEs,  including 
simplification potentials; 
Changes in revenues for services providers, in particular revenues 
from  changes  in  the  number  of  users  paying  for  their  goods  and 
services  (especially  for  what  concerns  potential  disproportionate 
impacts on SMEs); 
Changes in prices of goods and services (e.g. increases in prices in 
response to higher costs of offering free or discounted services to 
Cardholders); 
Changes  in  purchasing  power  of  Cardholders  given  that  they 
experience a reduction in their costs of travelling across the EU; 
Administrative  costs  on  public  authorities,  possible  need  of 
restructuring  or  create  of  new  public  authorities  dedicated  to  the 
Cards, including also costs to prevent fraudulent use of the Card. 
Description of the likely digital impacts. These may include changes 
in relation to: 
Digitalisation of the EU Parking Card (from paper format to digital 
formats as SIMON) that may influence the recognition of benefits; 
the monitoring of the use of the card at national and EU level, Card 
take-up by removing the need to request a new Card upon expiration, 
fraudulent use of the Card;  
Mobile  applications  and  websites  dedicated  to  the  Card  and  its 
benefits;  

100 

 
 
 
Digitalisation  of  national  registries  on  persons  with  disabilities: 
application, security, maintenance and updating of databases;  
Digital  skills  of  persons  with  disabilities  (e.g.  developing  better 
digital  skills  may  facilitate  being  informed  on  the  availability  of 
benefits both at national and EU level);  
Digitalisation  of  benefits  provided  by  service  providers  (e.g. 
common  EU  platform  where  the  list  of  service  providers  and 
available benefits can be consulted);  
Accessibility regarding the use of the card for age classes and social 
backgrounds,  depending  on  digital  skills/availability  of  digital 
devices. 
Description of the likely environmental impacts. These may include 
changes in relation to: 
Mobility (of both persons with disabilities, personal assistants and 
accompanying persons such as family and friends);  
Share of transport through public or private transport;  
Increase  in  the  use  of  transport  of  persons  with  disabilities,  both 
personal vehicles (especially in response to the Parking Card) and 
other means for travel across the EU. 
Description of the likely impacts on fundamental rights. These may 
include changes in relation to: 
Personal integrity and privacy;  
Equal opportunities;  
Data protection;  
Participation in culture;  
Environmental and consumer protection;  
Good administration;  
Human dignity;  
Non-discrimination;  
Integration of persons with disabilities;  
Freedom of movement. 
Description  of  the  likely  impacts  on  competitiveness  and  SMEs. 
These may include changes in competitiveness in the internal market 
or any disparate impact of the policy options on SMEs. 

Environmental  

0/3 

Fundamental 
rights 

0/3 

Competitiveness 
and SMEs 

0/3 

Source: Study supporting the impact assessment 

Cost-Effectiveness Analysis (CEA) 

The efficiency of the policy options considered, i.e. the evaluation and comparison of the costs and 
benefits of each measure, was not carried out through a standard Cost-Benefit Analysis (CBA). Many 
of the benefits of the policy options would indeed be complex to monetise, and monetisation itself 
would often require unrealistic assumptions. In such cases, in line with the Better regulation Toolbox, 
a different type of efficiency evaluation is more appropriate: the Cost-Effectiveness Analysis (CEA). 
The CEA draws upon monetised data on costs (e.g. in EUR) and compares them with quantitative or 

101 

 
 
 
qualitative  information  on  benefits.  It  is  used  in  case  monetised  information  on  benefits  is  not 
available  or  ambiguous,  if  monetisation  is  not  reasonably  possible  or  the  nature  of  benefits  is 
qualitative by definition (e.g. perceptions or attitudes). It is used to decide upon resource allocations 
between different measures.  

The  CEA  draws  upon  monetised  information  concerning  costs,  as  well  as  quantitative  and/or 
qualitative  information  on  benefits,  e.g.  the  extent  to  which  a  given  policy  option  effectively  and 
efficiently is  expected to achieve the policy objectives. The CEA typically uses both primary and 
secondary data. Depending on the subject matter, all three types of information listed above can be 
primary and/or secondary data. 

Regarding information on costs of the policy option, in some cases the absence of readily available 
data on costs was remedied through a stakeholders consultation strategy (explained in detail in Annex 
2) and the application of some assumptions. To identify cost savings for persons with disabilities of 
policy  option  A2,  the  Study  Team  elaborated  case  studies  of  individual  persons  with  disabilities 
travelling in the EU and facing different costs in the case of the baseline and in the presence of a 
European Disability Card. 

Individual travellers journeys to identify cost savings 

In  the  context  of  policy  option  A2,  the  mutual  recognition  of  disability  status  for  persons  with 
disabilities travelling for short-term stays would effectively reduce uncertainty regarding the offer of 
preferential conditions. These would result in cost savings for persons with disabilities travelling to 
other Member States, allowing them to enjoy preferential conditions on an equal basis with respect 
to national residents. To quantify this important information, the Study Team estimated the possible 
savings potential for persons with disabilities under different travel scenarios. The scenarios involved 
hypothetical journeys in three different countries (specifically, two large capital cities in Ireland and 
Hungary, one medium-sized city in Italy), for two different lengths (4 days or 2 months). The choice 
of Member States was based on the provision of preferential conditions analysed in Table 5 of Section 
3.2.2 of the Final Report so as to be representative, with one country providing several preferential 
conditions  across  sectors,  one  providing  an  average  amount  of  preferential  conditions  and  one 
providing only few preferential conditions. For short- term stays, the presence or not of a personal 
assistant  was  also  evaluated.  This  makes  for  a  total  of  9  estimated  travel  journeys  (and  potential 
savings for persons with disabilities). While the results of the estimation exercise are to be considered 
as  suggestive  of  the  potential  cost  savings  for  persons  with  disabilities,  they  do  offer  a  practical 
example with the potential to highlight the important savings that this category of stakeholders would 
have as a result of the policy. Table 2 maps the different travellers journeys analysed. 

Table 2– Types of Travel Journeys Estimated  

Type  of  Travel 
Journey 

Country 

Large Capital City 

Ireland (many preferential 
conditions) 

Short Term (4 Days)   Medium  Term 

(2 

4  days  trip  to  Dublin 
without 
personal 
assistant 

Months) 
2  months 
Dublin 
personal assistant 

stay 
in 
without 

4  days  trip  to  Dublin 
with personal assistant  

102 

 
 
 
 
 
Large Capital City 

Hungary (few preferential 
conditions) 

Medium Size City 

Italy  (average  amount  of 
preferential conditions) 

Source: Study supporting the impact assessment 

4 days trip to Budapest 
without 
personal 
assistant 

2  months 
Budapest 
personal assistant 

in 
stay 
without 

4 days trip to Budapest 
with personal assistant 

4 days trip to Bergamo 
without 
personal 
assistant 

2  months 
Bergamo 
personal assistant 

stay 
in 
without 

4 days trip to Bergamo 
with personal assistant 

In the estimations, potential savings related to international travel are excluded. The assumption is 
that international travel is mostly purchased in the home country, and, as such, the problem of mutual 
recognition of disability status does not apply. Even if the ticket is purchased with a foreign provider 
operating  nationally,  given  they  operate  in  the  country,  the  assumption  is  that  they  recognise  the 
national disability card for travel to and from that country. If this is not the case, then we would not 
consider some preferential  conditions  that a person with  a disability would  get  access  to  with  the 
EDC, and our savings estimate have to be understood as a lower bound of the actual savings. The 
focus  is  rather  on  the  real,  monetary  savings  for  reduced  tickets/fares  applied  to  persons  with 
disabilities  when  having  already  travelled  in  the  country  of  interest.  Furthermore,  in  the  exercise 
preferential conditions that are non-monetary in nature, such as, for example, a surrogate driver when 
renting a car, are also not considered, while emphasis is given to the direct economic benefits that 
can be estimated and gathered through desk research. If, for a specific service, there appears to be no 
explicit mention of a reduced price/monetary preferential condition for a persons with disabilities, the 
assumption made is of a lack of this kind of preferential conditions. With this in mind, estimates in 
the exercise hinge on the side of caution, and are probably a lower bound of real potential savings 
from preferential conditions for persons with disability. To gauge the magnitude of these savings, we 
also compare these estimates to the average spending of persons with disabilities in 2012 for overnight 
stays (EUR 102 in 2012, EUR 122 adjusted for inflation today)191. Although the two numbers are not 
directly comparable, this  is  the best  estimate available to  which we can compare these savings to 
obtain an idea of how large potential savings are with respect to how much persons with disability 
spend when travelling in the EU.  

The Study supporting the impact assessment estimated travel journeys span three countries: Ireland, 
Italy and Hungary, which differ across preferential conditions, general living standards and cost of 
living, and general touristic attractions. In each country, the estimated travel journey begins and ends 
at the airport (or train station) close to the location of interest. For Ireland and Hungary, we focused 

191 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. 

103 

 
 
 
 
 
 
 
 
 
 
 
our estimation on the capital cities, Dublin and Budapest, while for Italy we focused on a medium 
size city, Bergamo. For short stays, we estimate savings for persons with disabilities over a period of 
4 days, consisting of the following activities: 1 visit to a museum, 1 event at a theatre, 1 event at a 
cinema, 1 day trip by train/ferry, as well as transport to and from restaurants and accommodation. For 
medium term stays of two months, savings for persons with disabilities are estimated over a period 
of 4 days, consisting of the following activities: 5 visits to museums, 1 day trip by train, 1 theatre, 3 
cinema,  1  amusement  park,  as  well  as  transport  to  and  from,  restaurants  and  accommodation. 
Importantly,  for  medium  term  stays,  the  possibility  that  the  individual  traveller  with  disabilities 
becomes a resident, in the legal sense, of the country is excluded. This is important as in some cases, 
e.g. Lombardy in Italy, is an important prerequisite to gain access to preferential rates for local and 
regional transport. 

For each travel scenario, the savings are estimated by summing up the reduced price or tariff for a 
person with disability (and, eventually, his/her personal assistant) for each of the activity described 
above.  For  short-term  stays,  savings  estimates  over  the  whole  staying  period  for  persons  with 
disabilities  that  can  enjoy  full  preferential  conditions  range  from  EUR  31  to  123  in  total,  when 
travelling  alone.  This  increases  to  EUR  78  -  246  when  travelling  with  a  personal  assistant,  and 
summing the benefits for the persons with disabilities and their personal assistants. It is important to 
note that this last estimate relates to the savings if already travelling with a personal assistant, hence 
it does not imply that travelling accompanied by a personal assistant is overall cheaper than traveling 
alone. Per day of travel (4 days), the estimated monetary benefits range from roughly EUR 7 to 30 
per day if traveling alone, or from EUR 20 to 60 per day if travelling with a personal assistant.  

For medium-term stays, savings estimates for persons with disabilities who can enjoy full preferential 
conditions range from EUR 100 to 400. Per day (60 days), the estimated monetary benefits are in the 
range of roughly EUR 2 to 7. Note that the lower benefit per day is partly by construction: a much 
lower concentration of activities (museum, cinemas, events) can be expected over a medium term 
stay rather than a shorter-term stay. This, mechanically, dilutes the benefits over a longer time span. 
Moreover, the transport discount that persons with disabilities usually enjoy is proportionally less 
relevant over a longer period, as monthly tickets are, per day, cheaper than daily tickets.  

Overall,  monetary  benefits  of  preferential  conditions  when  traveling  for  at  least  one  night  appear 
sizeable in all scenarios estimated, and more relevant, in proportion to the cost, for short term stays 
rather than long term stays. In part, this is because direct monetary benefits are concentrated in sectors 
that are strongly related to short-term travel (i.e. transport and museums/events/leisure activities). In 
general, the economic benefits are high across the spectrum of scenarios simulated, although with a 
high degree of variability. Indeed, if compared to the average spending for an overnight stay intra-
EU for a person with disability, estimated around EUR 102 per day in 2012 (and EUR 122 today, 
adjusted for inflation)192, the daily savings from preferential conditions range in percentage from 2 to 
6% of daily spending for medium term stays, and up to 6 to 25% of daily spending for short term 
stays, depending on the country. To provide an additional order of magnitude, for short term stay, the 
smallest estimate for daily economic benefit (EUR 7) is a bit less than average price of an activity 
like cinema, theatre or museum; the upper bound instead, when traveling with a personal assistant, 

192 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. 

104 

 
 
 
 
(EUR  60)  equals  the  price  of  an  important  event  (concert  or  football  match),  or  a  dinner,  or  of 
accommodation in a medium size city not in peak season.  

To conclude, Table 3, Table 4 and Table 5 provide an overview of the different scenarios of individual 
travellers journeys carried out, with the respective sources used for the construction of the journeys. 

105 

 
 
 
Table 3 – Scenario 1 of individual traveller journey (Dublin, Ireland) 

Sector 

Activity 

for 
with 

Savings 
person 
disabilities 
(EUR) 

Savings 
personal 
assistant 
(EUR) 

for 

Notes 

Airport to Dublin  

Dublin to Airport 

Fast track at airport security 

Bus Fare city x 10 

7 

7 

8 

20 

Transport 

Dublin City to Dun Laoghaire 

25 

Dun Laoghaire to  Dublin City  

25 

Car Rental  

0 

Monthly Transport Card 

115-222  per 
month 

Accomodation 

n.a. 

Museum 

Irish Emigration Museum 

0 

0 

7 

7 

8 

20 

25 

25 

0 

0 

19 

106 

Sources 

https://www.dublinexpr
ess.ie/city-to-airport 

Dublin Airport 

Bus Fare Info 

Dublin Bay Cruises 

Dublin Bay Cruises 

No  discount  but  surrogate  driver 
for free 

Enterprise Ireland 

Bus Fare info 

No hotel found explicitly offering 
a  discount 
for  people  with 
disability 

No discount for disabled person, 
but  personal  assistant  enters  for 
free 

Irish 
Museum  

Emigration 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sector 

Activity 

for 
with 

Savings 
person 
disabilities 
(EUR) 

Savings 
personal 
assistant 
(EUR) 

for 

Notes 

National Museum of Ireland 

0 

Aviva Stadium event, accessible 
tickets 

13 

Abbey Theatre  

5 

0 

13 

0 

Fort Lucan 

7-14 

7-14 

Sources 

National  Museum  of 
Ireland 

Aviva Stadium  

The museum is free for all 

Discount is not clearly stated, but 
not  free,  assumption  that  tickets 
are  half  the  price  for  a  25  euros 
event 

Concession  prices  5$  off  on 
standard event (20%) 

https://booking.abbeyth
eatre.ie/ 

free  for  kids  with  disability  and 
accompanying adults 

Fort  Lucan  Outdoor 
Prices 

Lighthouse cinema 

4 

0 

0 

0 

No  mentioned  discount 
for 
personal assistant, reduced ticket 
for persons with disabilities 

No resturant explicitly offering a 
discount 
people  with 
for 
disability found 

https://www.lighthouse
cinema.ie/ 

Amusement 
Park 

Cinema 

Resturants  

Total  savings  for  4-days  stay  (travelling  with 
public transport, 1 museum, 1 theatre, 1 cinema, 1 
day trip by ferry) 

123 

247 

Savings per day 

Total  savings  for  2-months  stay  (travelling  by 
public transport, 5 museums, 1 ferry trip, 2 events, 
1 theatre, 3 cinema, 1 amusement park) 

Savings per day 

31 

423 

7 

62 

107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: Study supporting the impact assessment 

Table 4 – Scenario 2 of individual traveller journey (Bergamo, Italy) 

Sector 

Activity 

Airport to Bergamo 

Bergamo to Airport 

Fast track at airport security 

Transport 

Bus Fare city x 10 

Train to and from lake garda 

Savings 
for 
person  with 
disabilities 
(EUR) 

Savings 
for 
personal 
assistant 
(EUR) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

108 

Notes 

Sources 

No  explicit  mention  of  a 
tariff  for  persons 
preferential 
with  disabilities,  other  than  pets 
can travel for free 

No  explicit  mention  of  a 
preferential 
tariff  for  persons 
with  disabilities,  other  than  pets 
can travel for free 

ATB 
Bergamo 

Trasporti 

ATB 
Bergamo 

Trasporti 

No mention of free fast track for 
persons with disabilities 

Milano 
Airport 

Bergamo 

Trasporti 

ATB 
Bergamo 

No  explicit  mention  of  a 
preferential 
tariff  for  persons 
with  disabilities,  other  than  pets 
can travel for free 

Travel discounts for persons with 
disabilities  are  only  for  legal 
residents  of 
region,  a 
disability  card  per  se  does  not 
appear to be enough 

the 

Regione 
Tariffa Agevolata 

Lombardia 

 
 
 
 
 
Sector 

Activity 

Savings 
for 
person  with 
disabilities 
(EUR) 

Trenitalia  (long/medium  distance 
train) to Verona 

10 

Car Rental  

Monthly Transport Card 

Accomodati
on 

Museum 

Accademia Carrara  

Teatro Donizetti 

Theatre 

Cinema Conca Verde 

0 

0 

3 

8 

0 

Savings 
for 
personal 
assistant 
(EUR) 

40 

0 

0 

10-15 

0 

0 

109 

Notes 

Sources 

20%  discount  or  free  travel  on 
same train for the accompanying 
person  

Trenitalia 

Only residents with disability can 
travel  for  free  throughout  the 
region, by paying a lump sum of 
10 euros per year  

No  hotel  was  found  explicitly 
offering  a  discount  for  people 
with disability 

Persons  with  disabilities  pay  the 
reduced  price, 
the  personal 
assistant enters for free 

Mean  of  the  reduction  with  the 
persons  with  disabilities,  no 
mention of accompanying people 

Only  reduction  for  senior  and 
explicit 
young 
discount 
persons  with 
disabilities 

people, 
for 

no 

Regione 
Tariffa Agevolata 

Lombardia 

Accademia Carrara 

Teatro Donizzetti 

Conca Verde Cinema 

 
 
 
 
 
 
 
 
 
Notes 

Sources 

Gewiss Stadium Atalant 

GardaLand 

Fee  entry  (with  limited  places) 
for  persons  with  disabilities  and 
personal assistants  

Ticket  price  44  euros,  5  euros 
discount 
persons  with 
disabilities  and  extra  5  euro  for 
personal assistants 

for 

restaurant  was 

No 
found 
explicitly offering a discount for 
people with disability 

Sector 

Activity 

Savings 
for 
person  with 
disabilities 
(EUR) 

Gewiss Stadium Atalanta 

30 

Gardaland 

Stadium  

Amusement 
Park 

Restaurants  

5 

0 

Total  savings  for  2-days  stay  (travelling  with 
public transport, 1 museum ,1 theatre, 1 cinema, 1 
day trip by train) 

31 

Savings per day 

Total  savings  for  4-months  stay  (travelling  by 
public transport, 5 museums, 1 day trip by train, 2 
events, 1 theatre, 3 cinema, 1 amusement park) 

Savings per day 

8 

100 

2 

Source: Study supporting the impact assessment 

Savings 
for 
personal 
assistant 
(EUR) 

30 

5 

0 

84 

21 

Table 5 – Scenario 3 of individual traveller journey (Budapest, Hungary) 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sector 

Activity 

Airport fast track 

Transport  

72 h travel card 

Day trip to Visegrad 

6 

15 

10 

Local transport Monthly Pass 

25 per month 

Museum of Fine Arts 

12 

Museums  

Hungarian National Gallery 

12 

The Citadel visegrad 

Amusement  

Palatinus Strand 

0 

0 

Savings 
for 
person  with 
disabilities 
(EUR) 

Savings 
for 
personal 
assistant 
(EUR) 

Notes 

Sources 

Monetary  value  of  skipping  the 
line  (evaluated  as  the  cost  of 
buying the fast track option) 

Free  local  transport  for  persons 
with disability 

Budapest Airport 

Public Transport;  

-90%  discount  on 
transport (not free) 

per 

Monthly Budapest Pass 

regional 

Public Transport 

holding 

Persons with disabilities and one 
attendant 
an 
international  card  (it  is  stated 
that  “national  cards  issued  by 
local 
regulations  cannot  be 
treated”) 

No  explicit  discount  mentioned 
for persons with disability 

No  explicit  discount  mentioned 
for persons with disability  

Museum of Fine Arts 

National 

Hungarian 
Gallery 

The Citadel  

Palatinus Strand 

6 

15 

10 

25 
month 

12 

12 

0 

0 

111 

 
 
 
 
 
Sector 

Activity 

Buda Castle  

Opera House  

Cinema  

Restaurants  

Accomodati
on 

Total  savings  for  2-days  stay  (travelling  with 
public transport, 1 museum ,1 theatre, 1 cinema, 
1 day trip by train) 

45 

Savings per day 

Total  savings  for  4-months  stay  (travelling  by 
public transport, 5 museums, 1 day trip by train, 
1 theatre, 3 cinema, 1 amusement park) 

11 

142 

Savings 
for 
person  with 
disabilities 
(EUR) 

Savings 
for 
personal 
assistant 
(EUR) 

0 

0 

2 

0 

0 

0 

0 

0 

0 

0 

78 

20 

112 

Notes 

Sources 

Buda Castle 

Opera House 

CinemaCity 

No  explicit  discount  mentioned 
for persons with disability, only 
senior people 

No  explicit  discount  mentioned 
for persons with disability, only 
students 

A  discount  for  persons  with 
disability is explicitly mentioned 
(20% 
but  not 
assumed on 10 euros ticket)  

the  amount 

restaurant  was 

No 
found 
explicitly offering a discount for 
persons with disability 

No  hotel  was  found  explicitly 
offering  a  discount  for  persons 
with disability 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sector 

Activity 

Savings 
for 
person  with 
disabilities 
(EUR) 

Savings 
for 
personal 
assistant 
(EUR) 

Notes 

Sources 

Savings per day 

2 

Source: Study supporting the impact assessment 

113 

 
 
 
 
 
 
 
Calculation of the travel gap 

Table 6 provides an explanation regarding the assumptions made and the data sources used to estimate 
the  travel  gap  between  the  total  population  and  persons  with  disabilities,  based  on  available 
information on tourism patterns for this sub-group of the population. The Table also describes the 
data used to estimate the total number of persons with disabilities, which were proxied using Eurostat 
data on “severe” limitations, given that in chapter 2 of the main report this is shown to be a valid 
proxy for the number of persons with recognised disability in each Member State. 

Finally, Table 6 shows how estimates for future years (with a time horizon stretching to 2030) were 
obtained and through which assumptions. In particular, the ranges used in the main apply different 
scenarios of a varying travel gap between the general population and the population of persons with 
disabilities  to  the  estimated  participation  in  tourism  of  the  general  population  in  2030  (estimated 
assuming a constant growth rate in line with the evolution of travel patterns for the general population 
between 2012 and 2030). 

Table 6 – Data at the EU level for the estimation of the travel gap 

Variable 

Year  Amount 

Source 

Eurostat  database,  hlth_silc_12.  Available  at: 
link. 
Eurostat  database,  demo_pjan.  Available  at: 
link. 
The share of persons with “severe” limitations 
(only  available  for  persons  aged  16  or  older) 
from  hlth_silc_12  is  applied  to  the  total 
population aged 16 or older from demo_pjan. 

Directorate-General 

Economic  Impact  and  Travel  Patterns  of 
Accessible  Tourism  in  Europe  -  Full  Report, 
for 
08/03/2015. 
Enterprise  and  Industry,  now  known  as 
Directorate-General 
Internal  Market, 
for 
Industry,  Entrepreneurship  and  SMEs  (DG 
GROW), European Commission. Available at: 
link.  

Eurostat database, tour_dem_toage. Available 
at: link. 
Data are available from 2012 to 2019. 

Persons  with  “severe” 
disabilities 

Persons  with  “severe” 
disabilities 

2012 

30,917,031 

2019 

30,804,805 

participation in tourism of 
persons  with  disabilities 
aged 15-64 

2012 

58.1% 

2012 

64.4% 

2019 

69.1% 

n.a. 

0.7% 

participation in tourism of 
the  total  population  aged 
15-64 

participation in tourism of 
the  total  population  aged 
15-64 

in 
Yearly  growth  rate 
total 
tourism  of 
population  aged  15-64 
between 2012 and 2019 

the 

Travel  gap  between  the 
total population aged 15-

2012 

6.3% 

in 
Difference  between 
tourism of the total population aged 15-64 and 

the  participation 

114 

 
 
 
Variable 
64  and  persons  with 
disabilities aged 15-64 

Participation  in  tourism 
of  the  total  population 
aged 15-64 (estimate) 

Year  Amount 

2030 

74.7% 

2030 

68.3% 

Source 
the  participation  in  tourism  of  persons  with 
disability aged 15-64 

Obtained  applying  to  the  participation  in 
tourism of the total population aged 15-64 in 
2022 (assumed to be the same as in 2019, after 
the  end  of  the  disruptions  caused  by  the 
pandemic) the yearly growth rate of the period 
2012-2019, until 2030. 

Obtained  applying  the  constant  6.3%  travel 
gap of 2012 to the participation in tourism of 
the general population estimated for 2030. 

Participation  in  tourism 
with 
persons 
of 
(estimate, 
disabilities 
scenario 
constant 
travel gap) 

of 

Total  number  of  persons 
disabilities 
with 
(estimate, 
travelling 
constant 
scenario 
travel gap) 

of 

Participation  in  tourism 
of 
with 
persons 
(estimate, 
disabilities 
increasing 
scenario  of 
travel gap) 

2030 

21,053,378  Obtained 

by 

the 

estimated 
applying 
participation  in  tourism  of  persons  with 
disabilities in 2030 (scenario of constant travel 
gap)  to  the  total  number  of  persons  with 
disabilities in the EU (assumed to be constant 
for simplicity, and considering that the number 
remained the same from 2012 to 2019). 

2030 

62.8% 

The  estimate  is  obtained  by  assuming,  in  the 
worst-case  scenario  for  the  travel  patterns  of 
persons with disabilities that their participation 
in  tourism does  not  grow on par with  that of 
the  general  population  and  remains  constant 
until 2030. 

2030 

Total  number  of  persons 
disabilities 
with 
(estimate, 
travelling 
scenario  of 
increasing 
travel gap) 

19,334,354  Obtained 

by 

the 

estimated 
applying 
participation  in  tourism  of  persons  with 
disabilities  in  2030  (scenario  of  increasing 
travel gap) to the total number of persons with 
disabilities in the EU (assumed to be constant 
for simplicity, and considering that the number 
remained the same from 2012 to 2019). 

Travel  gap  (estimate  in 
the  increasing  travel  gap 
scenario) 

2030 

11.9% 

2030 

69.4% 

Participation  in  tourism 
of 
with 
persons 
(estimate, 
disabilities 
scenario  of  minimum 
improvements) 

the  participation 

in 
Difference  between 
tourism of the total population aged 15-64 and 
the  participation  in  tourism  of  persons  with 
disability  aged  15-64  in  the  scenario  of 
increasing travel gap. 

Economic  Impact  and  Travel  Patterns  of 
Accessible  Tourism  in  Europe  -  Full  Report, 
for 
08/03/2015. 
Enterprise  and  Industry,  now  known  as 
Directorate-General 
Internal  Market, 
for 
Industry,  Entrepreneurship  and  SMEs  (DG 

Directorate-General 

115 

 
 
 
Variable 

Year  Amount 

Source 
GROW), European Commission. Available at: 
link. 
The estimate is based on survey data collected 
in  the  context  of  DG  GROW’s  study  and 
reports  the  travel  propensity  of  persons  with 
disabilities 
in  a  scenario  of  “minimum 
improvements” in accessibility. 

2030 

Total  number  of  persons 
with 
disabilities 
(estimate, 
travelling 
scenario  of  minimum 
improvements) 

21,378,534  Obtained 

by 

the 

estimated 
applying 
participation  in  tourism  of  persons  with 
disabilities  in  2030  (scenario  of  minimum 
improvements) to the total number of persons 
with  disabilities  in  the  EU  (assumed  to  be 
constant  for  simplicity,  considering  that  the 
number  remained  the  same  from  2012  to 
2019). 

Travel  gap  (estimate  in 
minimum 
the 
improvements scenario) 

2030 

5.3% 

2030 

74.7% 

Participation  in  tourism 
of 
with 
persons 
disabilities 
(estimate, 
scenario  of  moderate 
improvements) 

the  participation 

Difference  between 
in 
tourism of the total population aged 15-64 and 
the  participation  in  tourism  of  persons  with 
disability  aged  15-64  in  the  scenario  of 
minimum improvements. 

Directorate-General 

Economic  Impact  and  Travel  Patterns  of 
Accessible  Tourism  in  Europe  -  Full  Report, 
08/03/2015. 
for 
Enterprise  and  Industry,  now  known  as 
Directorate-General 
Internal  Market, 
for 
Industry,  Entrepreneurship  and  SMEs  (DG 
GROW), European Commission. Available at: 
link. 
The estimate is based on survey data collected 
in  the  context  of  DG  GROW’s  study  and 
reports  the  travel  propensity  of  persons  with 
disabilities 
in  a  scenario  of  “moderate 
improvements” in accessibility. 

2030 

Total  number  of  persons 
disabilities 
with 
travelling 
(estimate, 
scenario  of  moderate 
improvements) 

23,011,189  Obtained 

by 

the 

estimated 
applying 
participation  in  tourism  of  persons  with 
disabilities  in  2030  (scenario  of  moderate 
improvements) to the total number of persons 
with  disabilities  in  the  EU  (assumed  to  be 
constant  for  simplicity,  considering  that  the 
number  remained  the  same  from  2012  to 
2019). 

Decreasing 
(estimate, 
optimistic scenario) 

travel  gap 
the  most 

2030 

0% 

Difference  between 
in 
tourism of the total population aged 15-64 and 
the  participation  in  tourism  of  persons  with 

the  participation 

116 

 
 
 
Variable 

Year  Amount 

Source 
disability  aged  15-64  in  the  most  optimistic 
scenario. 

Source: Study supporting the impact assessment 

Detailed assessment of costs for the transport sector 

The following tables provide a more in-depth assessment of the expected costs of the policy options 
aimed  at  facilitating  mutual  recognition  of  disability  status  in  the  EU  for  service  providers  in  the 
transport  sector.  In  particular,  the  focus  is  on  the  cost  of  offering  preferential  conditions  already 
offered to nationals to travellers with disabilities from other Member States. The sector was identified 
as one of those offering the most preferential conditions (either mandated by law or on a voluntary 
basis) to persons with disabilities. For this reason, a more detailed assessment of potential costs for 
this  sector  resulting  from  the  implementation  of  the  EDC  in  options  A1  and  A2  was  deemed 
necessary. 

Within the EU, there is great variety in the extent and amount of preferential conditions offered to 
persons with disabilities and their personal assistants in the transport sector across Member States. At 
the same time, data on such preferential conditions is scarce and as a consequence, precise estimates 
of  the  costs  to  be  incurred  by  a  given  sector  are  hard  to  obtain. Moreover,  the  main  limitation  to 
perform this calculation is the absence of data on the number of persons with disability that currently 
enjoy preferential conditions when travelling within the EU. Nevertheless, illustrative examples can 
be used to pin down the magnitude of the direct costs for the transport sector of policy options A1 
and A2. In this case, estimates of costs of the transport sector are obtained, thanks to information on 
preferential conditions (such as discounts and reduced fees for both persons with disabilities and their 
personal assistants) obtained via desk research. The estimation exercise is carried out for a set of 10 
Member States: Belgium, Croatia, Estonia, France, Germany, Hungary, Ireland, Italy, Romania and 
Spain. 

The following steps were carried out in order to perform the exercise. 

•  First, the total number of tourism trips of persons with disabilities aged 15 to 65 to each of the 
selected  Member  States  is  estimated.  Precise  data  of  total  tourism  trips  is  available  from 
Eurostat, but the number of trips for persons with disability, as well as the additional travel 
that would occur because of the EDC, can only be obtained with some assumptions, outlined 
below. Persons above 65 years of age are already assumed to be offered preferential conditions 
available  to  the  elderly,  and,  as  such,  are  not  included  directly  in  the  calculations  of  the 
estimated costs. 

•  Secondly, the direct costs of offering preferential conditions for the transport sector during 
the trip of an individual traveller with disabilities are also estimated for each Member State 
considered. Importantly, these journeys are assumed to last between 5 and 8 days on average: 
in fact, according to estimates, an average tourism trip in the EU in 2019 (the last year for 
which data are available before the travel disruptions caused by the pandemic) lasted 5 nights. 
An average tourism trip to a domestic destination lasted 4 nights on average, while an average 
tourism trip to a foreign destination (i.e. not to the country of residence, which is closer to the 

117 

 
 
 
 
scenario of interest in this context) lasted about 8 nights.193 The costs are thus estimated by 
listing a potential set  of  activities performed by the traveller during the trip,  involving  the 
transport sectors and compatible with an overnight stay ranging between 5 and 8 nights. The 
potential frequency of each activity is also taken into account, for example by considering that 
a  long  distance  trip  within  a  given  country  occurs  less  frequently  than  taking  the  bus  in  a 
metropolitan area. Further details are provided below and in Table 8. 

•  Finally,  the  total  number  of  tourism  trips  of  persons  with  disabilities  from  other  Member 
States  and the cost  for the transport sector of  a  5 to  8  days  trip to  each  Member State are 
multiplied  to  obtain  the  total  costs  for  the  transport  sector,  according  to  the  estimation 
exercise. 

Regarding information on the number of tourism trips that persons with disabilities take part in across 
Member States and their participation in tourism, Table 7 provides a detailed breakdown of the type 
of information that was used for the estimation and the related sources. The number of tourism trips 
to each Member State from persons from other Member States was gathered via Eurostat. From this, 
the  number  of  tourism  trips  from  persons  with  disabilities  was  estimated  under  two  different 
scenarios, one with and one without the EDC. For this estimation, the travel frequency, i.e. the number 
of  trips  taken  in  a  year,  was  assumed  to  be  the  same  between  PwD  aged  15-65  and  the  general 
population  aged  15-65.194     In  the  scenario  without  the  EDC,  the  number  of  tourism  trips  to  each 
Member State was multiplied by the share of persons with disabilities in the EU in 2021 (the latest 
year  for  which  data  on  the  incidence  of  disability  are  available)  adjusted  by  their  participation  in 
tourism (estimated for 2019 assuming a constant travel gap with respect to 2012 and applying it to 
the  participation  in  tourism  of  the  general  population).  As  anticipated,  information  on  travelling 
patterns are always drawn from 2019, as it is the latest year for which data are available before the 
travel  disruptions  caused  by  the  pandemic,  and  is  therefore  more  representative  of  the  current 
situation. In the scenario with the EDC, the gap is assumed to have closed and the total number of 
tourism trips is simply multiplied by the share of persons with disabilities in the population, as if the 
general  population  and  persons  with  disabilities  participated  in  tourism  at  the  same  rate.  The  
difference  between  the  number  of  tourism  trips  of  persons  with  disabilities  in  the  maximum  and 
minimum participation in tourism scenario can be thought of as the maximum possible increase in 
their tourism trips (i.e. an increase due to complete closure of the travel gap) resulting from options 
A1 or A2. Such an increase is, however, unlikely to happen in practice as the travel gap is due to 
several factors other than the lack of mutual recognition of disability status, including accessibility 
and financial constraints. For these reasons, this has to be understood as an upper bound of the true 
effect, and, consequently, of the true cost for the transport sector.   

Table 7 – Estimation of tourism trips from persons with disabilities to selected Member States 

193 See presentation of Eurostat statistic: here  
194 The only data available on the travel frequency of PwD aged 16-65 is in the DG Grow Report on Accessible Tourism 
(see previous footnote), where both PwD and the elderly report a travel frequency significantly higher than the general 
population, probably because of self-selection of travellers into the online survey used to calculate these figures. Indeed, 
for the elderly population (65+), for whom the travel frequency figure can be obtained from both Eurostat and the DG 
grow report and compared, the travel frequency is significantly higher in the DG grow report sample. Given it is unlikely 
that PwD have a higher travel frequency than the general population, the assumption is made that the travel frequency 
are, in the best case scenario, the same between the two groups, and only the travel propensities, i.e. the probability to 
travel, differ. 

118 

 
 
 
 
Variable 

Source 

Year 

Member 
State/EU 
27 

Amount 

2012  EU 27 

6.3% 

gap 

Travel 
(difference 
between 
the 
participation 
in 
the 
of 
tourism 
general  population 
and that of persons 
disabilities 
with 
aged 15-64) 

in 
Participation 
tourism 
the 
of 
general  population 
aged 15-64 

Participation 
in 
tourism of persons 
disabilities 
with 
aged 
15-65 
(baseline estimate) 

in 
Participation 
tourism of persons 
with 
disability 
aged  15-65  (best 
case  scenario  with 
EDC) 

of 
with 

Incidence 
persons 
“severe” 
disabilities  in  the 
population 
aged 
15-65 

Share  of  persons 
with  16-65  in  the 
total population 

Share  of  persons 
with 
disability 
requiring 
assistance 

Report, 

Participation in tourism of persons 
with  disabilities  from:  Economic 
Impact  and  Travel  Patterns  of 
Accessible  Tourism  in  Europe  - 
08/03/2015. 
Full 
Directorate-General  for  Enterprise 
Industry,  now  known  as 
and 
Internal 
Directorate-General 
Market, Industry, Entrepreneurship 
and SMEs (DG GROW), European 
Commission.  Available  at:  link. 
Participation  in  tourism  of  the 
general  population  from:  Eurostat 
database, 
tour_dem_toage. 
Available at: link.  

for 

Eurostat database, tour_dem_toage. 
Available at: link. 

2019  EU 27 

69.1% 

Estimated  as  the  participation  in 
tourism  of  the  general  population, 
minus the travel gap 

2019  EU 27 

62.8% 

Estimated  assuming  the  travel  gap 
and 
has 
travel 
closed 
propensities 
general 
of 
population 
and  persons  with 
disabilities are equal 

the 

the 

2019  EU 27 

69.1% 

Eurostat  database,  hlth_silc_12. 
Available at: link. 

2021  EU 27 

5.3% 

Eurostat database, available at link  2021  EU 27 

64.1% 

Eurostat 
hlth_dpeh. 
database, 
Available  at:  Link,  elaborated  at 
link 

2021  EU 27 

32% 

119 

 
 
 
Number of tourism 
trips 
the 
(to 
Member  State)  of 
persons from other 
Member States 

Eurostat  database,  tour_dem_ttw. 
Available at: link. 

2019 

Number of tourism 
trips  of  persons 
with 
disabilities 
aged  16-65  from 
Member 
other 
States 
(baseline 
estimate) 

the 

Estimated  multiplying 
total 
number of tourism trips by the share 
of persons with disabilities aged 15-
65  in  the  population,  corrected  by 
their participation in tourism 

2019 

Number of tourism 
trips  of  persons 
with 
disabilities 
aged  16-65  (best 
case  scenario  with 
the EDC) 

the 

Estimated  multiplying 
total 
number of tourism trips by the share 
of  persons  with  disabilities  in  the 
population  (hence,  assuming  the 
travel gap has closed) 

2019 

Belgium 

7,322,120 

Croatia 

9,148,672 

Estonia 

2,338,333 

France 

20,703,816 

Germany  21,381,766 

Hungary 

4,299,138 

Ireland 

2,228,143 

Italy 

28,452,724 

Romania  3,876,987 

Spain 

31,654,630 

Belgium 

226,777 

Croatia 

283,348 

Estonia 

72,422 

France 

641,229 

Germany  662,226 

Hungary 

133,151 

Ireland 

69,009 

Italy 

881,225 

Romania  120,076 

Spain 

980,393 

Belgium 

248,754 

Croatia 

310,808 

Estonia 

79,440 

France 

703,371 

Germany  726,403 

Hungary 

146,055 

Ireland 

75,697 

Italy 

966,624 

Romania  131,713 

Spain 

1,075,403 

Source: Study supporting the impact assessment based on Eurostat data and DG GROW’s report on 
accessible tourism 

After estimating the number of trips from persons with disabilities, the costs for the transport sector 
of one journey for a person with disability and their personal assistant are computed by listing a set 
of activities related to transport potentially carried out during a tourism trip and adding up their costs. 
The activities are detailed in Table 8 below and include: the purchase of 10 standard fare tickets in a 
city with the local public transport system, 2 tickets for a short distance journey and 2 tickets for a 

120 

 
 
 
 
transfer to the airport. A medium distance and a long distance journey are also included, but for only 
50% and 20% of the trips respectively, as it can reasonably be expected that a portion of all tourists, 
rather than staying in their first destination, choose to also travel to other destinations during the trip. 
For  each  activity,  the  cost  of  a  ticket  is  obtained  via  desk  research,  together  with  information  on 
discounts or reduced fees reserved to persons with disabilities and their personal assistants. Detailed 
information on this process is collected in Table 11, at the end of this Section. 

Table 8 – Individual traveller’s journey for the assessment of costs of the transport sector 
Member States 
Trips included 

Frequency 

Standard bus fare within a city  10 times during the trip 

Short distance journey 

Twice during the trip (return ticket) 

Medium distance journey 

Once during the trip, for 50% of all trips  

Long distance journey 

Once during the trip, for 20% of all trips 

Transfer to the airport 

Twice during the trip (return  ticket) 

Belgium, Croatia, 
Estonia, France, 
Germany, 
Hungary, Ireland, 
Italy, Romania, 
Spain 

Source: Study supporting the impact assessment 

Finally, the costs for the transport sectors are estimated as the monetary amount of the discount or 
reduced fee for the person with disability (e.g. if the price of the ticket is EUR 10 and the discount 
for persons with disability is 60%, the cost for the service provider in the transport sector is estimated 
at EUR 6). The same holds for personal assistants. 

 Despite the difficulties in calculating the participation in tourism of persons with disability (and the 
potential change in travel patterns due to the EDC), there are two other main sources of uncertainty 
underlying this estimation: i) uncertainty related to the provisions of preferential conditions in other 
Members States, benefit from these preferential conditions nonetheless; ii) uncertainty about the share 
of  persons  with  disability  who  travel  with  a  personal  assistant,  who  often  also  benefits  from 
preferential conditions. To overcome the first issue, the number of persons with disability who already 
benefit from preferential conditions, the answers from the Public Consultation are considered, where 
46% of respondents (EU citizens with disability aged 15-65) reported ever being denied access to 
preferential conditions when abroad. This proportion is taken as the highest number of persons who 
could  gain  access  to  preferential  conditions  for  all  countries  (while  this  could,  of  course,  vary  by 
sector and country, this disaggregation is not possible with the data at hand). Regarding the issue of 
how many PwD travel with a personal assistant, who could also benefit from preferential conditions, 
different  estimates  are available:  i) in  2012, Eurostat reported the share  of persons with  disability 
requiring assistance, estimated around 32% for EU population aged 15-64;195 ii) from the DG Grow 
report196, where 73% of persons with disability aged 16-65 report travelling accompanied, as well as 
the online survey targeted to persons with disability conducted during the study, where 14 out of 17 
PwD  (82%)197  answered  that  they  do  need  a  personal  assistant  to  travel.    On  the  one  hand,  only 

195 The data is available here (database: HLTH_DPEH )  and elaborated by Eurostat at this link. 
196 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. Participation in tourism of the general population from: Eurostat 
database, tour_dem_toage. Available at: link. 
197 Study supporting the impact assessment based on Survey targeted at PwDs 

121 

 
 
 
 
recognised personal assistants get access to preferential conditions because of the EDC, as the official 
personal assistant would have to be recognized to obtain the same preferential conditions offered to 
nationals. On the other hand, accompanying persons who are not the personal assistant can still be 
offered preferential conditions voluntarily by service providers198 . In estimating the costs, both values 
(the share who requires a personal assistant (32%) and the share who travels accompanied (73%)) are 
employed to obtain a lower and an upper bound of the costs. For this reason, a range of estimates is 
presented. 

There are two main reasons to take these estimates as a overestimate of the costs of offering 
preferential conditions as a result of the EDC in the transport sector: i) the EDC is estimated to 
close the gap in participation in tourism between PwD and the general population, which is the best 
case scenario and unlikely to happen without significant improvements in accessibility; ii) 46% of 
PwD are assumed not to benefit at the moment from preferential conditions, which is the maximum 
value given that these are PwD reporting ever being denied a preferential condition abroad (in any 
country or sector). Moreover, of the range of estimates presented, the lower bound is the one that 
more truly reflects the costs from the obligation of offering preferential conditions to persons with 
disability  and  their  assistant.  The  decision  to  offer  preferential  conditions  to  other  accompanying 
persons would remain voluntary for each service provider.   

The resulting  range  of  estimated  total  costs for  each  country  are shown in Table 9. To gauge the 
magnitude of these estimates, Table 9 also compares the figures with the relative size of the passenger 
transport  sector  (excluding  air  travel),  measured  in  terms  of  turnover199  in  2019.  The  size  of  the 
passenger transport sector excluding air travel is not always publicly available for all Member States, 
as, for some Member States, the disaggregations that necessary to obtain this figure are marked as 
confidential in recent years.200 Nonetheless, it was preferred to employ these figures for comparison, 
when available, rather than the total turnover (or value added) in the entire transport sector, including 
freight transport or air travel, which would be much less indicative of the size of the sector affected 
by the preferential conditions. When some of the necessary cells were not available, the turnover was 
imputed  by  using  values  available  for  previous  years,  adjusted  by  the  growth  in  the  rest  of  the 
passenger transport sector. 

Another comparison to gauge the order of magnitude of these costs is to compare them to  what it 
(would) cost to offer the same preferential conditions to the elderly (65+) travelling to other Member 
States, assuming they already benefit from the same or similar preferential conditions. The elderly 
are a significantly larger share of the EU population than persons with disability (20.8% in 2021201) 
and, although they are estimated to have a lower participation in tourism than PwD (49.6% in 2019202), 
they account for a higher share of total trips. Moreover, the elderly also have a much higher incidence 
of disability, estimated around 18.4% in 2021203 , which implies their personal assistant, if any, could 
also get access to preferential conditions. In this comparison, it is also taken into account that in the 
Public  Consultation  persons  with  disabilities  aged  65+  report  much  less  incidence  of  ever  being 
denied preferential conditions abroad: only 29% compared to 46% among persons with disabilities 
aged 15-65. In Table 9, the cost of offering preferential conditions to travelling PwD aged 15-65 and 

198 See an example here.  
199 For the definition of turnover, see Eurostat 
200 The data is available from Eurostat dataset: SBS_NA_1A_SE_R2, at the following link. 
201 Source: Eurostat, link 
202 Source, Eurostat, link 
203 See here for the incididence of severe limitations for the EU population aged 65+. 

122 

 
 
 
 
their personal assistants in the transport sector is compared to the cost of offering the same preferential 
conditions to the elderly population (also taking into account that some elderly might be accompanied 
by a personal assistant, if they are also persons with disabilities).  

regarding 

in  question,  and 

The  magnitude  of  the  expected  direct  costs  of  offering  preferential  conditions  for  transport 
service providers (excluding air transport) are presented in Table 9, and are commented in the 
main  report.  Overall,  the  costs  range  between  1.7.  to  31.2  million  EUR  depending  on  the 
the  share  of  personal 
the  assumption 
Member  State 
assistant/accompanying persons eligible for discounts. This range is driven mostly by the different 
sizes  of  the  Member  States,  and,  to  a  much  lesser  extent,  by  different  touristic  attraction,  and 
availability of preferential conditions (with the exception of Italy, where preferential conditions in 
transport are often related to residence status). For those countries in which the size of the passenger 
transport sector can be obtained, these additional costs appear very small relative to overall turnover, 
ranging from 0.01% to 0.31%. Table 9 also presents what it would cost (or currently does cost, for 
those countries that offer them) to offer the same preferential conditions to the elderly (65+). In most 
countries, the cost  is significantly lower, usually  less than one-fourth.  The exceptions are France, 
where it would be between one third and one half, and Italy, where it would be above one half: the 
reason is that in both countries most of the savings from preferential conditions apply to the personal 
assistant and not the PwD, so assuming that the elderly person gets the same preferential condition of 
the PwD (which is unlikely in this case) mechanically gives an higher estimate.   

Finally, it needs to be taken into account that these results are to be considered as only suggestive of 
the order of magnitude of total costs of policy options A1 and A2 for the transport sector. An exact 
estimate by country of the total costs is difficult to obtain,  in particular because of the absence of 
information  on  how  many  persons  with  disability  currently  travelling  benefit  from  preferential 
conditions in the transport sector.  

Table 9 – Range of estimated yearly costs in the transport sector in selected Member States  

Costs 

Costs due to 
trips from 
persons 
with 
disabilities 
15 to 65 
from other 
Member 
States 
(including 
personal 
assistants) 

Belgium 

Croatia 

Estonia 

France 

Germany 

Total   

€5,618,824 
-  
€8,044,334 

€2,021,504 
- 
€2,505,692 

€1,768,118 
- 
€2,317,306 

€13,118,033 - 
€21,219,981 

€23,588,985 - 
€28,144,220 

As %Turnover 
of passenger 
transport 
sector* 

0.11% -  
0.16% 

N/A 

0.24% - 
0.31% (e) 

0.02% - 
0.04% 

0.05%-0.06% 
(e) 

123 

 
 
 
  
  
  
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
22.5% -
31.7% 

18.5%- 
22.8% 

19.8% - 
25.7% 

28.5% - 
44.7% 

17.8% - 
21.0% 

As % of cost of 
offering same 
preferential 
conditions to 
all 65+ 

Source: Study supporting the impact assessment.  *including passenger water transport, but excluding 
passenger air transport. (e), indicates that the value of turnover in million EUR was not available, and was 
imputed from previous years, when available, to obtain the relevant estimate. N/A indicates not available, 
when even in years prior to 2019 the data to obtain the value of turnover in passenger transport, excluding air 
transport, was not available. 

Table 9 Continued – Range of estimated yearly costs in the transport sector in selected Member States  

Costs 

Hungary 

Ireland 

Italy 

Romania 

Spain 

Total   

€3,652,452 -  
€4,741,892 

€3,586,174 
- 
€4,700,061 

€2,845,742 
-  
€5,352,441 

€2,247,327 - 
€2,945,361 

€22,238,741 -  
€31,200,047 

As 
%Turnover of 
passenger 
transport *  

0.16% - 
0.20% 

(e) 

0.11% - 
0.15% 

 (e) 

0.01% - 
0.02% 

0.11%- 
0.15% 

 0.16%- 0.22% 
(e) 

Costs due 
to trips 
from 
persons 
with 
disabilities 
15 to 65 
from other 
Member 
States 
(including 
personal 
assistants) 

As % cost of 
offering same 
preferential 
conditions to 
all 65+ 

19.6% -  
25.2% 

19.8% -  
25.7% 

45.7%- 
80.2% ++ 

19.8% - 
25.7% 

21.8% - 30.1% 

Source: Study supporting the impact assessment.  *including passenger water transport, but excluding 
passenger air transport. (e), indicates that the value of turnover in million EUR was not available, and was 
imputed from previous years, when available, to obtain the relevant estimate. N/A indicates not available, 
when even in years prior to 2019 the data to obtain the value of turnover in passenger transport, excluding air 
transport, was not available. ++ The reason for this number is that preferential conditions in Italy are present 
virtually only for personal assistants. Assuming that the elderly get the same preferential conditions of PwD 
(but without the personal assistant), mechanically inflates this number.    

Costs 

Costs due to 
trips from 
persons 
with 

Hungary 

Ireland 

Italy 

Romania 

Spain 

Total   

€3,652,452 -  
€4,741,892 

€3,586,174 
- 
€4,700,061 

€2,845,742 
-  
€5,352,441 

€2,247,327 - 
€2,945,361 

€22,238,741 -  
€31,200,047 

124 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
disabilities 
15 to 65 
from other 
Member 
States 
(including 
personal 
assistants) 

As 
%Turnover of 
passenger 
transport *  

0.16% - 
0.20% 

(e) 

0.11% - 
0.15% 

 (e) 

0.01% - 
0.02% 

0.11%- 
0.15% 

 0.16%- 0.22% 
(e) 

The  range  of  estimated  costs  in  the  total  EU-27  is  presented  in  Table  10.  In  order  to  obtain  this 
estimate, it needs to be assumed that the 10 countries for which prices and preferential conditions 
were  collected  in  the  transport  sector  are  representative  of  the  EU-27.  This  assumption  seems 
reasonable  considering  that  the  10  countries  sampled  account  for  roughly  69%  of  the  EU-27 
population in 2021, and include both small and large Member States. The estimate is obtained by 
taking an average per capita cost for the 10 countries for which data is available, as well as population-
weighted average per capita cost, which takes into account the size of the different Member States. 
These average per capita costs are then multiplied by the EU-27 population to obtain the total cost 
(both lower and upper bound, depending on assumptions regarding personal assistant/accompanying 
persons stated above.) The total yearly costs are estimated to range between 116 and 161 million 
EUR, accounting for only 0.05% to 0.08% of (non-air) passenger transport in the whole EU-27.  

Table 10 – Range of estimated yearly costs in the transport sector at EU 27 level 

Per capita cost Lower 
bound 

Per capita cost Upper 
bound  

Population (2021) 

Country 

Belgium 

Croatia 

Estonia 

France 

Germany 

Hungary 

Ireland 

Italy 

Romania 

Spain 

Average per capita 
cost 

Population 
weighted average 
per capita cost 

11590000 

3899000 

1300000 

67750000 

83820000 

9710000 

5030000 

59110000 

19120000 

47420000 

€0.5 

€0.5 

€1.4 

€0.2 

€0.3 

€0.4 

€0.7 

€0.0 

€0.1 

€0.5 

€0.5 

€0.7 

€0.6 

€1.8 

€0.3 

€0.3 

€0.5 

€0.9 

€0.1 

€0.2 

€0.7 

€0.6 

€0.3 

€0.4 

125 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total  Cost  –  Lower 
Bound  

Total  Cost  –  Upper 
Bound  

EU  27  Population 
(2021) 

447,207,489   

308, 749, 000 

(the 10 countries where 
transport data was collected 
account for 69% of EU 
population in 2021) 

EU-27 Cost  

€116,869,492.0 

€161,026,119.7   

As  %Turnover  of 
passenger  transport 
*  

      0.05% (e) 

0.08% (e) 

Source:  Study  supporting  the  impact  assessment.    *including  passenger  water  transport,  but  excluding 
passenger air transport. (e), indicates that the value of turnover in million EUR was not available, and was 
imputed from previous years, when available, to obtain the relevant estimate. 

Table 11 – Detailed assessment of costs for service providers in the transport sector through 
travellers journeys 

Savings 
for 
person 
with 
disabilit
ies 
(EUR) 

Savings 
for 
personal 
assistant 
(EUR) 

2.5 

2.5 

K
m 

n.a
. 

Memb
er State 

Activity 

Standard 
bus 
fare  in  the  city 
of Antwerp 

Notes 

Sources 

An administrative fee of EUR 5 to 
receive a free travel pass card; the 
accompanying  person  needs  to 
have a special card that recognises 
them as an assistant (no fee to get 
such  card).  Visually  impaired  do 
not pay the EUR 5 administrative 
fee. 

Lijn  website. 
Available 
at: 
link. 

Belgiantrain 
website. 
Available 
link. 

at: 

Belgiantrain 
website. 
Available 
link. 

at: 

Belgiu
m 

Short  distance 
train 
trip  by 
(Brussels 
to 
Mechelen) 

2.0 

5.2 

3.6 

8.4 

Medium 
distance  trip  by 
train 
(Brussels 
to Antwerp) 

25  50%  discount;  need  to  have  a 
specific card in order to receive a 
discount, 
accompanying 
person  needs  to  have  a  card  that 
recognises 
an 
them 
accompanying person. 

the 

as 

55  50%  discount;  need  to  have  a 
specific card in order to receive a 
discount, 
accompanying 
person  needs  to  have  a  card  that 
an 
them 
recognises 
accompanying person. 

the 

as 

126 

 
 
 
 
 
 
 
 
 
 
 
 
Long  distance 
train 
trip  by 
(Brussels 
to 
Knokke) 

to 

Transfer 
airport 
(Brussels  Midi 
to Charleroi) 

Total costs for a 
trip of 5-days 

Standard 
bus 
fare  in  the  city 
of Zaghreb 

Short  distance 
train 
trip  by 
(Zaghreb 
to 
Velika Gorica) 

Medium 
distance  trip  by 
train 
(Zaghreb 
to Karlovac) 

Long  distance 
train 
trip  by 
(Zaghreb 
to 
Split) 

Croatia 

Transfer 
airport 
the 
Zaghreb) 

city 

to 
(from 
of 

8.8 

19 

12
4 

50%  discount;  need  to  have  a 
specific card in order to receive a 
discount, 
accompanying 
person  needs  to  have  a  card  that 
an 
them 
recognises 
accompanying person. 

the 

as 

55  No  discount  for  the  person  with 
the  person  with 
disability;  if 
disability  is  in  a  wheelchair  then 
the carer has a 100% discount but 
needs to book a ticket at least 72h 
in advance via e-mail. 

Belgiantrain 
website. 
Available 
link. 

at: 

Flibco 
website. 
Available 
link. 

at: 

0 

16.6 

32.6 

51.7 

0.5 

0 

n.a
. 

100% discount only if resident in 
Zagreb;  the  guide  dog,  when 
needed, travels for free. 

Zet  website. 
at: 
Available 
link. 

1.1 

1.5 

16  75% discount; the assistant travels 

for free 

3.4 

4.6 

53  75% discount; the assistant travels 

for free 

11.3 

15.1 

40
9 

75% discount; the assistant travels 
for free 

0 

0 

n.a
. 

No  discount  is  mentioned  for 
persons with disabilities. 

Hzpp  website. 
at: 
Available 
link. 

Hzpp  website. 
at: 
Available 
link. 

Hzpp  website. 
Available 
at: 
link. 

Pleso  Prijevoz 
website,  FAQ, 
at: 
available 
link; 
Policy 
and  Tickets, 
available 
at: 
link. 

Total costs for a 
trip of 5-days 

Standard 
bus 
fare  in  the  city 
of Tallinn 

11.5 

8.3 

2.0 

2.0 

2.0 

2.0 

Short  distance 
train 
trip  by 
(Tallinn 
to 
Saue) 

Estoni
a 

n.a
. 

the 

100%  discount,  only  available  if 
the  person  holds  a transport card 
disability 
national 
or 
card/certificate; the  assistant  also 
receives a 100% discount, without 
need to show a document 

Website 
travel 
Tallinn. 
Available 
link. 

for 
in 

at: 

20  100%  discount,  only  available  if 
the  person  holds  a transport card 
or 
disability 
national 
card/certificate; the  assistant  also 

the 

Elron  website. 
Available 
at: 
link.  

127 

 
 
 
 
 
10.0 

10.0 

12.0 

12.0 

16.2 

16.2 

2.0 

2.0 

36.7 

36.7 

2.1 

2.1 

18
2 

18
2 

23
4 

n.a
. 

receives a 100% discount, without 
need to show a document 

the 

100%  discount,  only  available  if 
the  person  holds  a transport card 
disability 
national 
or 
card/certificate; the  assistant  also 
receives a 100% discount, without 
need to show a document 

the 

100%  discount,  only  available  if 
the  person  holds  a transport card 
or 
disability 
national 
card/certificate; the  assistant  also 
receives a 100% discount, without 
need to show a document 

the 

100%  discount,  only  available  if 
the  person  holds  a transport card 
or 
disability 
national 
card/certificate; the  assistant  also 
receives a 100% discount, without 
need to show a document 

Elron  website. 
Available 
at: 
link. 

LuxExpress 
website. 
Available 
link. 

at: 

Elron  website. 
at: 
Available 
link. 

100%  discount,  only  available  if 
the  person  holds  a transport card 
disability 
national 
or 
card/certificate; the assistant does 
not need to prove anything. 

the 

Website 
travel 
Tallinn. 
Available 
link. 

for 
in 

at: 

n.a
. 

100% discount. Depending on the 
disability,  the  assistant  may  also 
receive a 50% discount  

Ratp  website. 
Available 
at: 
link. 

0 

0 

0 

0 

4.2 

15  50%  discount 
assistants 

for 

personal 

21.1 

19
0 

50%  discount 
assistants 

for 

personal 

Sncf  website. 
Available 
at: 
link.  

Sncf  website. 
Available 
at: 
link. 

35.0 

62.5 

50
0 

77
0 

The  trip  is  free  for  personal 
assistants if the card specifies the 
person  with  disabilities  needs  to 
be accompanied 

Flixbus 
website. 
Available 
link. 

at: 

50% discount for an assistant 

Medium 
distance  trip  by 
train (Tallinn to 
Tartu) 

Medium 
distance  trip  by 
bus  (Tallinn  to 
Tartu) 

Long  distance 
train 
trip  by 
(Tallinn 
to 
Valga) 

Transfer  to  the 
(from 
airport 
by 
Tallinn, 
tram) 

Total costs for a 
trip of 5-days 

Standard 
bus 
fare  in  the  city 
of Paris 

Short  distance 
trip  by 
train 
(Val de Reuil to 
Vernon) 

Medium 
distance  trip  by 
train  (Paris  to 
Le Havre) 

Long  distance 
trip 
by  Bus 
(Paris to Lyon) 

Long  distance 
train 
trip  by 
to 
(Paris 
Marseilles) 

France 

Transfer 
airport 
CDG) 

0 

to 
(Paris 

5.7 

n.a
. 

50%  discount  or  free  for  an 
assistant, PwD pays full price 

128 

Sncf  website. 
Available 
at: 
link. 

Ratp  website. 
at: 
Available 
link. 

 
 
 
 
Total costs for a 
trip of 5-days 

Standard 
in 
fare 
Berlin 

bus 
city 

Short  distance 
train 
trip  by 
(Berlin 
to 
Potsdam) 

Medium 
distance  trip  by 
train  (Berlin  to 
Brandenburg) 

Medium 
distance  trip  by 
bus  (Munich  to 
Nuremberg) 

Long  distance 
train 
trip  by 
(Berlin 
to 
Bremen) 

Germa
ny 

4.0 

0 

7.9 

0 

0 

13.0 

59.9 

0 

Berlin to airport  4 

0 

Total costs for a 
trip of 5-days 

bus 
Standard 
fare  in  the  city 
of Budapest 

32.6 

51.7 

0.94 

0.94 

€21.0 

€61.1 

3.0 

3.0 

n.a
. 

100%  discount  for  persons  with 
their 
severe 
assistant  if  have  a  specific  card 
(Schwerbehindertenausweis) 

disability 

and 

Official 
Website 
Berlin. 
Available 
link. 

of 

at: 

38  100%  discount  for  persons  with 
severe  disability  who  hold  a 
specific 
card 
(Schwerbehindertenausweis) 

Deutsche Bahn 
website. 
Available 
link. 

at: 

83  100%  discount  for  persons  with 
severe  disability  who  hold  a 
specific 
card 
(Schwerbehindertenausweis) 

Deutsche Bahn 
website. 
Available 
link. 

at: 

17
0 

39
5 

Free for personal assistants if the 
person  with  disability  has  a 
disability 
or  medical 
certificate 

card 

Flixbus  Policy 
and Tickets 

100%  discount  for  persons  with 
severe  disability  who  hold  a 
specific 
card 
(Schwerbehindertenausweis) 

Deutsche Bahn 
website. 
Available 
link. 

at: 

30  100%  discount  for  persons  with 
severe  disability  who  hold  a 
card 
specific 
(Schwerbehindertenausweis) 

Deutsche Bahn 
website. 
Available 
link.  

at: 

n.a
. 

Free  local  transport  for  persons 
with  disabilities  and  personal 
assistants 

BKK  website, 
persons  with 
physical 
impairments, 
available 
link; 
available 
link. 

at: 
prices, 
at: 

BKK  website, 
persons  with 
physical 
impairments, 
available 
link; 
available 
link. 

at: 
prices, 
at: 

BKK  website, 
persons  with 
physical 
impairments, 

Hunga
ry 

72  hours  travel 
card  in  the  city 
of Budapest 

15 

15 

n.a
. 

Free local transport for PwD and 
personal assistants 

Short  distance 
train 
by 
(Budapest 
to 
Visegrad) 

2.9 

2.9 

40  90% 

discount 

on 

regional 

transport 

129 

 
 
 
 
 
4.5 

4.5 

Medium 
distance by train 
(Budapest 
to 
Szolnok) 

10.79 

0 

Long  distance 
train 
by 
(Budapest 
to 
Debrecen) 

90% discount 

90% discount 

11
1 

22
1 

to 

5.9 

5.9 

Transfer 
airport 
(Budapest) 

n.a
. 

Free  local  transport  for  persons 
with  disabilities  and  personal 
assistants 

at: 
prices, 
at: 

available 
link; 
available 
link. 

BKK  website, 
persons  with 
physical 
impairments, 
available 
link; 
available 
link. 

at: 
prices, 
at: 

BKK  website, 
persons  with 
physical 
impairments, 
available 
link; 
available 
link. 

at: 
prices, 
at: 

BKK  website, 
persons  with 
physical 
impairments, 
available 
at: 
link.  Budapest 
airport 
website, 
available 
link. 

at: 

All values for Hungary are converted in EUR using the 
current exchange rate. 

Total costs for a 
trip of 5-days 

Standard 
bus 
fare  in  the  city 
of Dublin 

41.7 

39.6 

2.0 

2.0 

n.a
. 

Ireland 

Short  distance 
by train (Dublin 
to Newbridge) 

Medium 
distance  by  bus 
(Dublin 
to 
Limerick) 

Medium 
distance by train 
(Dublin 
to 
Limerick) 

10.9 

10.9 

46  100%  discount,  but  the  person 
needs  to  be  a  Free  Travel  Pass 
holder 

28.0 

28.0 

34.1 

34.1 

19
5 

19
5 

The  provider  accepts  the  Free 
Travel  Pass  for  persons  with 
disabilities, and refers to the Free 
Travel Scheme 

100%  discount,  but  the  person 
needs  to  be  a  Free  Travel  Pass 
holder 

130 

Transport 
Ireland 
website. 
Available 
link. 

Irishrail 
website. 
Available 
link. 

Citylink 
website. 
Available 
link. 

Irishrail 
website. 
Available 
link.  

for 

at: 

at: 

at: 

at: 

 
 
 
 
Long  distance 
train  (Dublin  to 
Killarney) 

34.0 

34.0 

30
8 

100%  discount,  but  the  person 
needs  to  be  a  Free  Travel  Pass 
holder 

Transfer 
to 
airport (Dublin) 

7 

7 

15 

Total 
savings 
for  a  trip  of  5-
days 

Standard 
bus 
fare  in  the  city 
of Bergamo 

78.0 

78.0 

0 

0 

n.a
. 

No 
a 
explicit  mention  of 
preferential tariff for persons with 
disabilities. 

Irishrail 
website. 
Available 
link. 

at: 

Dublin Airport 
website,  help 
support, 
& 
at: 
available 
link. 
DublinExpress 
website, 
available 
link. 

at: 

ATB  Trasporti 
Bergamo 
website. 
Available 
link. 

at: 

0 

0 

0 

Standard 
bus 
fare  in  the  city 
of Rome 

Standard 
bus 
fare  in  the  city 
of Trento 

Medium 
distance by train 
(Bergamo 
to 
Lake Garda) 

0 

0 

0 

Italy 

Medium 
distance 
by  
train  (Bergamo 
to Verona) 

Medium 
distance  by  bus 
(Milan to Turin) 

Long  distance 
by  train  (Milan 
to Rome) 

8.0 

40.0 

0 

0 

15.0 

0 

Discounts 
for  Rome 
only 
residents  depending  on  taxable 
income;  also,  only  available  on 
annual subscription. 

ATAC  Roma 
website. 
Available 
link. 

at: 

n.a
. 

travel  only 

Free 
residents. 

for  Trento 

90  Travel discounts for persons with 
disabilities  are  only  for  legal 
residents of the region, a disability 
card per se does not appear to be 
enough. 

12
0 

14
5 

50
0 

20%  discount  or  free  travel  on 
same  train for  the  accompanying 
person,  assumed  for  a  EUR  40 
ticket. 

Free 
travel  for  accompanying 
person  and/or  pet,  average  price 
of a ticket bought the day before. 

for 

No  mention  of  free  travel  or 
persons  with 
discounts 
disability  or  personal  assistants. 
There  are  only  discounts  for 
seniors.  There  are  preferential 

Trentino 
Trasporti. 
Available 
link. 

Regione 
Lombardia 
Tariffa 
Agevolata. 
Available 
link. 

at: 

at: 

Trenitalia 
website. 
Available 
link. 

Flixbus 
website. 
Available 
link. 

at: 

Italy 

at: 

Italo  website, 
Policy, 
available 
at: 
link;  Offers, 
available 
at: 
link. 

131 

 
 
 
 
 
 
to 

Transfer 
Bergamo 
Airport by bus 

0 

0 

2.0 

13.8 

0.6 

0.6 

4.2 

4.2 

3.8 

3.8 

30.0 

30.0 

savings 
Total 
for  a  trip  of  5-
days 

Standard 
bus 
fare  in  the  city 
of Bucharest 

Short  distance 
train 
trip  by 
(Bucharest 
to 
Fundulea) 

Medium 
distance  trip  by 
train  (Bucharest 
to Giurgiu) 

Long  distance 
train 
trip  by 
(Bucharest 
to 
Oradea) 

to 

2.9 

2.9 

Transfer 
airport 
(Bucharest) 

conditions, but related to service, 
and help in reserving seats. 

5  No 

explicit  mention  of 
a 
preferential tariff for persons with 
disabilities. 

n.a
. 

42 

11
5 

64
9 

n.a
. 

ATB  Trasporti 
Bergamo 
website. 
Available 
link. 

at: 

Stbsa  website. 
at: 
Available 
link. 

CFR  Călători 
website. 
Available 
link. 

at: 

CFR  Călători 
website. 
Available 
link. 

at: 

CFR  Călători 
website. 
Available 
link.  

at: 

CFR  Călători 
website. 
Available 
link.  

at: 

28.1 

28.1 

All values for Romania are converted in EUR using the 
current exchange rate. 

0 

2.4 

9.4 

11.4 

n.a
. 

n.a
. 

There is no tariff for persons with 
disabilities 
journey; 
for 
assistants  need  to  have  a  special 
card in order to travel for free 

1 

Tmb  website. 
Available 
at: 
link. 

The pasts costs EUR 2 for persons 
with  disabilities;  accompanying 
persons  needs  to  have  a  specific 
card 
the 
discount 

to  receive 

in  order 

Tmb  website. 
Available 
at: 
link. 

Venta website. 
Available 
at: 
link. 

1.3 

1.3 

27  25%  discount;  discount  only 
the  Tarjeta 
provided  with 
Dourada 
assistant 
the 
card; 
receives the same  discount  if  the 
person  has  a  65%  or  greater 
disability. 

132 

Roman
ia 

Spain 

savings 
Total 
for  a  trip  of  5-
days 

bus 
Standard 
fare  in  the  city 
of Barcelona 

10  journey  pass 
in 
city 
Barcelona 

Short  distance 
train 
trip  by 
(Madrid 
to 
Fuenlabrada) 

 
 
 
 
 
 
 
 
 
2.8 

2.8 

14.6 

14.6 

0.0 

55.0 

20.1 

20.1 

6.0 

6.0 

Medium 
distance  trip  by 
train (Madrid to 
Toledo) 

Medium 
distance  trip  by 
train (Madrid to 
Jaen) 

Medium 
distance  trip  by 
bus  (Madrid  to 
del 
Quintana 
Puente) 

Long  distance 
train 
trip  by 
(Madrid 
to 
Barcelona) 

Long  distance 
bus 
trip 
by 
(Madrid 
to 
Barcelona) 

Trip  to  Madrid 
airport by Train  

0.5 

0 

Total 
savings 
for  a  trip  of  5-
days 

30.8 

44.2 

73  25%  discount;  discount  only 
the  Tarjeta 
provided  with 
Dourada 
assistant 
the 
card; 
receives the same  discount  if  the 
person  has  a  65%  or  greater 
disability. 

31
0 

25
2 

61
3 

61
3 

40%  discount;  discount  only 
the  Tarjeta 
provided  with 
Dourada 
assistant 
the 
card; 
receives the same  discount  if  the 
person  has  a  65%  or  greater 
disability. 

Free for accompanying person 

25%  discount;  discount  only 
the  Tarjeta 
provided  with 
Dourada 
assistant 
the 
card; 
receives the same  discount  if  the 
person  has  a  65%  or  greater 
disability. 

15%  discount  for  those  with  a 
33%  disability  and  more;  same 
applies to the assistants except if 
the  disability  is  intellectual  or 
developmental  (in  that  case  the 
assistant travels for free) 

Venta website. 
Available 
at: 
link. 

Venta website. 
at: 
Available 
link.  

Flixbus  Policy 
and Tickets 

Venta website. 
at: 
Available 
link. 

Alsa  website. 
Available 
at: 
link. 

n.a
. 

20% discount for the person with 
disability,  no  mention  of  the 
special assistant 

Crtm  website. 
at: 
Available 
link. 

Source: Study supporting the impact assessment 

Final ranking matrix 

Following the assessment of the policy options through the MCDA, the options are compared based 
on their total scores through a final ranking matrix. In this matrix, the sums of the  weights for all 
criteria  in  relation  to  which  a  given  policy  option  performs  better  than  other  policy  options  are 
indicated. The outranking matrix follows the example of Table 11. 

Table 11– Ilustrative final ranking matrix 
Policy option 

Direction 

Score 

133 

 
 
 
 
 
 
Baseline 
Policy option 1 
Policy option 2 

+/- 
+ 
+ 

0 
5 
11 

Source: Study supporting the impact assessment 

ANNEX 5: COMPETITIVENESS CHECK 

1. Overview of impacts on competitiveness  

The impacts of policy options A2 and B2 on competitiveness and SMEs are analysed in Chapter 6. 
For  both  options,  these  impacts  are  deemed  to  be  small,  and  mainly  occurring  through  the  same 
channel: the increase in persons with disabilities travelling affecting the market for accessible tourism 
in Europe. Like for the wider tourism sector, many SMEs operate in this market204 and they would 
be positively impacted by the increased travel flows of persons with disabilities from other Member 
States. 

Table 1 – Overview of impacts on competitiveness – Preferred Options 

Dimensions 
Competitiveness 

of 

the 

Impact  of 
initiative 
(++ / + / 0 / - / -- / 
n.a.) 

to 
References 
sub-chapters  of 
the main report 
or annexes 

Comment 

Cost 
competitiveness 

and 

price 

0 

Chapter 6 

to  offer 
The  cost  for  service  providers 
preferential  conditions 
to  persons  with 
disabilities  from  other  Member  States  is 
considered  to  be  negligible  given  the  small 
proportion  they  represent  of  the  client  base 
(less than 1%  for the majority of respondents 
to  the  targeted  survey),  as  service  providers 
have a large majority of their clients from both 
nationals and tourists. Furthermore, this cost is 
partially  offset  by 
the  paying  customers 
accompanying  persons  with  disabilities  (such 
as  family  and  friends):  in  the  targeted  survey 
for service providers, 16 out of 23 respondents 
declared  that  persons  with  disabilities  are 
accompanied,  on  average,  by  at  least  one 
person  fully  paying  for  the  organisation’s 
services.205 This cost is estimated at:  
•  254 and 353 million EUR yearly for A2.  

204 World Tourism Organization (UNWTO, Madrid, 2018), European Union Tourism Trends: “EU destinations counted 
608 thousand accommodation establishments in 2016, mostly small and medium-sized enterprises (SMEs)”. Available 
at: link. 
205 Study supporting the impact assessment based on Survey on costs targeted at service providers 

134 

 
 
 
 
 
 
• 

roughly 40 million EUR to 55 million EUR 
yearly for B2  

These are yearly costs for the whole EU. Given 
the number, size, turnover of service providers 
in the EU in the affected sectors, these costs are 
practically negligible and are unlikely to reflect 
into prices. 
Given  the  nature  of  the  policy,  the  options 
would  not  put  at  any  disadvantage  EU  firms 
relative to firms outside the EU, as the tourism 
sector  is  naturally  a  domestic  sector,  and,  as 
such, all firms would be in the same situation. 
Moreover,  the  preferred  policy  options  are 
expected 
terms  of 
international  competitiveness,  by  decreasing 
uncertainty for costumers with  disabilities,  as 
well  as  costs  and  uncertainty  for  service 
providers regarding the validity of the different 
national  IDs.  By  removing  difficulties  in  the 
mobility of persons with disabilities travelling 
to different Member States, the policy options 
can be expected to make the accessible tourism 
market  more  competitive,  with  companies  in 
the  sector  striving  to  attract  tourists  with 
disabilities. 

to  be  beneficial 

in 

In  terms  of  attractiveness  for  international 
tourists, as explained above, the policy options 
are not expected to translate into higher prices, 
given the low overall costs. As such, this will 
not discourage non-EU tourists. 
No  significant  effect  is  expected  in  terms  of 
capacity  to  innovate,  as  this  is  not  strictly 
related  to  neither  of  the  preferred  policy 
options 
SME  competitiveness  is  not  expected  to  be 
to  other 
significantly 
business.  

impacted 

relative 

International 
competitiveness  

+ 

Chapter 6 

Chapter 6 

Chapter 
Annex 3 

6 

Capacity to innovate 

SME competitiveness 

0 

0 

2. Synthetic assessment  

The preferred policy options are not expected to  have significant impacts on competitiveness, nor 
particularly negative effects on SMEs. The policy options are likely to provide a boost in international 
competitiveness  for  business  operating  in  the  tourism  sector,  through  an  increase  in  the  travel 
propensity  of  persons  with  disabilities  from  other  Member  States.  On  the  one  hand,  the  cost  of 
offering preferential conditions to these costumers is minor both in terms of the direct cost and relative 
to the proportion of these costumers in the client base. Moreover, as most service providers report 

135 

 
 
 
 
that persons with disabilities are often accompanied by paying costumers (who are not the personal 
assistants, such as family and friends), the direct cost of the preferential condition might be offset 
immediately  by  higher  turnover.  The  costs  are  not  higher  for  SMEs,  while  the  benefits  could  be 
higher, as these businesses are particularly concentrated in the tourism sector.  

136 

 
 
 
 
ANNEX 6: EVIDENCE FEEDING THE PROBLEM DEFINITION 

1. Disability assessment in the Member States  

National disability cards and certificates are provided to persons with disabilities after an assessment 
of their disability status. Disability assessments are conducted at the national level based on criteria 
and procedures enshrined in provisions of laws.206 Box 1 below includes an overview of the main 
approaches used to undertake disability assessments across the Member States. 

Box 1 – Main approaches to disability assessment207  

•  Medical approach, based on the diagnosed medical condition of individuals; 
•  Barema method, based on impairment tables showing the percentage of disability per type of 

impairment; 

•  Functional  capacity  assessment,  focused  on  functional  limitations  to  performing  certain 

activities; 

•  Care and support needs assessment, based on the degree of the need for external help that the 

individual needs to care for himself/herself due to his/her health issues; 

•  Economic loss assessment, based on the calculation of the loss of income due to the disabilities 

under examination; 

•  Holistic  approach,  based  on  an  assessment  of  impairment,  functional  capacity  and 

environmental factors (e.g. surroundings, social context). 

Source: Study supporting the impact assessment 

Disability status is often assessed based on a combination of two or more methods.  

Table 1 – Member States’ disability assessment methods208  

Source: Study supporting the impact assessment 

206 Lisa Waddington, Mark Priestley and Roy Sainsbury (2018), Disability Assessment in European States.  Academic 
Network of Disability Experts (ANED) Synthesis Report. Available at: link; Silvia Favalli, Delia Ferri (2016), Defining 
Disability  in  the  European  Union  Non-discrimination  Legislation:  Judicial  Activism  and  Legislative  Restraints’. 
European Public Law 22, no. 3 (2016): 541–568. 
207  Lisa  Waddington,  Mark  Priestley  and  Roy  Sainsbury  (2018),  Disability  Assessment  in  European  States.  ANED 
Synthesis Report. Available at: link. 
208 EDF, Disability Assessment and Social Protection. Available at: link; ANED country reports on disability assessment. 
Available at: link. 

137 

Assessment methodsATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKMedical approach ✓✓✓✓✓✓✓Barema method✓✓✓✓✓✓✓✓✓Functionalcapacityassessment✓✓✓✓✓✓✓✓Careandsupportneeds assessment ✓✓Economiclossassessment✓Holistic approach ✓✓✓✓ 
 
 
 
 
Box 2 - Examples of requests for clarification received by SOLVIT 

•  An  Austrian  citizen  travelling  to  Hungary  asking  (i)  if  the  Austrian  disability  card  is 
accepted in Hungary; (ii) information about the type of preferential conditions to which the 
card gives access. The citizen also raised the absence/difficulties to source any information 
about where to use the card, how the card works and the scope of the associated benefits. 
•  Another Austrian citizen travelling to France asking if it will be possible to access France's 

disability benefits using the Austrian card. 

•  A  Slovakian  citizen  travelling  to  Austria  for  tourism  purposes  asking  if  his/her  national 

disability card is accepted in Austria for getting discounts 

•  A  Hungarian  citizen  travelling  to  Croatia  asking  if  his/her  national  disability  card  is 

accepted in Croatia. 

•  A  citizen  asking  if  a  disability  card  from  an  EU  Member  State  gives  one  access  to  free 

public transport and highway tolls benefits in other EU Member States. 

•  A German citizen asking if the German card is accepted in other EU countries and if the 

card from other EU Member States is accepted in Germany. 

•  A German citizen staying in a non-specified EU country asking if it is possible to access 

disability benefits outside Germany using the German card. 

•  A Spanish citizen asking how to use the card both for parking (leaving the card in the parked 
car) and for accessing places (e.g. museum) and preferential conditions (discounts) abroad. 
•  A  Spanish  citizen  travelling  to  the  Netherlands  asking  if  the  Spanish  Disability  Card  is 

accepted in the Netherlands. 

Source: Study supporting the impact assessment based on the SOLVIT platformbased on the SOLVIT 
platform 

2. Statistics on disability (including tourism and travel patterns) 

Figure 1– Shares of EU population by disability and income quintile 2021 

Source: Eurostat data, Study supporting the impact assessment 

138 

 
 
 
  
 
Table 2 - Data on tourism and travel patterns of the general population and persons with 
disabilities  

Member State 

of 
aged 

Share 
persons 
15-64 
participating  in 
tourism, 2012 

Share 
of 
persons  with 
disabilities 
participating  in 
tourism,  2012-
2013 

the 

Gap 
participation  in 
tourism 
between 
general 
population  and 
persons  with 
disabilities, 
2012 

of 
aged 

Share 
persons 
15-64 
participating  in 
tourism, 2019 

Corrected 
number 
of 
persons  with 
disabilities 
travelling, 2019 

Austria 

80.5% 

Belgium 

54.7% 

Bulgaria 

22.0% 

Croatia 

Cyprus 

Czechia 

Denmark 

59.5% 

78.1% 

78.8% 

82.3% 

Estonia 

69.0% 

Finland 

France 

94.4% 

73.5% 

Germany  

82.6% 

Greece 

40.9% 

Hungary 

54.6% 

Ireland 

71.7% 

Italy 

56.9% 

Latvia 

50.5% 

Lithuania 

59.6% 

Luxembourg 

83.0% 

Malta 

The 
Netherlands 

54.6% 

87.5% 

61.1% 

30.7% 

7.8% 

n.a. 

46.2% 

61.8% 

75.5% 

62.0% 

75.5% 

70.7% 

71.6% 

49.5% 

25.7% 

46.2% 

26.0% 

47.4% 

48.7% 

61.4% 

38.2% 

85.7% 

Poland 

54.0% 

22.8% 

19.4 

24.0 

14.2 

n.a. 

31.9 

17.0 

6.8 

7.0 

18.9 

2.8 

11.0 

-8.6 

28.9 

25.5 

30.9 

3.1 

10.9 

21.6 

16.4 

1.8 

31.2 

139 

81.8% 

70.7% 

45.7% 

61.6% 

79.8% 

83.8% 

61.0% 

82.7% 

86.6% 

72.2% 

81.3% 

46.4% 

63.4% 

77.0% 

50.9% 

64.3% 

67.8% 

85.7% 

74.2% 

86.6% 

71.1% 

497,185 

278,866-
492,085 

70,645- 
134,472 

n.a. 

7,186-28,532 

548,149 

182,395 

101,191-
115,245 

283,699 

4,283,903 

4,143,895- 
5,483,607 

561,075 

141,153-
240,039 

128,978 

630,326-
646,354 

101,065- 
132,538 

6,531-103,312 

29,938 

7,419- 12,368 

733,160 

1,152,633-
1,755,226 

 
 
 
Portugal 

39.6% 

Romania 

25.5% 

Slovakia 

Slovenia 

Spain 

Sweden 

EU 27 

59.1% 

71.1% 

55.8% 

n.a. 

64.4% 

34.1% 

11.4% 

29.2% 

42.8% 

49.5% 

75.5% 

58.1% 

5.5 

14.1 

29.9 

28.3 

6.3 

n.a. 

6.3 

51.4% 

32.4% 

78.6% 

75.7% 

76.3% 

76.1% 

69.1% 

372,328 

158,038-
212,683 

244,351 

86,712 

1,248,111- 
2,342,459 

n.a. 

19,334,354 

Source: Study for the impact assessment based on Eurostat data and DG GROW’s report on accessible 
tourism in Europe209 

3. Implementation analysis of the EU Parking Card for persons with disabilities  

Objectives and scope of the EU parking card 

The EU parking card for persons with disabilities (hereinafter referred to as “EU parking card”), also 
known  as  “Blue  Badge”,  was  introduced  in  1998  by  Council  Recommendation  98/376/EC,210  as 
amended by Council Recommendation 2008/205/EC.211 It provides for a standardised model of EU 
parking  card  with  a  view  of  ensuring  its  mutual  recognition  across  the  Member  States,  hence 
facilitating the free movement of persons with disabilities by car (see Box 3).  

 Box 3 – Council Recommendation 98/376/EC: Preamble 3 

Whereas a mode of transport other than public transport constitutes, for many persons with 
disabilities, the only means of getting about independently for purposes of occupational and 
social integration; whereas, in certain circumstances and with due regard to road safety, it is 
only right that  persons with disabilities should be enabled, by means of a parking card for 
such people, to park as near to their destination as possible; whereas persons with disabilities 
should thus have the opportunity to avail themselves of the facilities provided by the said 
parking card throughout the Community in accordance with the national rules applying in 
the country in which they happen to be. 

Source: Council Recommendation 98/376/EC 

The  EU  parking  card  provides  for  various  parking  concessions,  including  free  parking,  extended 
parking, or reserved parking spaces, as established by Member States' specific provision of law. In 
particular, paragraph 3 gives some indications  on who should be  entitled to  the EU parking card, 

209 Economic Impact and Travel Patterns of Accessible Tourism in Europe - Full Report, 08/03/2015. Directorate-General 
for Enterprise and Industry, now known as Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW), European Commission. Available at: link. 
210 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link.  
211 Council Recommendation of 3 March 2008 adapting Recommendation 98/376/EC on a parking card for people with 
disabilities, by reason of the accession of the  Republic of Bulgaria, the Czech Republic, the Republic of Estonia, the 
Republic of Cyprus, the Republic of Latvia, the Republic of Lithuania, the Republic of Hungary, the Republic of Malta, 
the Republic of Poland, Romania, the Republic of Slovenia and the Slovak Republic. Available at: link.  

140 

 
 
 
 
recommending the Member States to grant it ‘to people whose disability leads to reduced mobility’.212 
The introduction of an EU standardised model of the EU parking card guarantees that persons entitled 
to  certain  parking  rights  in  their  Member  State  can  benefit  from  such  advantages  also  in  another 
Member State where they decide to travel.213 In this sense, the Recommendation also foresees that 
full information on the conditions for using the EU parking card should be provided to cardholders.214 
In particular, paragraph 4 recommends Member States to ‘provide, on the basis of a technical fact 
sheet  prepared by the Commission,  an overview of the conditions  of use in  the different  Member 
States of the EU when issuing a parking card to  persons with disabilities and at the request of the 
persons concerned’.215 Moreover, the EU parking card is issued to a named person with recognised 
disability status, rather than to a specific vehicle, so it is transferable to any vehicle the person may 
be using.216 

The  standardised  model  set  out  by  Council  Recommendation  98/376/EC  details  the  dimensions, 
format  and  layout,  which  should  make  the  card  easily  identifiable  across  the  EU,  with  the  most 
recognisable component being the international disability symbol represmj  enting a wheelchair.217 
The Annex to Council Recommendation 98/376/EC entitled “Provisions on the Community-model 
parking  card  for  people  with  disabilities”  provides  for  further  details,  in  particular  with  regard  to 
card’s height, width, colour, material (plastic-coated), the elements that shall be contained (e.g. the 
wheelchair symbol, the expiry date, serial number, specification on the issuing authority, the words 
“Parking card for people with disability” in national language and the words “Parking card” in other 
EU languages, the holder’s personal information, signature and photo, specific statements, etc.) and 
where these elements are to be displayed.218 Moreover, in its preamble, the Recommendation also 
foresees that the Member States should introduce security features to prevent forgery or counterfeiting 
of the parking card.219 

How  successful  was  the  Recommendation  on  the  EU  parking  card  in  ensuring  its  mutual 
recognition  across  the  Member  States  and  facilitating  the  free  movement  of  persons  with 
disabilities in the EU  

Since the adoption of Council Recommendation 98/376/EC in 1998, the EU parking card has been 
adopted in - and is widely used by - all the Member States, as demonstrated by the number of 
valid cards in place (see Table 3 for a general overview on the number of valid EU parking cards or 
the cards issued in a given year and see Figure 2 for a comparison among the number of valid cards 
in  some  of  the  Member  States)  as  well  as  by  the  number  of  consulted  persons  with  disabilities 
claiming to be aware of the card220 and to use it.221 Also the majority of respondents to the public 

212 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 
213 Muñoz, E., Serrano, M., Marqués, A., Ferreras, A., & Solaz, J. (2016, June). SIMON: an ICT proposal for the mobility 
impaired citizens. In 11th ITS European Congress, Glasgow, Scotland (pp. 6-9). 
214 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 
215 Ibid. 
216 European Parliament (2022), Disability assessment, mutual recognition and the EU Disability Card  - Progress and 
opportunities. Available at: link. 
217 Ibid. 
218 Muñoz, E., Serrano, M., Vivó, M., Marqués, A., Ferreras, A., & Solaz, J. (2016). SIMON: assisted mobility for older 
and impaired users. Transportation research procedia, 14, 4420-4429. 
219 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 
220 Study supporting the impact assessment based on Survey targeted at PwD 
221 Ibid. 

141 

 
 
 
 
consultation claimed to be aware of the EU parking card222 and, among those owning the card, to 
make use of it.223 

222 Study supporting the impact assessment 
223 Ibid. 

142 

 
 
 
 
Table 3 – Number of existing EU parking cards per Member State 

Member States224 

Number of cards  

Notes 

AT 

BE 

BG 

CY 
DK 

FI 

FR 

IE 

LT 

LV 

MT 

NL 
PL 
PT 

2022: 100,000 

2021: 472,492  

2019: 16,020 

2023: 9,628 
2023: 130,000 
2018: 14,926  
2019: 15,342  
2020: 14,221  
2021: 14,809  
2022: 17,450 

2017-2018: 630,000 

2022: 120 - 125,000 

2023: 61,953 

2023:14,540 
2017: 9,752 
2019: 10,589 
2020: 8,485 
2021: 11,239 
2022: 13,299 
2023: 13,552 
2023: 213,251  
2022: 277,838 
2023: 59,514 

SE 

2013-2022: 21,933 

Issued since 1 January 2014 

Total  number  of  cardholders  in 

Sofia 

Cards issued in years 2018-2022 

Cards issued between 1 Jan 2017 

and 1 February 2019 

N. of cardholders in the period of 
01/01/2010 -  31/12/2022 

Number  of  cards 

in 
Stockholm in years 2013-2022 

issued 

SI 

2019: 26,763 
2023: 33,291 

Source: Study supporting the impact assessment

224 CZ, DE, EE, EL, ES, HR, HU, IT, LU, RO, SK: no data available. 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 2 – Number of valid EU parking cards per Member State compared to the estimated 
no. of persons reporting “severe” disability225 

1.200.000,00

1.000.000,00

800.000,00

600.000,00

400.000,00

200.000,00

0,00

BE

BG

CY

DK

IE

LT

LU

LV MT

NL

PT

SI

Estimated no. of persons reporting “severe”disability

No. of valid cards

Source: Study supporting the impact assessment based on EUROSTAT data and on data collection 
conducted at the Member State level  

Overall, the adoption of a common EU model has improved the mutual recognition of the card 
across the Member States,226 hence facilitating the free movement of persons with disabilities 
across the Member States, according to 38 out of 87 respondents to the online surveys227 and by 74% 
of  respondents  to  the  Public  Consultation.228  Consistently,  a  survey  conducted  by  the  European 
Disability Forum (EDF)  in  2020 pointed to  the EU parking card as one of the most practical  and 
visible EU initiatives on disability issues. Specifically, the EDF survey confirmed that the EU parking 
card  is  mutually  recognised  across  the  Member  States,  making  travelling  abroad  easier.229  In  this 

225 Error! Reference source not found. provides data limited to twelve Member States as data collected through desk 
research and consultation activities on the no. of persons with disabilities holding the EU parking card is not consistent 
and hardly comparable across the remaining Member States. 
226 Study supporting the impact assessment based on Survey targeted at NCAs Q3.2- Ensuring mutual recognition of the 
card across Member States; Survey targeted at other PAs Q3.2; Survey targeted at EU-level CSOs Q3.1; Survey targeted 
at national CSOs Q3.2 (See annex 2). 
227  Study  supporting  the  impact  assessment  Survey  targeted  at  NCAs  Q3.2  -  Facilitating  the  exercises  of  the  free 
movement rights for persons with disability; Survey targeted at other public authorities Q3.2; Survey targeted at EU-level 
CSOs Q3.1; Survey targeted at national CSOs Q3.2 (See annex 2). 
228 Study supporting the impact assessment 
229 EDF recommendations for strengthening the EU Parking Card 2020. Available at: link.  

144 

 
 
 
 
 
 
respect,  the  majority  of  persons  with  disabilities  consulted  declared  to  use  the  EU  parking  card 
abroad230 and agreed that the card facilitates travels to other Member States.231  

Yet,  the  EU  parking  card  presents  some  shortcomings  due  to  the  fact  that  it  stems  from  a 
provision issued 25 years ago that has so far not been updated and also to its legal nature, i.e. a 
Recommendation which is not binding by nature, thus providing for minimum harmonisation across 
the  Member  States.232  In  line  with  the  principle  of  subsidiarity,  disability  policies  are  mainly 
competence  of  the  Member  States.  Hence,  national  authorities  are  free  to  establish  their  own 
provisions for the functioning  of the EU parking card. More specifically, each Member State  can 
determine the eligibility criteria for obtaining the card (the disability assessment), the management 
system  in  place  and  the  issuing  authority,  which  may  be  local  or  central,  as  well  as  any  further 
elements to be added in the card layout.  

In  addition,  the  Recommendation  does  not  contain  provisions  on  coordination  and  monitoring  of 
Member States. As a consequence, there is little indication of coordination and monitoring actions in 
recent years to improve harmonisation across the Member States.233 The lack of common actions for 
the coordination and monitoring of the EU parking card across the Member States and the margin of 
discretion  allowed  by  the  Recommendation  have  resulted  in  remarkable  differences  across  the 
Member States with regard to the EU parking card’s design, issuing and enforcement rules. In turn, 
even if the EU parking card is widely used and generally recognized across the Member States, such 
differences result in some barriers for persons with disabilities in using the card when travelling to 
another Member State.234 

With  respect  to  the  disability  assessment,  the  Member  States  have  different  rules  in  place 
regarding the eligibility criteria  for obtaining  the EU parking card. Persons with disabilities are 
often  considered  as  part  of  a  single  homogeneous  group,  even  if  in  reality  they  constitute  a 
heterogeneous group of people that differ in age and lifestyles, physical and mental characteristics, 
or travel patterns and transport needs.235 Given that there is not a definite and shared definition of 
disability,  the  Member  States  apply  different  criteria  to  identify  who  is  eligible  to  obtain  the  EU 
parking card. For instance, in some Member States, the EU parking card may be available to everyone 
who has a national disability card, or who appears on a national disability register236 (e.g. RO), thus 
the eligibility criteria for the EU parking card are more broadly interpreted and do not concern only 
mobility impairments. In other cases, the EU parking card may be issued to recipients of disability 
pensions/benefits, or following a specific need assessment (e.g. as part of an assessment for long-
term social care/support). In most cases, as shown in the table below, the EU parking card is granted 
to persons with a disability that implies reduced mobility or impaired vision. Indeed, paragraph 3 of 
the Recommendation suggests that the EU parking card should be granted to a person with a disability 
that leads to reduced mobility.237  

230 Study supporting the impact assessment based on Survey targeted at PwD 
231 Ibid. 
232 EDF recommendations for strengthening the EU Parking Card 2020. Available at: link. 
233 The last Commission request for information to Member States on the implementation of the EU parking card dates 
from 2019 and was discussed in the High Level Group on Disability in 2019.  
234 Do not take my spot! – The EU Disability Parking Card. Available at: link. 
235 Muñoz, E., Serrano, M., Marqués, A., Ferreras, A., & Solaz, J. (2016, June). SIMON: an ICT proposal for the mobility 
impaired citizens. In 11th ITS European Congress, Glasgow, Scotland (pp. 6-9). 
236  European  Parliament  (2022) Disability  assessment,  mutual  recognition  and  the  EU  Disability  Card  -  Progress  and 
opportunities. Available at: link. 
237 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 

145 

 
 
 
 
✓ 

✓ 

✓  ✓ 

✓  ✓ 

✓  ✓  ✓  ✓  ✓ 

Table 4 – Member States’ different eligibility criteria for obtaining the EU parking card238 
  AT  BE  BG  CY  CZ  DE  DK  EE  EL  ES  FI  FR  HR  HU  IE  IT  LT  LU  LV  MT  NL  PL  PT  RO  SE  SI  SK 
Model 
Reduced 
mobility 
Impaired 
vision  
Severe 
disabilities  
Intellectual 
and non-
physical 
disabilities  
Mobility 
restriction 

✓  ✓  ✓  ✓  ✓  ✓  ✓  ✓  ✓  ✓ 

✓  ✓  ✓  ✓  ✓  ✓ 

  ✓  ✓ 

✓  ✓  ✓ 

✓  ✓ 

✓  ✓ 

✓  ✓ 

✓  ✓ 

✓  ✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

Source: Study supporting the impact assessment  

Different  eligibility  criteria  result  in  different  treatment  depending  on  the  country  of  origin 
across  the  Member  States,  thus  causing  confusion  and  frustration  to  persons  with  disabilities  as 
regards their mobility and related rights. In this respect, as also stated by a Member of the European 
Parliament during the event "Do not take my spot! – The European Disability Parking Card", the fact 
that the EU parking card is issued not only to persons with reduced mobility but also to persons with 
other types of disabilities (e.g. mental disabilities) raises confusion about the use of the EU parking 
card.239 In this respect, a representative from an EU-level parking association interviewed claimed 
that, when using the EU parking card, persons with non-visible disabilities (e.g. dementia) often face 
questions from controllers, bystanders and persons with physical disabilities, complaining that the 
parking spot is taken by persons with no physical issues that are still fit to easily access to premises.240 

Moreover,  the  Member  States  have  different  systems  in  place  for  the  management  of  the  EU 
parking card. Indeed, the EU parking card can be issued either by a centralised, decentralised or 
mixed  (authority  management  system)  model,  depending  on  whether  the  designated  authority 
deciding on the eligibility and responsible for the issuance is national or local. In general, the Member 
States with a larger population (DE, ES, IT, RO) tend to adopt a decentralised system, which could 
be  considered  more  efficient  to  process  a  larger  number  of  cards,  while  those  with  a  smaller 
population  (AT,  BE,  CY,  DK,  IE,  LU,  LV,  MT)  generally  adopt  a  centralised  system.241  The 
centralised  model  is  generally  linked  with  lower  risk  of  frauds  and  forgeries  as  compared  to  a 
decentralised model.242 Indeed, centralisation of responsibilities allows greater efficiency in terms of 
both issuing procedures and enforcement capacity against misuse of the card, including checks on the 
card validity.  

In order to get both advantages linked with the centralised and decentralised model, some Member 
States  (EE,  EL,  FI,  FR,  HU,  LT,  SI)  have  decided  to  adopt  a  mixed  model,  where  the  authority 
responsible  for  the  physical  issuance  and  delivery  of  the  card  and  the  authority  in  charge  of  the 
eligibility assessment are identified either at the central or the local levels. The mixed model has also 
led to better control on the uniform implementation of the entitlement criteria, issuance by specialised 
bodies  and  implementation  of  national  databases  with  national  cards  number,  compared  to  the 

238 With ‘severe disability’ is meant amputation of limbs, severe mobility impairment, blindness, etc.  
239 Do not take my spot! – The EU Disability Parking Card. Available at: link. 
240 Targeted interview with one EU Parking association (#3). 
241  European  Commission  (2019)  Parking  card  for  persons  with  disabilities  -  Updated  overview  (shared  by  EC,  not 
published). 
242 Minutes from the EU Disability High Level Group meeting 14 May 2019 – 9.30 to 16.30. Available at: link.  

146 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
decentralised  model.243  Table  5  below  provides  an  overview  of  different  management  systems  in 
place across EU. 

Table 5 – EU parking card management systems  

Source: Study supporting the impact assessment 

Regarding the mixed model, Table 6 below illustrates different approaches adopted across Member 
States. 

Table 6 – EU parking card mixed management systems  

Source: Study supporting the impact assessment  

Differences in the design and in the validity period of EU parking cards issued in the different 
Member States are also present. Annex I to the Recommendation provides for minimum standards in 
terms of design and layout of the EU parking card, but the technological progress since 1998 and the 
non-binding nature of the provision have resulted in increasing differences in the design of the cards 
issued by the Member States, reinforced by a lack of coordination. Differences in the layout of the 
EU parking card sometimes even occur also within a single Member State, when the card is issued at 
the local level (e.g. if the logo of the municipality is included).244 A respondent from the study survey 
targeted at national Civil Society Organisations (CSOs) included as an issue that affects to a high 
extent  the  implementation  of  the  EU  parking  card  the  fact  that  some  of  the  Member  States  have 
different parking card models even in their own regions.245 A further element of complexity is the 
coexistence of older and newer models of cards. For example, since 2017, in France the EU parking 
card  is  progressively  being  replaced  by  a  new  non-EU  model  parking  card,  i.e.  the  CMI  (‘Carte 
mobilité inclusion’), yet both models are currently valid and in use. 

The table below provides some examples of national differences regarding the EU parking card.  

243 European Commission (2019) Parking card for persons with disabilities - Updated overview. 
244 Do not take my spot! – The EU Disability Parking Card. Available at: link. 
245 Study supporting the impact assessment based on Survey targeted at national CSOs 

147 

ModelATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKCentralised✓✓✓✓✓✓✓✓✓✓Decentralised✓✓✓✓✓✓✓✓✓✓Mixed✓✓✓✓✓✓✓ 
 
 
 
 
 
Table 7 – Examples of additional features with respect to the standard EU parking card 

Additional 
security feature 
Barcode 
Hologram 
QR code 
NCF  (‘Near  field 
communication’) 
tag  for  wireless 
detection 
Unique 
(national 
regional) 
Anti-copying 
paper 

number 
or 

AT  BE  DK  ES  FI 

IE 

IT  MT  NL  PL  SE  SK 

✓ 
✓ 

✓ 
✓ 

✓ 

✓ 

✓ 
✓ 

✓ 

✓ 

✓ 

✓ 
✓ 

✓ 

✓ 

✓ 

✓ 

✓ 
✓ 

✓ 

✓ 

✓ 

Source: Study supporting the impact assessment  

Member States have added these features, not originally foreseen in the Recommendation, in 
order to better prevent frauds and forgeries.246 Frauds may consist in the use of a parking card of 
someone else, including a deceased person, or in using both a duplicate card and the original one at 
the same time. In order to tackle this kind of fraud, Belgium added a QR code in the EU parking card 
that can be scanned through an app (‘Handi2park’) used by the police to check their validity. Until 
the end of January 2019, 71,219 EU parking cards had been checked using Handi2park and in almost 
10% of the cases there appeared to be a misuse of the EU parking card. Most of the times, the EU 
parking card of a deceased person was used, or the original card was still used even if a duplicate had 
been issued.  

With respect to forgeries, these occur, for example, when a copy of the EU parking card belonging to 
someone else is used or when the rightful owner makes copies of the EU parking card to use it on 
more than one vehicle simultaneously. Holograms are expressly included on EU parking cards issued 
in Italy, Malta, Slovakia and Sweden to make sure that copies of the card are recognisable, preventing 
possible forgeries. For example, in Malta, in 2022, 110 cards in the car park of an important hospital 
were found to be copies. Also in Sweden, a barcode and hologram have been introduced as copied 
cards were commonly found to be used in vehicles. 

In other countries, no additional features are present on the EU parking card compared to the standard 
model set out in Annex I to the Recommendation, but other actions against fraud and forgery have 
been implemented. For example, in Greece, the Hellenic Police operated a special traffic policing 
operational  programme,  called  "Free  movement  of  citizens  in  cities",  from  September  2019  to 
September  2020.  Each  month,  violations  related  to  parking  on  spaces  reserved  to  persons  with 
disabilities  were  recorded  and  the  number  of  violations  dropped  from  9,531  (period  September-
November 2019) to 1,868 (period September 2020). 

Differences in the layout and design of the EU parking card across the Member States may 
reduce the degree of mutual recognition. Indeed, while the visual format is still easy to recognise 
thanks to the international disability symbol representing a wheelchair, the text displayed on the EU 
parking card is usually printed in the national language of the Member State where the card is issued, 
and the physical dimension does not allow for the inclusion of text in multiple languages. Therefore, 

246 Minutes from the EU Disability High-Level Group meeting 14 May 2019 – 9.30 to 16.30. Available at: link.  

148 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
its meaning is not immediately clear to local authorities or service providers of other Member States 
where the card is used, unless they can understand the text written in a foreign language.247  
Several  respondents  to  the  online  surveys  confirmed  that  national  differences  in  terms  of  validity 
period248  and  design249  hinder  the  mutual  recognition  of  the  card,  thus  negatively  affecting  its 
implementation  across  the  Member  States.  Moreover,  7  out  of  8  CSOs  and  14  out  of  19  NCAs 
participating in the workshops claimed that national differences in terms of design and functioning 
of the EU parking card hinder its mutual recognition across the Member States.250 Furthermore, 3 out 
of 15 persons with disabilities consulted during the survey confirmed to have faced problems linked 
to the non-recognition of their EU parking card in another Member State,251 as well as the majority 
of respondents to the Public Consultation.252 From 2018 to 2022, around 30 enquiries were submitted 
thought he SOLVIT platform to raise issues about fines received even when showing the EU parking 
card. In particular, in two complaints, cardholders stated that their French parking card had not been 
recognised by local parking authorities abroad as it does not follow the EU model, which resulted in 
one case in a fine with the car being taken away and in the other case in denial to park in the special 
parking space for persons with disabilities close to an airport entrance. 

Another issue affecting the mutual recognition of the EU parking card is the different rights and 
benefits granted across the Member States. The EU parking card is, indeed,  used differently and 
may  give  right  to  different  benefits  depending  on  the  Member  State  issuing  it,  which  may  create 
confusion when travelling to another Member State.  

Table 8 – Examples of national differences in the rights granted by the EU parking card 

Member 
States 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 

Reserved 
parking 
spaces 

Parking on 
roads where it 
is generally 
prohibited253 

Free 
parking in 
paid 
parking 
areas 

No time 
limit 
parking in 
areas 
subject to 
time limits 

Parking in 
pedestrian 
zones 

✓ 
✓ 
✓ 
✓ 
✓ 
✓ 

✓ 
✓ 

✓ 
✓255 
✓ 
✓ 

✓ 

✓ 
✓ 
✓ 
✓ 

✓ 

✓ 
✓ 
✓ 
✓ 

✓254 
 ✓256 

247  European  Parliament  (2022) Disability  assessment,  mutual  recognition  and  the  EU  Disability  Card  -  Progress  and 
opportunities. Available at: link.  
248  Study  supporting  the  impact  assessment  based  on  Survey  targeted  at  NCAs;  Survey  targeted  at other  Pas;  Survey 
targeted at EU-level CSOs; Survey targeted at national CSOs 
249  Study  supporting  the  impact  assessment  based  on  Survey  targeted  at  NCAs;  Survey  targeted  at other  Pas;  Survey 
targeted at EU-level CSOs; Survey targeted at national CSOs 
250 Study supporting the impact assessment based on Respondents to the online workshop with CSOs held on 22 March 
2023; Respondents to the online workshop with NCAs held on 23 March 2023 
251 Study supporting the impact assessment based on Survey targeted at PwDs.  
252 Study supporting the impact assessment based on Public Consultation (standard questionnaire) 
253 If not causing obstructions. 
254 Allowed only in individual cases and if urgently necessary. 
255 Allowed for maximum 15 minutes. 
256 Allowed only if explicitly allowed by local concessions and during the specified times. 

149 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Reserved 
parking 
spaces 

Parking on 
roads where it 
is generally 
prohibited253 

Free 
parking in 
paid 
parking 
areas 

Member 
States 

Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 

✓ 

✓ 
✓ 

✓ 
✓ 
✓ 
✓ 
✓ 

✓ 
✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓259 
✓ 
✓260 

✓261 

No time 
limit 
parking in 
areas 
subject to 
time limits 
✓ 
✓ 
✓ 

Parking in 
pedestrian 
zones 

✓257 

✓ 

✓ 

✓ 

✓ 

✓258 

✓ 

✓ 
✓ 

✓ 

✓ 

✓262 

Source: Study supporting the impact assessment 

In the survey, 8 out of 25 NCAs,263 4 out of 5 other public authorities,264 11 out of 23 national CSOs,265 
7 out of 10 of EU-level CSOs266 and 10 out of 24 persons with disabilities267 believe that national 
differences  in  terms  of  rights  granted  by  the  card  is  an  issue  to  a  high  or  very  high  extent  to  the 
implementation of the EU parking card. Moreover, from 2018 to 2022, around 80 enquiries about the 
rights  granted  by  the  EU  parking  card  across  the  Member  States  were  submitted  on  the  SOLVIT 
platform,  demonstrating  uncertainty  as  to  mutual  recognition.  In  many  cases,  persons  used  the 
platform to ask how they can use their EU parking card when visiting another Member State. For 
example, a French citizen holding the card asked what rights are granted by the EU parking card in 
Czech Republic. Similarly, a Hungarian cardholder asked if in Vienna (AT) he could park without 
paying  as  he  is  allowed  to  do  in  his  home  country  showing  the  EU  parking  card.  In  around  70 
enquiries, persons with disabilities, or someone on their behalf, simply asked if the EU parking card 
is  actually  recognized  across  the  Member  States.  For  example,  an  Italian  cardholder  travelling  to 

257 Allowed only if explicitly allowed by local concessions and during the specified times. 
258 Allowed only in spaces marked with a wheelchair symbol. 
259 Allowed for maximum 3 hours. 
260 Allowed only in case of absolute necessity, for a short time and without obstructing other vehicles or pedestrians. 
261 Allowed for maximum 3 hours. 
262 Allowed for maximum 3 hours. 
263 Study supporting the impact assessment based on Survey targeted at NCAs 
264 Study supporting the impact assessment based on Survey targeted at other public authorities 
265 Study supporting the impact assessment based on Survey targeted at national CSOs  
266 Study supporting the impact assessment based on Survey targeted at EU-level CSOs 
267 Study supporting the impact assessment based on Survey targeted at PwDs  

150 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Vienna (AT) asked if there was the need to communicate to the Austrian authorities the possession 
of the EU parking card, to prevent possible fines. 

Box 4 - Examples of complaints received by SOLVIT on the EU parking card 

•  A  French  cardholder  asked  what  rights  are  granted  by  the  EU  parking  card  in  the  Czech 
Republic; a Hungarian cardholder asked if in Vienna (AT) he could park without paying as he 
is allowed to do so in his home country, showing the EU parking card.  

•  An Italian cardholder travelling to Vienna (AT) asked if there was a need to communicate to 
the Austrian authorities the possession of the EU parking card to prevent possible fines. 

•  A Danish cardholder complained about a fine received in Portugal for not paying when parking 
in a space reserved to persons with disabilities, arguing that in Denmark payment is not due 
when showing the EU parking card. 

• 

In  two  other  cases,  cardholders  complained  that  their  French  parking  card  had  not  been 
recognised  by  local  parking  authorities  abroad,  as  it  does  not  follow  the  EU  model,  which 
resulted in one case in a fine with the car being taken away and in the other case in denial to 
park in the special parking space for persons with disabilities close to an airport entrance. 

Source: Study supporting the impact assessment based on the SOLVIT platform 

As a consequence, national differences in the EU parking card result in some difficulties in the 
exercise offreedom of movement for persons with disabilities. Indeed, non-recognition of the EU 
parking card might result in practical disadvantages, such as not being able to park near the entrance 
of premises. Limited recognition of the EU parking card across the Member States is considered an 
issue linked to its implementation to a high or very high extent by 13 out of 25 respondents of the 
survey targeted at NCAs,268 2 out of 5 other public authorities,269 9 out of 23 national CSOs,270 6 out 
of 10 EU-level CSOs271 and 11 out of 24 persons with disabilities.272 

This issue has been recently confirmed by a study conducted for the European Parliament, claiming 
that whether they are tourists, cross-border workers, job seekers or residents, persons with disabilities 
frequently encounter different criteria and procedures that are applied to disability assessments and 
to consequent parking entitlements or benefits granted across the Member States, negatively affecting 
the  exercise  of  their  freedom  of  movement.273  Also,  as  anecdotal  evidence,  the  lack  of  mutual 
recognition was pointed out by a petition sent in 2015 by a British citizen to the European Parliament, 
stating that his/her EU parking card issued in the UK was not recognised in Spain, his/her country of 
residence, resulting in several fines.274  

According to the respondents of the survey targeted at persons with disabilities, the issues affecting 
the implementation of the EU parking card mostly hinder their ability to easily access different 

268 Study supporting the impact assessment based on Survey targeted at NCAs 
269 Study supporting the impact assessment based on Survey targeted at other public authorities 
270 Study supporting the impact assessment based on Survey targeted at national CSOs 
271 Study supporting the impact assessment based on Survey targeted at EU-level CSOs 
272 Study supporting the impact assessment based on Survey targeted at PwDs 
273  European  Parliament  (2022) Disability  assessment,  mutual  recognition  and  the  EU  Disability  Card  -  Progress  and 
opportunities. Available at: link. 
274 Petition No 0590/2015 by M.G.S. (British) concerning the problems he is facing in Spain due to the use of a parking 
card for people with disabilities issued in the UK. Available at: link. 

151 

 
 
 
 
premises275 and to fully exercise their right to mobility in the EU.276 Respectively 14 out of 23 
national CSOs and 5 out of 10 EU-level CSOs responding to the survey agreed that these issues hinder 
to a high or very high extent mostly the ability to easily access different premises.277 At the same 
time, 13 out of 23 national CSOs and 5 out of 10 EU-level CSOs, together with 9 out of 25 NCAs 
and 3 out of 5 other public authorities, also believe that the issues affecting the implementation of the 
EU parking card might increase to a high or very high extent the administrative burden/burden of 
obtaining information about the different parking conditions for persons with disabilities.278 During 
a interview conducted with a representative of a EU Parking association,279 it has been highlighted 
that also frauds and forgeries of the EU parking card have a strong impact on the ability of persons 
with disabilities to easily access different premises, as persons using fake EU parking cards take away 
the  spaces  reserved  to  persons  with  disabilities.  Similarly,  in  an  enquiry  submitted  through  the 
SOLVIT  platform  in  2021,  a  German  person  with  disability  complained  that  he  was  seeing  a 
disproportionate amount of EU parking cards issued by the Czech authority and claimed that, in his 
opinion, a case of large scale abuse was taking place, hindering his right to find a free parking lot 
reserved to persons with disability.  

Is the EU parking card still needed? 

Since  its  introduction,  the  EU  parking  card  proved  to  be  still  relevant,  being  one  of  the 
instruments available to persons with disabilities to facilitate their free movement, as shown by 
the number of valid EU parking cards in place (see 7 above) and the high percentage of consulted 
persons with disabilities claiming to be aware of the EU parking card280 and to use it281. Moreover, 
according to the surveys, 19 out of 25 NCAs, 4 out of 5 other public authorities, 19 out of 23 national 
CSOs and 9 out of 10 EU-level CSOs believe that the EU parking card is still relevant to meet the 
current  needs  of  persons  with  disabilities.282  According  to  different  stakeholders  (NCAs,  CSOs, 
parking associations) consulted in  the interviews and workshops,  persons  with  disabilities tend to 
prepare  their  trip  carefully  when  they  travel,  as  they  need  to  make  sure  of  the  accessibility  and 
conditions offered in the premises and services they will use. 

Yet, it should be highlighted that the EU parking card originates from a Recommendation adopted in 
1998, almost 25 years ago, and which has never been updated to meet new developments and needs. 
Council Recommendation 2008/205/EC,283 which amended Council Recommendation 98/376/EC,284 
did not substantially revise the provisions of the EU parking card, but only extended them to the new 
Member States adhering to the EU at that time (i.e. BG, CY, CZ, EE, HU, LT, LV, MT, PL, SI and 
SK). There is some evidence that some of the Recommendation’s provisions are not up to date 

275 Study supporting the impact assessment based on Survey targeted at PwDs 
276 Study supporting the impact assessment based on Survey targeted at PwDs 
277 Study supporting the impact assessment based on Survey targeted at EU-level CSOs 
278 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public authorities; 
Survey targeted at EU-level CSOs; Survey targeted at national CSOs 
279 Study supporting the impact assessment based on Targeted interview with one EU Parking association 
280 Study supporting the impact assessment based on Survey targeted at PwDs 
281 Ibid. 
282 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public authorities; 
Survey targeted at EU-level CSOs; Survey targeted at national CSOs 
283 Council Recommendation of 3 March 2008 adapting Recommendation 98/376/EC on a parking card for people with 
disabilities, by reason of the accession of the  Republic of Bulgaria, the Czech Republic, the Republic of Estonia, the 
Republic of Cyprus, the Republic of Latvia, the Republic of Lithuania, the Republic of Hungary, the Republic of Malta, 
the Republic of Poland, Romania, the Republic of Slovenia and the Slovak Republic. Available at: link. 
284 98/376/EC: Council Recommendation of 4 June 1998 on a parking card for people with disabilities. Available at: link. 

152 

 
 
 
 
and  aligned  with  the  latest  developments  and  issues  affecting  persons  with  disabilities  when 
travelling in the EU, as well as with their needs and habits. On this point, there is an increase both 
in the number of persons with disabilities desiring to travel in the EU and in the frequency of their 
travels, thus confirming the relevance of an EU parking card that is mutually recognised across the 
Member States.285 According to a representative from an EU-level parking association interviewed, 
to make sure that they will have a parking space at destination, some persons with disabilities prefer 
to reserve a private garage in case they cannot count on the availability of parking for persons with 
disabilities in the street.286 

Moreover, new and emerging technological developments are increasingly (mis)used to develop 
increasingly sophisticated forgery and fraud mechanisms, as also confirmed by additional security 
features progressively included by the Member States in the card’s design (see Table 7 in previous 
section). According to the survey, the majority of respondents agree that specific security features 
added to the EU model by some Member States (e.g. holograms, QR codes, barcodes, etc.) on the 
parking card are effective to tackle frauds287 and forgeries.288 On this point, a representative from an 
EU-level parking association interviewed pointed out that misuses of the EU parking card are a major 
problem as they prevent persons with disabilities to access certain services and to participate to social 
life.289 The interviewee explained that enforcers in charge of checking the validity of the EU parking 
card are not always aware of how a real EU parking card looks like, since there is no cross-national 
database on parking cards’ design or on parking cards’ holders. Hence, the interviewee highlighted 
that  the  current  paper  copy  solution  is  not  in  line  anymore  with  the  progress  of  technology  that 
exposes the EU parking cards to more and more sophisticated frauds and forgeries. According to a 
representative of another EU-level parking association interviewed, frauds and forgeries of the EU 
parking  card  could  be  easily  prevented  by  introducing  a  digital  format  of  the  card.  However,  the 
interviewee pointed out that moving to a digital way of enforcing the EU parking card entails the risk 
of not having the physical card on the car, which might lead other people to think that the car is parked 
illegally.290  

285 Gonda, T. (2021). Travelling Habits of People with Disabilities.  GeoJournal of Tourism and Geosites, 37(3), 844–
850. Available at: link.  
286 Study supporting the impact assessment based on Targeted interview with one EU Parking association 
287 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public authorities; 
Survey targeted at national CSOs; Survey targeted at EU-level CSOs 
288 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public authorities; 
Survey targeted at national CSOs; Survey targeted at EU-level CSOs 
289 Study supporting the impact assessment based on Targeted interview with one EU Parking association 
290 Ibid. 

153 

 
 
 
 
Moreover,  a  parking  association  representative  noted  that  the  paper-based  card  is  not  in  line 
anymore with how parking rights are controlled, as this is done more and more digitally, checking 
the car license plates in a national or local database. An increasing number of Member States use the 
ANPR (automatic number-plate recognition), as in the Netherlands, where an automatic camera picks 
the car plate number to recognize it and the system uses a database to check who has a parking right 
in that spot. However, the camera does not necessarily pick up the information on the ownership of 
an EU parking card, unless the physical parking card has a particular technology in it (e.g. NFC). So, 
persons with disabilities end up getting fines even if they have a right of parking in a specific space.291 
According to the interviewee, in the future there will be the need for a fraud-proof EU parking card 
and a database solution that will allow to check whether a vehicle is linked to an EU parking card or 
not.292 

In this regard, 6 out of 7 CSOs and 13 out of 19 NCAs participating to the workshops agreed that an 
update of Council Recommendation 98/376/EC, and in particular of its Annex I, would be necessary 
to  update  the  format  of  the  card  in  order  to  avoid  fraud  and  forgery  and  address  new  ways  of 
controlling parking rights.293  

The SIMON project, funded by the Competitiveness and innovation Framework Programme, aimed 
at enhancing the EU parking card through digital technologies to allow contactless and mobile user 
identification, with a view of reducing risks of fraud and issues related to data privacy (see Box 5).294  

Box 5 – The SIMON project  

The project consisted in four large-scale pilots in Madrid (ES), Lisbon (PT), Parma (IT) and 
Reading (UK), with the objective to use Information and Communication Technologies (ICT) 
services  to  promote  the  independent  living  and  societal  participation  of  persons  with 
disabilities in the context of public parking areas and other transport modes. The two main 
challenges addressed by the project were the reduction of frauds in the use of the EU parking 
card  and  the  proposal  of  specific  multimodal  navigation  solutions  for  elderly  people  and 
persons  with  disabilities.295  The  project  demonstrated  the  potential  of  new  technological 
solutions to improve the effectiveness  of the EU parking card, facilitate free movement of 
persons with disabilities and reduce fraud. More specifically, new technologies were explored 
to identify innovative tools and appropriate information services to users of the EU parking 
card  as  well  as  to  overcome  difficulties  in  collecting  reliable  information  about  parking 
accessibility.296 For example, with the development of the SIMON project, it has been proven 
that  a  digital  format  for  the  EU  parking  card  would  allow  easier  checks  on  its  validity, 
reducing  frauds,  and  would  help  to  overcome  the  issues  linked  to  the  EU  parking  card 
recognition in different languages.297 

Source: Study supporting the impact assessment 

How coherent is the EU parking card with other EU policies  

This section aims at understanding the extent to which the EU parking card is coherent with other EU 
policies in the field of free movement, disability and social rights. 

291 Ibid. 

154 

 
 
 
 
 
As far as free movement rights are concerned, the coherence assessment looked at the consistency 
between  the  EU  parking  card  and  Directive  2004/38/EC  on  free  movement.298  The  preamble  of 
Directive 2004/38/EC specifies that, according to the prohibition of discrimination contained in the 
EU Charter of Fundamental Rights, Member States should ensure the free movement of EU citizens 
across  all  the  Member  States  without  discrimination  on  grounds,  among  others,  of  disability.299 
Likewise, the preamble of Recommendation 98/376/EC states that, together with the promotion of 
the mutual recognition, the aim of the EU parking card is to facilitate the freedom of movement of 
persons with disabilities. Hence, the Recommendation proved to be coherent with and supports the 
goal of Directive 2004/38/EC on free movement which, in turn, takes into account non-discrimination 
against persons with disabilities. 

With  respect  to  EU  disability  policies,  the  assessment  looked  at  the  consistency  between  the  EU 
parking card and the pilot EU Disability Card implemented in eight Member States (i.e. BE, CY, 
EE, FI, IT, MT, RO and SI). More specifically, it investigated whether the issuing authorities, the 
eligibility criteria and the rights granted by the pilot EU Disability Card in these Member States are 
coherent with those in place for the EU parking card in the same countries.

292 Ibid. 
293 Study supporting the impact assessment based on Respondents to the online workshop with CSOs held on 22 March 
2023 and to the online workshop with NCAs held on 23 March 2023. 
294 Muñoz, E., Serrano, M., Marqués, A., Ferreras, A., & Solaz, J. (2016, June). SIMON: an ICT proposal for the mobility 
impaired citizens. In 11th ITS European Congress, Glasgow, Scotland (pp. 6-9). 
295 Muñoz, E., Serrano, M., Vivó, M., Marqués, A., Ferreras, A., & Solaz, J. (2016). SIMON: assisted mobility for older 
and impaired users. Transportation research procedia, 14, 4420-4429. 
296 Muñoz, E., Serrano, M., Marqués, A., Ferreras, A., & Solaz, J. (2016, June). SIMON: an ICT proposal for the mobility 
impaired citizens. In 11th ITS European Congress, Glasgow, Scotland (pp. 6-9). 
297  European  Parliament  (2022) Disability  assessment,  mutual  recognition  and  the  EU  Disability  Card  -  Progress  and 
opportunities. Available at: link.  
298 Directive 2004/38/EC of the European Parliament and of the Council of 29 April 2004 on the right of citizens of the 
Union and their family members to move and reside freely within the territory of the Member States amending Regulation 
(EEC)  No  1612/68  and  repealing  Directives  64/221/EEC,  68/360/EEC,  72/194/EEC,  73/148/EEC,  75/34/EEC, 
75/35/EEC, 90/364/EEC, 90/365/EEC and 93/96/EEC. Available at: link.  
299 Ibid. 

155 

 
 
 
 
Table 9 – Comparison between the EU Disability Card and the EU parking card in the Member States participating to the pilot project 

Member 
State 

Elements 
of 
comparison 

EU Disability Card 

EU Parking Card 

Issuing authority 

FPS Social Security 
Vlaams  Agentschap  voor  Personen  met  een  Handicap 

(VAPH) 

Agence pour une Vie de Qualité (AViQ) 
Service  Personne  Handicapée  Autonomie  Recherchée 

(Phare) 

Dienststelle für Selbstbestimmtes Leben (DSL) 

Public Service Social Security. 

BE 

Eligibility criteria 

for persons with disabilities. 

Children receiving increased child benefit. 

Persons recognised by or receive help from an official institution 

Persons with a permanent disability of 50% or more 
(disability of the legs) or of 80% or more (other 
invalidity); 

War invalid (civil or military) with a disability of 50% 

or more; 

Persons completely paralyzed on the arms or if both 

arms have been amputated; 

Persons with reduced self-reliance or mobility 

Rights granted 

Making activities, such as sports events, museum visits and other 

leisure activities, more accessible. 

Parking and traffic rights. 

Issuing authority 

Department for Social Inclusion of Persons with Disabilities.  

CY 

Eligibility criteria 

Cypriot and EU citizens with disabilities who have a permanent 
residence in the area controlled by the Republic of Cyprus for 
at least consecutive 12 months; 

Persons  with  disabilities  with  recognised  refugee  status  or 
supplementary  protection  status,  in  accordance  with  the 
Refugee Law. 

Department  for  Social  Inclusion  of  Persons  with 

Disabilities. 

Cypriot and EU citizens with disabilities who have a 
permanent residence in the area controlled by 
the Republic of Cyprus for at least consecutive 
12 months;  

Persons  with  disabilities  with  recognized  refugee 
status  or  supplementary  protection  status,  in 
accordance with the Refugee Law; 

Organisations  that  provide  care  to  persons  with 

disabilities. 

“Persons with disabilities” for the purposes of issuing 
Parking card means:  
Persons  whose  disability  involves  amputation  or 
severe  weakness  of  the  upper  and/or  lower 
limbs  due  to  any  cause,  and  as  a  result  the 
person with disability has a permanent degree 
of disability of 39% or more; 

156 

 
 
 
 
 
 
Member 
State 

Elements 
of 
comparison 

EU Disability Card 

EU Parking Card 

Rights granted 

It ensures equal access to some specific benefits in the field of 
culture, tourism, entertainment, sports and transports. 

Parking and traffic rights. 

Persons with disabilities according to the provisions 
of  the  law  for  special  allowance  for  blind 
persons,  severe  motor  disability  allowance 
scheme, care allowance for quadriplegic people, 
care allowance for paraplegic persons; 

Persons with intellectual disabilities; 
Persons that undergo heamodialysis. 

Issuing authority 

National Social Insurance Board. 

EE 

Eligibility criteria 

All  persons  with  disabilities  that  have  a  disability  certificate 
issued  by  Social  Insurance  Board  (degree  and  type  of 
disability and duration of disability). 

Rights granted 

Benefits (not specified). 

Issuing authority 

Kela (an independent social security institution supervised 

by the Finnish Parliament).  

Persons with a disability allowance; 
Pensioners with a care allowance; 
Persons  with  speech,  hearing  and  vision  impairment  with  an 
to 

the  person  entitled 

interpreter  assistance  and 
accompanying them; 

FI 

Persons  with  a  mobility  assistance  provided  under  the  Social 

Eligibility criteria 

Welfare Act; 

Persons cared for by an informal caregiver and their caregiver; 
Persons with a travel companion service and the person entitled 

to accompanying them; 

Persons with assisted living under the Act on Services for Persons 
with  Disabilities  and  the  person  entitled  to  accompanying 
them; 

157 

Issuing authority: National Social Insurance Board.  
Persons with disabilities who has assessed severe, 
profound or moderate degree of movement or 
vision function disability; 

Persons  with  temporary  movement  or  vision 

function deviation;  

Persons  with  a  mobility  disability  and  people 
servicing  persons  with  a  mobility  disability  or 
blind persons 

Parking and traffic rights. 

Finnish Transport and Communications Agency. 

Persons  with  disabilities  resulting  from  an  illness, 
problem  or  disability  preventing  the  individual 
from walking and the disability category for this 
impairment is 11 or higher; 

Persons  with  disabilities  resulting  from  impaired 
vision. Visual acuity in the better eye can be a 
maximum  of  0.1  or  overall  eyesight 
corresponds to disability category 17; 

Persons with a permit for transporting a person with 
serious  disabilities  if  the  said  person  requires 
regular  transport  and  cannot  manage  without 
an escort after transportation. 

 
 
 
 
Member 
State 

Elements 
of 
comparison 

EU Disability Card 

EU Parking Card 

Persons  with  personal  assistance  and  the  person  entitled  to 

accompanying them. 

Rights granted 
Issuing authority 

Disability allowance, care allowance and interpreter assistance. 

INPS (National Institute of Social Security) 

IT 

Eligibility criteria 

50% if deriving from the workplace; 

Persons with accompanying allowance; 
Blind persons; 
Deaf persons. 

Persons  with  disabilities  from  67%  to  100%  disability  or  from 

Parking and traffic rights. 
Municipality of residence. 
Persons with significantly reduced walking ability; 
Blind persons. 
For a period of less than five years, therefore for a 
limited period, the card can be released also to:  
Persons  with  temporary  impaired  walking  ability 
due to injury or other pathological causes;  
Persons  with  total  absence  of  any  functional 
autonomy  and  with  the  need  to  continuous 
assistance, to go to places of care. 

Rights granted 

Issuing authority 

Free access or discounts to access national museums and other 

cultural premises. 

Commission  for  the  Rights  of  Persons  with  Disability 

(CRPD). 

Parking and traffic rights. 

Aġenzija Sapport. 

MT 

Eligibility criteria 

A person has to meet the definition of disability as defined by the 
Equal Opportunities (Persons with Disability) Act (EOA) 2000. 
The  EOA  defines  disability  according  to  the  definition  of 
disability in Article 2 of the UNCRPD. 

158 

Persons who are entitled to the European Disability 
Card  and  have  severe  and  permanent  or 
temporary mobility impairment; 

Persons  with  a  permanent  visual  impairment,  not 
exceeding 6/60 in the better eye, or who have 
a visual limitation preventing them from seeing 
from  an  angle  of  at  least  20  degrees  (tunnel 
vision)  and  who  use  a  motor  vehicle  on  a 
regular basis; 

Persons who have a severe permanent impairment 

who drive a car regularly; 

Persons  who  have  permanent  and  severe  physical 
impairment which prevents them from walking 
or  who  do  so  with  great  difficulty  or  for those 
whom  any  effort  at  walking  would  be 
detrimental  to  their  lives  on  account  to  their 
impairment  and  who  makes  use  of  a  motor 
vehicle on a regular basis; 

 
 
 
 
 
Member 
State 

Elements 
of 
comparison 

EU Disability Card 

EU Parking Card 

Rights granted 

Free access and discounts to cultural and touristic destinations. 

Issuing authority 

National  Authority  for  the  Protection  of  the  Rights  of 

Persons with Disabilities.  

Parking and traffic rights. 
Local public authority. 

Persons  with  a  severe  mental  impairment  or  who 
exhibit  severe  challenging  behaviour  and  who 
require frequent  assistance and/or supervision 
during  the  day  and  night  and  who  use  of  a 
motor vehicle on a regular basis. 

RO 

Eligibility criteria 

Children  and  adults  with  severe,  accentuated,  medium  or  light 
disabilities,  based  on  a  valid  disability  certificate.  Only 
persons who have a disability certificate are allowed to hold 
the Card. 

Children who hold a Disability Certificate issued by 
the  decision  of  the  Commission  for  child 
protection, 
its  validity 
(document  within 
period);  

Adults who hold a Disability Certificate issued by the 
Disability Advice Board or, as the case may be, 
a Decision issued by the Superior Commission 
for  the  Evaluation  of  Adult  Persons  with 
its  validity 
Disabilities,  (document  within 
period); 

Their  legal  representatives  (the  parent  or  the 
person  designated,  according  to  the  law,  to 
exercise  the  rights  and  fulfil  the  obligations 
towards  the  person  with  disabilities),  on 
request, can use a card for free parking spaces. 

Rights granted 

Free or partially subsidized access for people with disabilities to 

cultural, sporting and leisure events. 

Issuing authority 

Local administrative offices. 

Parking and traffic rights. 

Local administrative offices. 

SI 

Eligibility criteria 

Persons  with  recognised  disability  based  on  the  Equalisation  of 
Opportunities for Persons with Disabilities Act Citizens of the 
Republic  of  Slovenia  with  permanent  residence  in  the 
Republic of Slovenia or foreigners with permanent residence 
in the Republic of Slovenia; 

Persons  with  Disabilities  I.,  II.  and  III.  categories  under  the 
Pension  and  Disability  Insurance  Act  (all  workers  with 
disabilities - decisions based on Act); 

Persons  who  have  suffered  from  at  least  60% 
physical impairment due to loss, malfunction or 
paralysis of the lower or upper limbs or pelvis;  

Persons with multiple sclerosis;  
Persons with muscular and neuromuscular disorders 
least  30%  physical 

with  estimated  at 
impairment;  

159 

 
 
 
 
 
 
Member 
State 

Elements 
of 
comparison 

EU Disability Card 

EU Parking Card 

Persons with recognised physical impairment (PI): around 90% 
PI due to loss of vision, around 70% PI due to hearing loss 
or at least 80% PI, if the PI is cumulative and the minimum 
percentage for one PI is at least 70% (Pension and Disability 
Insurance Act - physical impairment decisions); 

Persons with intellectual disabilities who have been 
granted  disability  according  to  the  regulations 
on the protection of persons with physical and 
mental disabilities;  

Persons with at least 90% physical impairment due 

Persons  with  disabilities  according 

the  Vocational 
Rehabilitation  and  Employment  of  Disabled  Persons  Act 
(Decision by Employment Service of Slovenia); 

to 

Recognised status of a Persons with Disabilities according to the 
Act  Regulating  the  Training  and  Employment  of  Disabled 
Persons  (Decision  by  Employment  Service  of  Slovenia); 
Status  acquired  under  the  Act  Concerning  Social  Care  of 
Mentally  and  Physically  Handicapped  Persons  (Decisions by 
Centre  for  Social  Work  or  rarely  by  Pension  and  Disability 
Insurance Institute of Slovenia). 

Various discounts - like entry ticket to a museum or better access 

to attractions at a theme park. 

Rights granted 

to visual loss;  

Minors who have physically or mentally disability or 
are  reduced  mobility  due  to  lower  limbs  or 
pelvis related impairments; 

Health  services,  social  services  and  disability 
organizations,  whose  workers  visit  home  care 
workers  because  of  urgent  and  unavoidable 
services needed for their health and life. 

Parking and traffic rights. 

Source: Study supporting the impact assessment

160 

 
 
 
Overall, the issuing authorities of the pilot EU Disability Card and of the EU parking card are 
the same only in Cyprus and Estonia. The pilot EU Disability Card seems to be issued mostly 
by central authorities, also in countries where the management model of the EU parking card 
is  decentralised (i.e.  IT  and RO), apart from Slovenia where both  cards  are  issued by local 
administrative offices. 

In terms of eligibility criteria, overall, those to obtain the EU parking card are more specific 
than those for the EU Disability Card. For example, the criteria in place in Estonia and Italy 
for  obtaining  the  EU  parking  card  are  linked  to  mobility  impairment  and  motor  disability. 
Furthermore,  in  Italy,  the  EU  parking  card  might  be  granted  also  in  case  of  a  temporary 
impairment of walking ability of the person, contrarily to the EU Disability Card that assumes 
a permanent disability status. In other cases, as in Romania, the eligibility criteria for obtaining 
the two cards are quite similar, with the exception that the EU parking card might be granted 
also to the legal representative that uses the car to accompany a person with disabilities. This 
is further proved by the responses to the survey targeted at NCAs, where 15 out of 25 NCAs 
affirmed that the eligibility criteria for obtaining  a disability card, if present in the Member 
State, are not the same as the ones for obtaining the EU parking card.300 Moreover, 4 of these 
respondents explicitly stated that the eligibility criteria in place for the EU parking card are 
stricter with respect to the ones for the disability card.301 

Then, for what concerns the rights granted, the two cards seem to be complementary and the 
rights granted to cardholders are not overlapping. Indeed, in general, the EU Disability Card 
often grants free access or discounts in the sector of culture, leisure, sport and public means of 
transport, while the EU parking card gives rights related to parking (e.g. reserved parking slots, 
free parking, parking without time limit) and traffic (e.g. the possibility to circulate in limited 
traffic zones). 

With regard to the coherence with social rights, in 2017, the European Parliament, the Council 
and  the  Commission  proclaimed  the  European  Pillars  of  Social  Rights,  a  list  of  20  key 
principles aimed at building a fair, inclusive and full of opportunity EU.302 

The  rights  of  persons  with  disabilities  are  taken  into  account  by  Principle  n.  3  on  equal 
opportunities, which claims: “Regardless of gender, racial or ethnic origin, religion or belief, 
disability,  age  or  sexual  orientation,  everyone  has  the  right  to  equal  treatment  and 
opportunities regarding employment,  social protection, education, and access  to  goods and 
services  available  to  the  public”  and  by  Principle  n.  17,  which  is  specifically  addressed  to 
persons  with  disabilities,  claiming  that  “people  with  disabilities  have  the  right  to  income 
support that ensures living in dignity, services that enable them to participate in the labour 
market and in society, and a work environment adapted to their needs”. 

These two principles are in line with the preamble of Council Recommendation introducing 
the EU parking card, which reads “all people with disabilities should be entitled to additional 
concrete measures aimed at improving their occupational and social integration” and “a mode 
of transport other than public transport constitutes, for many people with disabilities, the only 
means  of  getting  about independently for  purposes of  occupational  and social integration”. 

300 Study supporting the impact assessment based on Survey targeted at NCAs  
301 Study supporting the impact assessment based on Survey targeted at NCAs 
302 European Pillars of Social Rights. Available at: link. 

161 

 
 
 
 
Therefore, it is possible to conclude that the EU action towards the promotion of social rights 
is  coherent  with  the  objective  of  Recommendation  98/376/EC  to  improve  accessibility  for 
persons with disabilities and to promote their rights and equality of opportunity. 

On  the  other  hand,  the  EU  is  also  committed  to  making  Europe  the  first  climate  neutral 
continent in the world through the European Green Deal, a set of proposals to make all sectors 
of the EU’s economy fit to reach climate targets in a fair, cost effective and competitive way.303 
One of the target of the European Green Deal is to transition to greener mobility offering clean, 
accessible and affordable transport everywhere, in particular by halving the emissions of cars 
and  vans  by  2030.  However,  as  stated  in  Recommendation  98/376/EC,  private  vehicles  are 
often the main means of transport used by persons with disabilities to move independently. 
Thus, in order to allow persons with disabilities to make sustainable choices such as preferring 
rail  travel  rather  than  using  a  private  car,  it  is  key  to  make  public  transportation  means 
accessible and affordable for everyone.304 

How cost-efficient was the implementation of the EU parking card 

This section aims at understanding whether the introduction of the EU parking card has been 
efficient  for  the  Member  States  and  stakeholders  in  terms  of  proportionality  of  costs  and 
benefits, also compared to a situation in which different national parking cards had continued 
to  be  used.  In  order  to  evaluate  the  efficiency  of  this  instrument,  expected  benefits  are 
understood as the capability of the EU parking card to improve the free movement of persons 
with disabilities and the expected costs are understood as the cost for Member States, public 
authorities and parking managers to implement and monitor the use of the EU parking card. 

Overall,  the  EU  parking  card  for  persons  with  disabilities  proved  to  be  an  efficient  policy 
initiative. Indeed, although 11 out of 25 NCAs and 3 out of 5 other public authorities claimed 
that the EU parking card entails costs for national authorities in charge of managing and issuing 
the card in the Member States,305 39 out of 63 respondents to the online surveys believe that 
the benefits linked with the adoption of the EU parking card for persons with disabilities have 
overcome the related costs.306  

Finally,  no  specific  information  could  be  found  on  the  costs  of  implementation  of  the  EU 
parking card, but considering that the Recommendation dates from 1998, it can be assumed 
that implementation costs have been offset as the costs of issuing new cards with the EU model 
should now be incorporated in the business-as-usual costs. Yet, there is some evidence that 
national  differences  in  the  design  and  implementation  of  the  EU  parking  card  contribute  to 
increasing overall costs. Specifically, as reported by the representative of an EU-level parking 
association interviewed, the increasing divergences in the design of the EU parking card across 
the Member States have raised the need to provide parking controllers with ad-hoc trainings on 
the different types of cards in place.307  

303 The European Green Deal. Available at: link.  
304 European Disability Forum (2019) An inclusive Green Deal for Europe. Available at: link. 
305 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public 
authorities  
306 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public 
authorities; Survey targeted at national CSOs; Survey targeted at EU-level CSOs 
307 Study supporting the impact assessment based on Targeted interview with one EU Parking association 

162 

 
 
 
 
What  is  the  EU  added  value  of  the  EU  parking  card  compared  to  keeping  different 
national parking cards 

Despite  its  shortcomings,  the  EU  parking  card  improved  mutual  recognition,  as  its  visual 
standard is easy to recognise for everyone and the results of the EU intervention in this specific 
policy area suggest that such EU model could spill over to other areas that need harmonisation 
across the EU. 

Most  respondents  to  the  online  survey  agreed  that  the  EU  parking  card  for  persons  with 
disabilities provides greater benefits than if different parking cards had continued to be used.308 
Similarly, a survey conducted by the EDF in 2020 showed that the EU parking card is seen as 
one  of  the  most  practical  and  visible  EU  initiatives  on  disability  issues.  In  particular,  the 
respondents to the survey believe that the EU parking card is successfully recognised across 
the Member States, making travelling abroad easier.309 In addition, 14 out of 24 persons with 
disabilities consulted in the context of the survey declared to use the EU parking card when 
travelling abroad310 and agreed that the card facilitates travels to other Member States.311 

A  representative  from  an  EU-level  parking  association  interviewed  agreed  that  the  EU  can 
bring  added  value  also  in  the  future  developments  of  the  EU  parking  card.  Indeed,  in  the 
interviewee’s view, this instrument should be updated with digital components, and this is a 
field where the EU can bring added value with very concrete solutions, making at disposal of 
the  Member  States  the  technological  knowledge  to  help  this  process  of  innovation  and 
digitalisation. The interviewee, further added that further developments of the EU parking card 
could  take  inspiration  from  other  initiatives  such  as  the  European Car and  Driving 
licence Information System  (Eucaris),312  an  exchange  mechanism  that  connects  the  national 
vehicle and driving licence registration authorities in Europe to support the fight against car 
theft  and  registration  fraud,  since  some  countries  (e.g.  Netherlands)  are  already  enforcing 
parking rights  by controlling  the car plates  against  a database of car owners, and  an option 
could be to register the EU parking card with the car.313 

308 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other public 
authorities; Survey targeted at national CSOs; Survey targeted at EU-level CSOs 
309 EDF recommendations for strengthening the EU Parking Card 2020. Available at: link. 
310 Study supporting the impact assessment based on Survey targeted at PwDs. 
311 Study supporting the impact assessment based on Survey targeted at PwDs 
312 Eucaris. Available at: link. 
313 Study supporting the impact assessment based on Targeted interview with one EU Parking association 

163 

 
 
 
 
 
4. Mapping of services providing preferential conditions in the EU 

Most common preferential conditions offered to persons can be discerned into the following 
categories: 

•  Monetary support; 
•  Grants; 
•  Other type of support. 

Given that scope of the initiative is focused on short-term stays in other Member States, the 
analysis focused on monetary and other support. This is because the grants category (applying 
typically to adaptation of housing but which may – in a handful of cases – also cover adaption 
of vehicles, including rental cars) is predominantly accessed by  persons with disabilities who 
reside permanently or long-term in a given Member State. 
With regards to monetary support, this category covers price reduction or free access to events 
or  specific  services  and  is  largely  provided  for  accessing  public  transport  services,  cultural 
events,  leisure,  and  sport  services,  as  well  as  for  entering  amusement  parks.  Moreover, 
monetary  support  includes  also  exemptions,  i.e.  persons  with  disabilities  are  freed  from  an 
obligation  or  liability  imposed,  such  as  paying  for  particular  services  (e.g.  certain  taxes, 
electricity or telecommunications services). 
The price reduction can start at a 10% entrance fee/ticket price discount all the way to a 100% 
discount.  In  some  countries,  while  a  person  with  disability  receives  “only”  a  certain  price 
reduction,  their  personal  assistant  may  use  the  services  for  free.  For  example,  in  Slovakia 
national rail transport providers provide a 60% price reduction for the holder of the national 
disability card, while those who’s national disability card assigns them personal assistants are 
provided also with a free transportation of the assistant, wheelchairs, a stroller for an immobile 
child and/or a guide dog. 
Member States also offer exemptions for persons with disabilities across some services. Some 
of these types of preferential  treatment  are offered by sectors  and services less relevant  for 
short-term stays (e.g. by electricity service providers). However, a few exemptions are offered 
in e.g. the tourism sector, which may be deemed a key sector for the purposes of this initiative. 
Box 6 provides examples of the types of monetary support provided in some Member States. 

Box 6 – Examples of monetary support provided in some Member States 314 

In Austria, parents of children with disabilities receive a school travel allowance to ensure 
the child can access transport to and from school regardless of the distance between 
the home and the school. 

In Croatia, exemptions are in place for:  

Paying the annual fee for the use of public roads and the tolls for the use of motorway 
Paying the tourist tax. 

In Cyprus, persons with reduced mobility and persons with visual or hearing disabilities 
are exempted from the fixed charges for particular telecommunication products and 
services. Furthermore, in the tourism sector persons with disabilities may make use of 
beach  parasols  and  sunbeds  for  free  for  up  to  10%  on  the  total  number  of  beach 
sunbeds per arranged beach (contact with the Municipal and Village Authorities in 
advance is needed). 

314 Study supporting the impact assessment  

164 

 
 
 
 
 
In the Czech Republic, telecommunication providers may provide a price reduction that 
the operator’s “loss” amounts to a maximum of CZK 200 (ca EUR 8.50) loss including 
VAT per customer per month. The providers can determine in what form they will 
provide  benefits.  Therefore,  they  offer  special  tariffs  for  fixed  and  mobile  lines  (or 
internet) to the eligible persons with disabilities. If the applicant for a discounted tariff 
is  a  minor,  the  person  who  is  their  legal  representative  is  entitled  to  establish  a 
discounted tariff. 

In Estonia, on certain dates persons with disabilities have free access to cultural activities 
while during the rest of the year they are entitled to a price reduction in entrance fees. 
In Germany, Lufthansa offers persons with severe disabilities, a reduction in the air fare 
on domestic German flights with Lufthansa and the regional airlines under certain 
conditions. Lufthansa and the regional carriers also carry the accompanying person 
of  a  person  with  severe  disability  with  identification  mark  B  on  domestic  German 
flights free of charge. Furthermore, persons with disabilities are entitled to a free use 
of taxis if the trip is necessary for a medical appointment. It has to be granted and 
approved by the insurance company beforehand. 

The Greek postal services transport, free of charge, postal items weighing up to 7 kg, sent 
from/to  blind  or  severely  visually  impaired  persons  (i.e.  80%  disability)  or  from/to 
institutions/associations for the blind. 

In  Romania,  persons  who  have  a  handicap-adapted  car  are  exempt  from  paying  road 
taxes. Furthermore, they may access all matches organised by the Romanian Football 
Association as prescribed by law. 

Source: Study supporting the impact assessment 

Other support offered in the Member States is very varied in terms of scope and covers many 
sectors. The support may include access  to  braille, audio  guides etc., or specialised support 
within the job recruitment  sector. Miscellaneous support may also  include commitments by 
specific  sectors  to  serve  persons  with  disabilities  before  other  customers.  Box  7  provides 
examples of the types of preferential conditions provided in some Member States. 

Box 7 – Examples of other support provided in some Member States 315 
In Belgium, persons with disabilities visiting amusement parks have access to: 

Free audio/visual guides 
Explanatory brochures or leaflets adapted to meet different needs (in Braille lettering 

or easy to read for example)  

Adapted guided visits (in sign language for example).  
Reserved accessible parking areas  
Priority lines for easier access to attractions.  

In the Czech Republic, persons with disabilities have the right to be served without joining 
the queue if this action requires a longer wait, especially standing. Personal discussion 
of  matters  is  not  considered  to  be  shopping  in  shops  or  procuring  paid  services,  or 
treatment and examination in medical facilities. 

In Cyprus, persons with disabilities can more easily be hired to the public sector, provided 
that  the  number  of  persons  with  disabilities  hired  under  the  relevant  law  does  not 
exceed 7% of the total number of employees in Public Service.  

315 Study supporting the impact assessment 

165 

 
 
 
 
In  Greece,  the  "My  Work"  platform  helps  persons  with  mental  disabilities  to  find 
employment.  Furthermore,  in  accordance  with  “Rights  of  citizens  and  businesses  in 
their  dealings  with  public  services”  persons  with  disabilities  who  attend  all  public 
services of the country must be served on a priority basis. 

In Italy, there are various projects in place to promote social and work inclusion via the 
provider  Agenzia  Nazionale  Disabilità  e  Lavoro  (ANDEL),  which  is  a  not-for-profit 
agency. 

In Luxembourg, persons who are recognised  to be living with disabilities should receive 
offers  of  employment  that  take  into  account  the  disability  in  question,  either  on  the 
ordinary  labour  market  or  in  a  sheltered  environment.  Human  assistance  is  also 
available for people with visual or hearing impairments. 

Source: Study supporting the impact assessment 

In some Member States (e.g. BE, DK), preferential conditions are offered also to personal 
assistants, predominantly to support persons with disabilities to accessing public transport or 
cultural  events.  For  example,  in  Malta  some  service  providers,  particularly  providers 
overseeing  touristic  attractions,  may  decide  to  offer  free  entrance  or  other  preferential 
conditions  to  personal  assistants  of  their  choice.  In  Estonia,  preferential  conditions  for 
assistants differ across the various sectors. For example, in public transportation the assistant 
of  persons  with  visual  impairments  rides  free  of  charge  while  when  visiting  a  theatre,  the 
assistants pay 50% of the price.  
The analysis indicates that there is limited consistency in the types of preferential conditions 
offered across the Member States. The assessment found commonalities across the Member 
States regarding reduced costs for persons with disabilities in a few key sectors. These most 
common preferential treatment types allow persons with disabilities to access:  

•  Selected public transport systems; 

•  Parking spaces; 

•  Cultural events, in particular museums in the Member States; 

•  Leisure centres and sport centres.  

However,  the  extent  to  which  preferential  treatment  is  applied  across  these  services  is  not 
uniform – in some Member States the preferential treatment applies to some public transport 
services and not all (e.g. France), and access to museums may refer to all or to a few selected 
institutions. Therefore, the preferential treatment cannot be concluded to be universal even in 
Member States that offer reduced costs on a mandatory basis. It is also relevant to point out 
that  monetary  support  alone  does  not  indicate  a  complete  removal  of  barriers  for  travel. 
Reduced or free entry also needs to be physically accessible in order to be exercised by persons 
with disabilities. 
Table 10 below provides a complete overview of preferential conditions offered per Member 
State and per service sector.

166 

 
 
 
 
Table 10 – Overview of the types of preferential conditions offered to persons with disabilities across the Member States 

Source: Study supporting the impact assessment

167 

ServicesATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKPublic transportPrivate transportParkingBusiness servicesFacilities managementAdvertisingRecruitment servicesServices to commercial agentsServices provided both to business and consumersReal estate servicesDistributive tradesOrganisation of trade fairsCar rentalTravel agenciesServices in the field of tourismLeisure servicesSports centresCultural servicesAmusement parksSupply of electricityTelecommunicationPostal ServicesMonetary supportOther type of support BothNon.a.Legend 
 
 
 
 
 
▪  Residents with disabilities  

In  most  Member  States,  preferential  conditions  to  residents  with  disabilities  are  offered  in  the 
following services:316 

•  Public and private transport; 
•  Leisure and sport; 
•  Parking; 
•  Amusement parks; 
•  Tourism; 
•  Sport, leisure and cultural services; 

Whether preferential conditions are offered on a voluntarily or mandatory basis depends on 
both the type of services and providers concerned. More specifically, preferential conditions are 
usually provided on a voluntary basis for the majority of services.317 Services for which preferential 
conditions are often provided on a mandatory basis include public transport and parking services, as 
well  as  recruitment  services,  supply  of  electricity  and  gas,  as  well  as  postal  services  and 
telecommunication.318  Finally,  for  some  services  (e.g.  cultural  services,  tourism),  preferential 
conditions are sometimes provided on both voluntary and mandatory basis, depending on the specific 
service provider.  
Even when granted on a mandatory basis, preferential conditions may be still not universal, i.e. they 
are offered only by some providers within the concerned sector (e.g. in France, reduced tickets apply 
to some public transport services and not to all).319 On the other hand, in Malta, public entities are 
obliged to offer preferential services to EU Cardholders as the National Disability Card is a gateway 
card for government services. 
Further complexity is observed in some Member States, such as Austria and Italy, where regional and 
local  legislation  provides  for  additional  preferential  conditions  besides  those  granted  based  on  a 
mandatory basis at the national level.320  
In order to obtain preferential conditions, persons with disabilities are generally requested to 
show a national disability card or certificate. Yet, exceptions apply across the Member States. For 
instance, in Hungary, where preferential conditions are offered on a voluntarily basis, in addition to 
the national disability certificate some service providers ask for a card certifying membership of a 
disability  CSO.  In  the  Netherlands,  preferential  conditions  for  using  public  transport  services  are 
offered to holders of the public transport assistance card, which is obtained through an assessment 
procedure.321  
Table 11 below provides an overview of services for which preferential conditions are offered across 
the  Member  States  to  residents  with  disabilities,  along  with  information  on  the  nature  of  such 
conditions, i.e. whether they are offered on a mandatory or voluntary basis.

316 Study supporting the impact assessment  
317 Ibid.  
318 Ibid. 
319 Ibid. 
320 Ibid. 
321 Persons with disabilities from other Member States holding a card with similar conditions, this will be accepted as 
equal to the Dutch card.  

168 

 
 
 
 
Table 11 – Mapping of services for which preferential condition are offered to residents with disabilities across the Member States 

Source: Study supporting the impact assessment 

169 

ServicesATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKPublic transportPrivate transportParkingBusiness servicesFacilities managementAdvertisingRecruitment servicesServices to commercial agentsServices provided both to business and consumersReal estate servicesDistributive tradesOrganisation of trade fairsCar rentalTravel agenciesServices in the field of tourismLeisure servicesSports centresCultural servicesAmusement parksSupply of electricityTelecommunicationPostal ServicesYes (mandatory)Yes (voluntary)Yes (both)Yes (not specified)Non.a.Legend 
 
 
 
 
 
▪  Non-residents with disabilities  

Regarding preferential conditions offered also to persons with disabilities from other Member 
States, available information is very limited and mostly consists of anecdotal evidence. Yet, the data 
collection undertaken at the Member State level still provides some interesting information. Overall, 
in most Member States (e.g. CZ, EL, IE, IT, LU, LV, NL, PT, SK, SE), most service providers offer 
preferential conditions to persons with disabilities from other countries on a voluntary basis. 
Only in few Member States (e.g. FI) all preferential conditions offered to residents are also provided 
to non-residents with disabilities. In Greece and Lithuania, non-residents with disabilities can access 
for free various archaeological areas and use public transport by demonstrating their disability card.322  
Furthermore, in the eight Member States that participated in the pilot EU Disability Card (i.e. 
BE,  CY,  EE,  FI,  IT,  MT,  RO,  SI),  preferential  conditions  are  offered  to  all  persons  with 
disabilities from these eight countries. However, there are differences and exceptions also among 
these  countries.  For  instance,  in  Estonia,  all  persons  with  disabilities  can  access  preferential 
conditions when using culture, leisure, sports, and transport services, regardless of their country of 
origin. On the contrary, in Malta, the Malta Public Transport only offers preferential conditions to 
holders of the EU Disability Card marked with ‘MT’. 
In some Member States, (e.g. BE, CY, HR, PL, PT, SE), preferential conditions are offered also to 
assistants of persons with disabilities from other Member States.  
To conclude, survey results confirm that there is very limited offer of preferential conditions to non-
residents as compared to residents with disabilities.323  
Table 12 below provides for an overview of the preferential conditions offered to non-residents with 
disabilities. 

322 Study supporting the impact assessment 
323 Study supporting the impact assessment based on Survey targeted at NCAs; Survey targeted at other relevant public 
authorities; Survey targeted at NCAs; Survey targeted at other relevant PAs 

170 

 
 
 
 
 Table 12 – Mapping of services for which preferential condition are offered to non-residents 
with disabilities across the Member States 

Source: Study supporting the impact assessment 

Box  8  –  cases/examples  of  difficulties  in  accessing  preferential  conditions  in  other  Member 
States  

Three German citizens with disabilities pointed out that: 

- They experienced difficulties in accessing preferential conditions for using trains or local public 
transport  when  travelling  across  the  EU  as  their  national  disability  cards  were  not  accepted 
abroad.[this partially overlaps with the next sentence - could one of the two sentences be skipped/both 
be merged?]  

- Their national disability card was not accepted when they travelled to Italy and Luxembourg. 

- They experienced difficulties in accessing preferential conditions for using cultural services (e.g. 
museums, cultural events) when they travelled to France as their national disability cards were not 
accepted there. 

- They stated that their national disability card was not accepted when travelling to Hungary, hence 
they could not access public transport discounts. 

A Hungarian citizen with disabilities stated that his national disability card was not accepted during 
travels for short-term stays in at least seven Member States (AT, CZ, DE, DK, FR, PL, SK). 

Three  Austrian  citizens  with  disabilities  stated  that  their  national  disability  cards  are  often  not 
accepted  when  they  travel  to  other  Member  States,  hence  they  are  often  asked  for  additional 
documents to prove their disability status abroad.  

171 

ServicesATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKPublic transportPrivate transportParkingBusiness servicesFacilities managementAdvertisingRecruitment servicesServices to commercial agentsServices provided both to business and consumersReal estate servicesDistributive tradesOrganisation of trade fairsCar rentalTravel agenciesServices in the field of tourismLeisure servicesSports centresCultural servicesAmusement parksSupply of electricityTelecommunicationPostal ServicesYesNon.a.Legend 
 
 
 
 
 
 
 
Two Austrian citizens with disabilities specified that their national disability cards were not accepted 
for accessing tourist facilities in Germany.  

Two persons with disabilities from Slovakia indicated that their national  disability cards were not 
accepted  when  they  tried  to  enter  museums  or  to  buy  transport  tickets  in  other  Member  States. 
Particularly, one of them specified that his national disability card was not accepted when he travelled 
to  Czech  Republic,  thus  he  could  not  access  discounts  for  public  transport,  ending  up  to  pay  the 
transport ticket at a full price.  

A French person with disabilities stated that preferential conditions to access museums in Spain are 
denied to non-residents with disabilities. 

A  Latvian  person  with  disabilities  reported  that  his  national  disability  card  was  not  accepted  for 
receiving  discounts  when  using  public  transport  in  Italy  as  well  as  when  entering  museums  in 
Denmark. 

The national disability card of a Polish person with disabilities was not recognised when he travelled 
to Croatia. The same happened to a Romanian person with disabilities that travelled to Hungary as 
well as to a Belgian resident with disabilities that travelled to Spain for tourism purposes.  

The  national  disability  card  of  a  Belgian  person  with  disabilities  was  not  accepted  in  France, 
particularly when he used French railways, or when accessing French museums. 

 A  blind  person  [which  nationality?]  complained  that  his  disability  certificate,  which  contains  a 
printed blind person's pictogram, was not accepted when he travelled across the EU, and particularly 
to Czech Republic and Slovakia.  

A  Belgian  public  authority  confirmed  that  non-residents  with  disabilities  cannot  benefit  from 
preferential conditions granted to Belgian citizens with disabilities when using trains in Belgium, nor 
can their personal assistants travel free of charge on the same basis as personal assistants of Belgian 
citizens with disabilities. 

Other  two  NCAs  from  Member  States  that  participated  in  the  EDC  pilot  project  reported  to  have 
received  a  high  number  of  complaints  from  cardholders  as  their  EDC  was  not  accepted  in  other 
Member States that did not take part in the pilot.324 

Source: Study supporting the impact assessment 

324 Study supporting the impact assessment based on Workshop with NCAs held on 23 March 2023.  

172 

 
 
 
 
 
 
 
 
 
 
ANNEX 7: INTERVENTION LOGIC, AND MONITORING 

Table 1 - Intervention logic linking problems, drivers, specific objectives and policy options  

Specific 
Objectives 
SO1: To facilitate 
mutual recognition 
of disability status 
when persons with 
disabilities travel 
to or visit other 
Member States. 

Problems 

Drivers 

access 

1.  When persons with 
disabilities 
travel 
to  or  visit  other 
States, 
Member 
to 
their 
preferiental 
conditions 
including 
those 
related  to  services 
is  hampered 
as  
disability 
their 
not 
is 
status 
recognised. 

is 

of 

limited 
A.  There 
acceptance  across  the 
EU 
national 
disability  cards  and 
certificates  of  non-
residents 
with 
disabilities  issued  by 
other Member States. 

Insufficient 
A.1 
awareness 
and 
knowledge  of  different 
national 
disability 
cards and certificates 

A.2  No  obligation  to 
accept 
limited 
and 
voluntary 
acceptance 
of  national  disability 
cards and certificates 

2.  When travelling by 
the  EU, 
in 
car 
with 
persons 
disabilities 
face 
difficulties in using 
their  EU  parking 
card.  

National 
B. 
the 
in 
divergences 
implementation  of  the 
EU  parking  cards  for 
persons 
with 
disabilities. 

SO2: To facilitate 
use and legal 
certainty in the use 
of the EU parking 
card for persons 
with disabilitie. 

173 

Policy options 

A1: To introduce an EDC 
in  all  Member  States 
on  a  mandatory  basis 
by  means  of  an  EU 
legislative  act,  which 
provides  for  mutual 
recognition 
of 
disability  status  of 
with 
persons 
disabilities  that  travel 
for  short-term  stays 
(up  to  three  months) 
in  the  EU  limited  to 
the  culture, 
leisure,  
sport and transport. 
A2: To introduce an EDC 
in  all  Member  States 
on  a  mandatory  basis 
by  means  of  an  EU 
legislative  act,  which 
provides  for  mutual 
recognition 
of 
disability  status  of 
persons 
with 
disabilities  that  travel 
for  short-term  stays 
(up  to  three  months) 
in the EU. 
To 

B1: 
Recommendation 
98/376/EC with a view to 
facilitating 
mutual 
recognition  of  the  EU 
parking card; 
B2: 
To 
Recommendation 
98/376/EC  with  an  EU 
legislative  act,  which 
provides 
for  mutual 
recognition  of  national 
parking cards for persons 

amend 

repeal 

 
 
 
 
 
Problems 

Drivers 

Specific 
Objectives 

Policy options 

with  disabilities,  based 
on a common EU model.  

Table 2 – Monitoring indicators for the preferred policy option 

Specific 
objectives 

Operational 
objectives 

Indicators 

Sources 
data 

of 

Number 
transposed the Directive to date 

of  Member  States 

having 

that 
with 

Ensure 
persons 
disabilities 
recognised 
in 
another  country 
have  access  to 
preferential 
conditions   

Ensure  that  the 
application 
systems  is  user 
and 
friendly 
accessible 
for 
potential 
beneficiaries 

Facilitate  social 
integration  and 
of 
travelling 
persons 
with 
disabilities 

Increase 
availability 
preferential 
conditions 
persons 
disabilities 

the 
of 

to 
with 

facilitate 

To 
mutual 
recognition  of 
disability status 
when  persons 
with 
disabilities 
travel to or visit 
other  Member 
States  

Number  of  complaints  linked  to  the  EDC 
(reported  by  persons  with  disabilities, 
service providers, including on fraud and/or 
forgery)  

Transposition 
checks 

Level of satisfaction with the EDC perceived 
increased  wellbeing  and  integration,  higher 
cultural,  sports,  leisure  participation  and 
higher mobility, etc. 

Number  and 
share  of  persons  with 
disabilities  (overall  and  those  travelling  in 
the EU for short term stays) 

Costs  for  service  providers  and  national 
Authorities  

Number  of  the  EDC  issued  by  Member 
States 

Member 
States’ 
data 
(National  and 
Local 
Authorities) 

SOLVIT 
platform 
complaints 

ad 

Potential 
hoc 
survey/study 

174 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To 
facilitate 
use  and  legal 
certainty  in  the 
use  of  the  EU 
parking 
card 
for 
persons 
with 
disabilities. 

that 
with 

Ensure 
persons 
disabilities 
recognised 
in 
another  country 
the 
use 
can 
parking facilities 

Facilitate 
the 
enforcement  of 
rules  related  to 
parking 
rights 
for  persons  with 
disabilities  

Ensure  that  the 
application 
systems  is  user 
and 
friendly 
accessible 
for 
potential 
beneficiaries 

(Common 
both 
objectives)  

to 
specific 

Improve 
information  on 
how  to  get  and 
use the European 
Disability  Card 
and 
the  EU 
parking card. 

Number of complaints as to cases of lack of 
recognition of the EU parking Card (reported 
by  persons  with  disabilities  and/or  national 
Authorities) 

Member 
States’ 
data 
(National  and 
Local 
Authorities) 

SOLVIT 
platform 
complaints 

ad 

Potential 
hoc 
survey/study 

ad 

Potential 
hoc 
survey/study 

Member 
States’ 
data 
(National  and 
Local 
Authorities) 

Number and type of reported cases of fraud 
or forgery of the European Parking Card 

Number of revised parking cards issued by 
Member States 

Costs for national Authorities 

%  of  people  who  are  satisfied  with 
information provided  

The  number  of  websites  containing  the 
information how to get and use the cards and 
their accessibility  

Frequency  of  use  of  the  section  of  Your 
Europe portal providing information on the 
EU  parking  card  (e.g.  yearly  number  of 
visitors of these websites)   

Number  and  scale  (participation,  turnout, 
duration,  funding)  of  awareness  raising 
campaigns  

175 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Number  of  European  Disability  Cards/EU 
parking  card  applications  (through  national 
application  procedures),  and  issued  in  each 
Member State  

Some of the proposed indicators will be fed with information whose collection is already foreseen by 
the policy options, such as the number of persons applying for the EDC or the number of the EU 
parking  card  holders.  Others  may  require  the  design  of  new  data  collection  mechanisms  or  the 
integration of existing EU surveys, such as EU-SILC.  

ANNEX 8: IMPACTS OF THE POLICY OPTIONS 

Policy options aimed at facilitating mutual recognition of disability status in the 
EU in relation to access to services when visiting another Member State 

Table  1  –  Comparative  overview  of  impacts  and  related  ratings  for  the  effectiveness  and 
efficiency criteria 

Type  

Baseline 

A1 

A2 

of impacts  

Social  

• 

• 

travel 

gap 
points) 

(6.3 
The 
of 
percentage 
Persons  with  disabilities 
compared  to  the  general 
population  will 
remain 
constant 
The  level  of  uncertainty 
regarding the availability of 
preferential 
conditions 
offered 
to  Persons  with 
disabilities  when travelling 
the  EU  Member 
across 
States will remain high  

•  Reduction  of  the  travel  gap 
for  Persons  with  disabilities: 
and  1.94 
between  1.32 
percentage points 

•  Reduction  of  the  travel  gap 
for  Persons  with  disabilities 
of  between  2.8  and  4.12 
percentage points 

•  Removal 

to 

of 
the  access 

uncertainty 
related 
to 
preferential  conditions  as  all 
benefits  currently  offered  to 
residents  with  disabilities  in 
the 4 sectors covered will be 
offered  also  to  non-residents 
with disabilities travelling for 
short-term stays 

•  Removal 

to 

of 
the  access 

uncertainty 
related 
to 
preferential  conditions  as  all 
benefits  currently  offered  to 
residents  with  disabilities 
will  be  offered  also  to  non-
residents  with  disabilities 
travelling for short-term stays 

Economic  

Public authorities:  

Public authorities: 

Public authorities: 

•  Cost: 

The 

cost 

of 
Production  and  delivery  of 
the EDC: between 1.02 and 
4.54  EUR  per  card  for 
participating 
Member 
States. 

•  Cost:  Launch 

of 

an 

awareness-raising 
campaign:  between  a  total 
of 20,000 and 70,000 EUR.  

•  Cost:  Production  of 

the 
physical 
Similar 
EDC: 
estimates  to  those  identified 
for 
the  baseline  scenario. 
These  estimations  might  be 
even  lower  given  that  the 
common  EDC  format  would 
reduce design costs 

•  Cost: Establishment of an IT 
system  for  the  digital  EDC: 
1.67  million  EUR  for  the 
whole EU 

• 

Same costs as A1 as concern 
production  and  delivery  of 
the EDC 

•  Benefit:  Time  savings  as  no 
requests for clarifications are 
expected considering that all 
benefits  currently  offered  to 
residents  with  disabilities 
will  be  offered  also  to  non-
residents  with  disabilities 
travelling for short-term stays 

176 

 
 
 
 
 
for  participating  Member 
States. 

Persons with disabilities: 

•  Cost:Economic  loss  ranges 
per short-term trip: between 
30 and 140 EUR 

•  Cost: Economic loss ranges 
between  100  to  400  EUR 
for short term trips (4-days) 
and  between  100  and  140 
EUR  for  medium  trip  (2 
months)325 
Service providers: 

•  Cost:Time delays and extra 
burdens  associated  with 
checking 
different 
the 
national  disability  cards  or 
certificates  to  verify  the 
proof of disability status 

Impact on the whole economy 

• 

Foregone  benefit  of  not 
closing the travel gap in the 
whole  EU  in  2023:  4.5 
billion EUR (upper bound)  

Environmental 

•  Negligible impact 

•  Cost:  maintenance  of  an  IT 
system  for  the  digital  EDC: 
249,757 EUR per year for the 
whole EU 

•  Costs  related  to  request  for 
clarifications  received  from 
Persons  with  disabilities  that 
ask  whether  some  services 
fall within the four sectors in 
scope of EDC 
Persons with disabilities 

•  Benefit:  Savings  for  Persons 
with 
range 
disabilities 
between  30  to  140  EUR  per 
short-term  trip  (4-days),  and 
100 to 400 EUR per medium-
term trip (2 months). 

Service providers: 

• 

The  total  yearly  costs  in  the 
transport sector are estimated 
to range between 116 and 161 
million  EUR  at  EU  level, 
accounting for only 0.05% to 
0.08%  of  the  turnover  of 
(non-air)  passenger  transport 
in  the  whole  EU-27.  As  the 
transport sector is one of  the 
most  exposed  sectors  to  the 
preferential 
offer 
for 
conditions, 
offering 
preferential 
conditions  in  relation  to  the 
services of other sectors (e.g. 
culture,  sports)  would  be 
even lower. Also, most of the 
service  offer  non-monetary 
benefits. 

the  costs 

of 

•  Benefit:  increased  turnover 
from 
customers 
paying 
travelling  with  persons  with 
disabilities326 

Impact on the whole economy 

•  Value added in the market for 
accessible 
the 
estimates  range  from 1.32  to 
1.94  billion  EUR,  increased 
tax revenues 

tourism: 

•  Negligible 

impact 

on 
environmental 
footprint 
estimated in a range of 200 to 
640 tonnes of CO2 equivalent 

Persons with disabilities 

•  Benefit:  savings  at  least  the 
same  as  A1,  but  including 
also  preferential  conditions 
the  extra  A2 
present 
sectors 

in 

Service providers: 

•  Cost:  The  estimated  direct 
cost  of  offering  preferential 
conditions will be the same as 
or higher than A1 

•  Benefit:  increased  turnover 
customers 
paying 
from 
travelling  with  persons  with 
disabilities 

• 
Impact on the whole economy 

•  Value added in the market for 
accessible 
the 
estimates  range  from  2.1  to 
3.1  billion  EUR,  increased 
tax revenue 

tourism: 

• 

Same as A1 

325 Both short-term and medium trip fall within the short-term stays (up-to 3 months). 
326 In 2012, the DG GROW study on accessible tourism estimated that across the EU countries people with disabilities 
travel with more companions (on average 2.2 persons) than the elderly population do (on average 1.6 persons). 

177 

 
 
 
 
 
 
Administrative 
costs  

rate 
Final 
Effectiveness 
(see 
explanation below) 

rate 
Final 
Efficiency 
(see 
explanation below) 

0 

0 

Effectiveness  

•  Not  expected  to  entail  any 
administrative 

substantial 
costs 

• 

Same as A1  

2 

2 

3 

3 

Under  the  baseline  scenario,  the  travel  gap  of  persons  with  disabilities  compared  to  the  general 
population  will  remain  constant.  Also,  the  level  of  uncertainty  regarding  the  availability  of 
preferential conditions offered to persons with disabilities when travelling across the EU Member 
States will remain high. Therefore, the baseline scenario is not expected to contribute towards the 
achievement of Specific Objective (SO) 1 (i.e. to facilitate the mutual recognition of disability status 
when persons with disabilities travel to other Member States).  

Policy option A1 scores positively on its effectiveness in the achievement of SO1. By mandating the 
production and use of a European Disability Card policy option 1 is expected to facilitate the mutual 
recognition of disability status when persons with disabilities travel to other Member States. This is 
expected to reduce the travel gap of persons with disabilities by a range of 1.32 – 1.94 percentage 
points.  However,  despite  leading  to  higher  social  impacts  compared  to  the  baseline,  the  main 
limitation of option A1 would be its scope, as mutual recognition through the Card would only be 
ensured  in  the  sectors  of  culture,  leisure,  sports  and  transport  (the  same  sectors  of  the  pilot  EDC 
initiative). Hence, option A1 would fall short of achieving specific objective 1 for all services in the 
EU by failing to fully remove the uncertainty related to mutual recognition. 

On the other hand, policy option A2 would extend the validity of the EDC to all services (with or 
withoutremunerarion) offering preferential conditions to residents with disabilities leading in turn to 
a  removal  of  the  uncertainty  related  to  the  preferential  conditions  available  for  persons  with 
disabilities when they travel abroad. Also, due to its the broader scope, policy option A2 is expected 
to  lead  towards  a  higher  reduction  (between  2.8  and  4.12  percentage  points)  compared  to  policy 
option A1. Overall, due to its higher social impacts, policy option A2 is more effective towards the 
achievement of SO1.  

Efficiency  

The  baseline  scenario  has  been  rated  as  not  efficient  due  to  the  economic  loss  for  persons  with 
disabilities as well as for the whole economy (4.5 billion in 2023).  

The cost-effectiveness of policy option A1 is expected to be higher than the baseline scenario. More 
precisely, option A1 will entail some costs for public authorities and service providers related to the 
production and delivery of the cards as well as to the offer of preferential conditions also  to non-
residents with disabilities. However, the identified costs are expected to be small and they will be 
offset by benefits for persons with disabilities as well as for the whole economy. Costs for service 
providers  offering  preferential  conditions  would  be  minor  for  both  policy  options.    Indeed,  it  is 
expected that beyond the benefits in terms of social impacts (see explanations of the effectiveness 

178 

 
 
 
 
rate) persons with disabilities will save between 30 to 140 EUR per short-term trip (4-days), and 100 
to 400 EUR per medium-term trip (2 months). Also, policy option A1 is expected to lead to beneficial 
impacts  on the whole economy.  Indeed, under policy option A1 the value added to  the market  of 
accessible tourism is estimated in a range between 1.32 to 1.94 billion EUR.  

As concerns policy option A2, the expected costs will be similar to those identified under policy 
option A1. However, policy option A2 is expected to bring higher benefits both in terms of social 
(see explanations of the effectiveness rate) and economic impacts. As for the latter, the following 
benefits are expected: 

•  Time savings for public authorities due to a reduction of requests for clarifications considering 
that all benefits currently offered to residents with disabilities will be offered also to non-residents 
with disabilities travelling for short-term stays; 

•  Savings  for  persons  with  disabilities  that  will  apply  to  a  broader  range  of  services  than  those 

included under policy option A1;  

•  The value added in the market for accessible tourism would range from 2.1 to 3.1 billion EUR. 

Therefore, overall, policy option A2 gained a higher rate than A1 under the efficiency criterion. 

Policy options aimed at facilitating use and legal certainty in the use of the EU 
parking card for persons with disabilities 

Table  2  –  Comparative  overview  of  impacts  and  related  ratings  for  the  effectiveness  and 
efficiency criteria 

Type of impacts  

Baseline 

B1 

B2 

Social  

• 

The  level  of  uncertainty 
regarding  the  recognition 
of  national  parking  cards 
will remain high 

•  Negligible  reduction  of  the 
travel  gap  for  Persons  with 
disabilities 

•  Removal  of  the  uncertainty 
regarding  the  recognition  of 
Persons with disabilities’ EU 
parking card  

•  Reduction  of  travel  gap  for 
Persons  with  disabilities 
between 
0.4 
0.27 
percentage points 

and 

Economic  

Public authorities:  

Public authorities: 

Public authorities: 

• 

parking 

Potential  costs  of  updating 
the security features of the 
EU 
in 
response  to  the  increased 
number  of  cases  of  fraud 
and forgery 

card 

•  Costs  related  to  increased 
knowledge  (e.g.  collection 
of 
staff 
information, 
training)  on  the  different 
formats  of the  EU  Parking 
across 
available 
Cards 
Member States 
Persons with disabilities: 

• 

The  risk  to  incur  costs 
to  parking  fines 
related 

In Member States which choose to 
updated 
to 
adhere 
recommendation: 

•  Benefit:Reduction 

in 

the 
enforcement  costs  for  public 
the 
due 
authorities 
enhanced security features of 
the EU parking card 

to 

•  Cost: Update of the format of 
the  EU  Parking  Card  with 
hologram:  range  between  € 
0.017  and  €  0.25  per  card, 
depending on the size and the 
foil used 

•  Cost: 

Serial 
connected to a database: € 4 

number 

179 

•  Costs  are  the  same  as  B1  at 
national level, but will affect 
all Member States 

• 
•  Benefits (i.e. reduction in the 
enforcement  costs)  are  the 
same  as  B1  but  they    will 
occur  in  all  Member  States  
due  to  the  binding  nature  of 
B2 

Persons with disabilities:  

• 

Expected  benefits  are  the 
same as B1 but they are more 
likely  to  happen  due  to  the 
binding nature of B2  

 
 
 
• 

(between 90 and 300 EUR 
per fine) will remain high 
The  risk  not 
to  obtain 
preferential  parking  will 
remain  high  (with  costs  of 
up to 4 EUR per day) 

•  Cost:  Establishment 

and 
update  of  national  website: 
range  between  EUR  7500 
and EUR 23000 per Member 
State 

Persons with disabilities 

Impact: 

•  Value added in the market for 
accessible 
range 
from  0.2  billion  EUR  to  0.3 
billion  EUR,  increased  tax 
revenue 

tourism: 

In  Member  States  which  coose 
to 
updated 
to 
adhere 
recommendations: 

•  Benefit:  Time  savings 

to 
obtain  information  on  the 
mutual recognition of the EU 
parking card. 
Savings  of  EUR  4/day  or 
(different 
EUR 
estimates 
(B2 
greater than B1) 

available) 

3/hour 

• 

•  Reduced  risk  of  potential 
fines  in  a  range  between  90 
EUR and 300 EUR  

Service providers: 

•  Negligible value added in the 
market for accessible tourism 

•  Negligible  impacts  linked  to 
the increased travel by car of 
cardholders following greater 
certainty in the recognition of 
EU parking card  

•  Negligible  impacts  linked  to 
the  increased  production  of 
to 
the  EU  parking  cards 
replace  those  with  outdated 
security features 

•  Not  expected  to  entail  any 
administrative 

substantial 
costs 

1 

0 

Same as B1 

Same as B1 

3 

1 

Environmental 

•  Negligible impacts 

Administrative costs  

Final 
Effectiveness 
explanation below) 

rate 
(see 

Final 
Efficiency 
explanation below) 

rate 
(see 

0 

0 

Effectiveness 

The baseline scenario will not be effective towards the achievement of SO2 (i.e. to ensure mutual 
recognition of the EU parking card for persons with disabilities) as the current differences affecting 
the mutual recognition of the EU parking card will still remain.  

The effectiveness of policy option B1 towards the achievement of SO2 will be higher compared to 
the baseline scenario, as the changes in the Council Recommendation are expected to lead to a higher 
harmonisation of EU parking cards across Member States, facilitating its recognition. However, the 

180 

 
 
 
 
  
 
 
 
 
 
 
voluntary nature of option B1 would not ensure that the amendments will be uniformly implemented 
across Member States, thus limiting the overall effectiveness of policy option B1.  

On the other hand, policy option B2 due its binding nature is expected to lead to higher harmonisation 
of the EU parking card across Member States. This will remove the uncertainty faced by persons with 
disabilities as concerns the recognition of the EU parking card across Member States. Also, policy 
option B2 is expected to lead towards a small reduction of the travel gap estimated between 0.27 and 
0.4 percentage points. Hence, in turn, B2 ensures a higher effectiveness towards the achievement of 
SO2 compared to B1 

Efficiency  

The baseline scenario is not expected to be cost-effective. Indeed, under the baseline scenario the 
cost for public authorities and persons with disabilities are not offset by any benefit.  

Similarly, policy option B1 is not expected to lead to benefits that offset the costs incurred by pubic 
authorities and persons with disabilities.  

By  contrast,  under  policy  option  B2,  public  authorities  incur  some  costs  that  are  offset  by  the 
reduction in terms of the enforcement costs as well as by higher benefits for persons with disabilities 
(see effectiveness rate).  

Table 3 - Comparison of the costs and benefits  

  Stakeholders 

Policy Area A 

Benefits 

Options aimed at 
facilitating 
mutual 
of 
recognition 
status 
disability 
in 
in 
the  EU 
relation  to  access 
to  services  when 
visiting  another 
Member State 

(Mandatory 
A1 
EDC model in all 
Member  States 
travelling 
for 
visiting 
and/or 
– 
purposes 
selected sectors) 

A2 
(Mandatory 
EDC model in all 
Member  States 
travelling 
for 
visiting 
and/or 

  Service Providers 

  National Authorities 

of 

Increased 
revenue 
tax 
from increased size  in the 
market 
accessible 
tourism  (For  A1  between 
1.5  billion  EUR  and  1 
billion  Euro  and  for  A2 
between 3.1 billion EURO 
and 2.1 biullion Euro  per 
year, 
gap  
decreases) ) 

travel 

if 

validity 

Decreased 
additional 
administrative 
burden 
thanks 
to 
decreased 
additional 
of 
number 
information requests about 
the 
the 
disability  cards,  provision 
of  preferential  conditions, 
citizens. 
etc. 
Decreased 
legal 
uncertainty as concerns the 
foreign 
of 
validity 
disability cards.     

from 

of 

in 

sport 

Decreased 
4 
uncertainty 
(culture, 
sectors 
leisure, 
and 
transport)  about  the 
validity  of  national 
cards and reduction in 
costs 
for  checking 
cards/certificates  (A2 
greater than A1) 

Increased 
turnover 
from  paying  persons 
accompanying  PwD 
(such  as  family  and 
friends).  In  2012,  the 
DG  GROW  study  on 
accessible 
tourism 
estimated  that  across 
countries 
the  EU 
people 
with 
disabilities travel with 
more companions (on 
average  2.2  persons) 
elderly 
than 
(on 
population  do 
average 
1.6 
persons).  (A2 

the 

  Persons 

with 

disabilities 
Decreased 
in  4 
uncertainty 
sectors 
(culture, 
leisure,  sport  and 
transport) 
and 
increase 
participation 
in 
tourism    (between 
300k and 2 million 
more)  (A2  greater 
than A1) 

Direct  monetary 
benefits 
from 
preferential 
conditions 
(for 
around  44%  of 
that  have 
PwD 
denied 
been 
preferential 
conditions  when 
travelling  to  other 
State 
Member 
to 
according 
results 
the 
public 
consultation) 
in 
travelling 

the 

of 

181 

 
 
 
 
 
 
 
 
 
purposes  –  all 
service sectors) 

range  of  EUR  30-
120  (if  alone)  and 
EUR  80-250  with 
a PA for trips up to 
4  days  and  up  to 
EUR  100  to  400 
per  trips  up  to  2 
months (A2 
greater  or  equal 
A1) 

Costs 

None 

slightly  greater  than 
A1).  These  persons 
will  be 
additional 
clients for the services 
concerned. 

Increased  size  in  the 
market  of  accessible 
tourism 
(For  A1 
between  1.5  billion 
EUR  and  1  billion 
Euro  and 
for  A2 
between  3.1  billion 
2.1 
and 
EURO 
  per 
biullion  Euro 
year, 
travel  gap  
if 
decreases 
 Costs  of  providing 
the 
additional 
preferential 
conditions 
to  PwD, 
including  preferential 
conditions  in  the  4 
sectors  of  option  A1 
that 
the 
includes 
transport sector and in 
for 
sectors 
other 
Option  A2  illustrated 
by  the  costs  in  the 
transport 
sector 
(between 116 and 161 
million EUR, i.e. only 
0.05%  to  0.08%  of 
(non-air) 
passenger 
transport in the whole 
EU-27)  and between 
1.7  and  31.2  million 
EUR at national level, 
depending 
on 
Member  States      (A2 
slightly  greater  or 
equal A1) 

Costs of providing the 
additional preferential 
conditions 
to  PwD, 
including  preferential 
conditions  in  the  4 
sectors  of  option  A1 
that 
the 
includes 
transport sector and in 
other 
for 
sectors 
Option  A2  illustrated 
by  the  costs  in  the 
transport 
sector 
(between  0.1  and  1.9 
EUR per capita, up to 
0.2  and  3.9  EUR 

implementation 
Total 
costs  between 
roughly 
95.000 and  530.000 EUR. 
Including:  I)  The  one-off 
cost  of  establishing  the 
national  website  ranged 
roughly  between  7,500 
ii) 
and  23,000  EUR, 
Awareness 
raising 
campaigns ranged roughly 
between 
and 
70,000 EUR. (A2 equal to 
A1) 

20,000 

Production and delivery of 
cards: 1.02-4.54 EUR/card 
(A2 equal to A1).  

Digitalisation:  the  one-off 
costs to build an IT system 
for 
are 
digital  EDC 
estimated to be EUR 1.67 
recurring 
million  with 
maintenance 
costs 
estimated at EUR 249,757 
per year. 

182 

 
 
 
 
 
 
 
Policy Area B 

Benefits 

Costs 

in 
to 

Higher 
participation 
tourism  due 
decreased 
uncertainty(B2 
greater than B1) 

Reduced  risk  of 
having to pay fines 
of 
lack 
for 
recognition 
or 
pay 
having 
to 
spot 
parking 
below 
(savings 
300  EUR 
per 
year) (B2  greater 
than B1) 

Savings  of  EUR 
or  EUR 
4/day 
3/hour 
(different 
estimates 
available) 
greater than B1) 
None 

(B2 

extended 

to 
when 
personal 
assistants) 
(A2  greater  or  equal 
A1) 
Reduced 
of 
checking  the  validity 
of 
parking 
cards (B2 greater than 
B1) 

costs 

EU 

 None 

Reduction  in  enforcement 
costs  

Reduced costs of checking 
the validity of EU parking 
cards (B2 greater than B1). 

For  the  preferred  option 
B2  there  will  be  benefits 
related  to  tax  revenues 
related  to  the  accessible 
tourism 
added 
value 
between  0.3  billion  EUR 
and 0.2 billion Euro while 
the wil not be any change 
for option B1. 

Issuing  EU  parking  cards 
(costs  similar 
to  EDC 
above)(B2 higher than B1) 

Setting 
national 
up 
database (B2 equal to B1) 

Setting up national website 
(costs  similar 
to  EDC 
above) (B2 equal to B1) 

ANNEX 9: POTENTIAL IMPACTS OF THE POLICY OPTIONS ON TRAVEL GAP 
OF PERSONS WITH DISABILITIES AND VALUE ADDED TO THE MARKET OF 
ACCESSIBLE TOURISM 

In  light  of  very  limited  individual-level  data  and  studies  on  tourism  behaviors  of  persons  with 
disabilities,  estimating  the  impact  of  the  policy  options  can  only  be  made  by  combining  various 
sources of information and making several assumptions. Firstly, it is assumed that the highest impact 
of any preferred policy option is to close the travel gap  of persons with disabilities relative to the 
general population. This assumption can be considered sufficiently credible given that it is unlikely, 
given  the  socio-economic  disparities  between  persons  with  and  without  disabilities  as  well  as 
remaining barriers in accessibility that would not be addressed by the policy options, that a single 
policy  could  induce  persons  with  disabilities  to  travel  abroad  relatively  more  than  the  general 

183 

 
 
 
 
 
 
 
 
 
 
 
 
 
population.  While  the  policy  options  considered  are  expected  to  bring  relevant  costs  savings  for 
persons with disabilities, it is unlikely that they would more than offset such disparities. An additional 
assumption is that the preferred policy option is unlikely to have a negative impact on the travel gap, 
which is highly credible. Thus, it is expected that the impact of the policy option on the travel gap 
will vary between 0 and 6.3 percentage points, the latter being the estimated travel gap.  

With these assumptions in mind, in order to assess the potential impact of the policy options on the 
travel gap, a specific question from the Public Consultation is used, which asks respondents to assess 
to what extent the European Disability Card could increase the number of persons with disabilities 
travelling in the EU. 1126 stakeholders answered this question, most of them being EU citizens (999 
respondents;  non-EU  citizens  and  “Other”  were  excluded).  The  question  uses  a  qualitative  Likert 
scale  with  five  response  options:  “Very  high  extent”,  “High  extent”,  “Moderate  extent”,  ”Small 
extent” and  “Not at all”. The distribution of responses is reported in Table 1 below. Following the 
standard  practice  in  the  psychometric  literature  when  aggregating  qualitative  answers  into  a 
quantitative assessment, numerical values are assigned to the qualitative scale, ranging from 0 for 
“Not at all” to 4 for “Very high extent”. With this procedure, the average value on the question is 
computed,  resulting  in  a  figure  of  2.87,  implying  that,  according  to  respondents,  on  average  the 
European Disability Card would roughly increase the number of persons with disabilities travelling 
in the EU to “a high extent”. To transform this estimate into an estimate of impact in terms of the 
travel gap, an additional assumption must be made. If all respondents to this question would have 
indicated “Not at all”, then the expected impact on the travel gap would have been 0. If instead, all 
respondents would have indicated “Very high extent”, then the expected impact on the travel gap 
would  have  implied  the  closing  of  the  travel  gap  of  6.3  percentage  points.  With  this  additional 
assumption, the computed average is used in order to calculate the expected impact on the travel gap 
through a simple normalization: 6.3 * (2.87 / 4) = 4.52 percentage points. We attribute such an effect 
to the policy options A2 and B2 even though the questionnaire did not provide specific detail on what 
sectors the European Disability Card would cover. However, since prior to this question, respondents 
were asked to indicate which sectors they would consider relevant, and these included Parking, it is 
assumed they would expect the policy to include all relevant sectors, with Parking included (A2 + 
B2). Thus, it is estimated that A2 + B2 could reduce the travel gap by 4.52 percentage points.  

Table 1 Distribution of responses in the public consultation to the question “To what extent do 
you think the European Disability Card could increase the number of persons with disabilities 
travelling in the EU” 

Very high extent 
High extent 
Moderate extent 
Small extent 
Not at all 
Total 

N 

336 
414 
285 
74 
17 
1126 

% 

29.8% 
36.8% 
25.3% 
6.6% 
1.5% 
100% 

The next step is to distinguish the effect of A2 from B2 and to try to estimate also the effects of A1. 
Option B1 is discarded from the analysis since it is expected to be only marginally effective relative 
to the baseline and highly variable in terms of impact due its voluntary nature. The goal is to quantify 
the relative value of the sectors included in each policy option. Again, the Public Consultation is used 
in absence of other data sources.  Respondents were asked to indicate which sectors they believed 

184 

 
 
 
 
would be important to be covered by the card. Figure 1 reports the distribution of responses for each 
sector. To obtain the relative value of each sector, first it must be assumed, in the absence of more 
detailed information, that if a respondent selected multiple sectors, they attribute the same value to 
those sectors. With this assumption in mind, the aggregate relative value of sectors covered by the 
policy options is computed using the distribution of responses on this question. If a given sector was 
selected by more respondents, then its relative value is considered to be higher. Specifically, the value 
of each sector is computed by dividing the number of respondents selecting that sector by the sum of 
respondents selecting each individual sector. For instance, the value of public transport would be = 
100 * 1140 / (114 + 1041 + 1005 + … + 182 + 117 + 64) = 9.65%, higher than what would be obtained 
if all the sectors were valued equally, which would simply be 100 / 23 (number of sectors) = 4.35%. 
By doing a similar calculation for the sectors covered by A2 and B2, the value of A2 is estimated at 
91.2%, while the estimate for B2 is 8.8%. Thus relatively, A2’s value is 10.3 times higher than of B2 
which allows to separate the effect of A2 from B2 in the calculation reported previously. Out of the 
4.52  percentage  points  impact,  0.4  percentage  points  would  be  due to  B2  and  the  remainder  4.12 
percentage  points  to  A2.  Through  a  similar  calculation,  the  relative  value  of  A2  to  A1  can  be 
calculated. The estimate is 2.13, implying that the impact of A1 in terms of reducing the travel gap is 
estimated to be 1.94 percentage points.  

Figure 1 Distribution of responses in the public consultations to the question “In your view, 
what are the services persons with disabilities would benefit the most from equal treatment and 
thus should be covered by the card?” 

Up to now, one of the assumptions was that the maximum potential effect of the policy options is the 
complete closing of the travel gap. However, this is likely to be outside of the range of effects of the 
policy  options  considering  that,  according  to  the  DG  Grow  report,  only  68%  of  persons  with 
disabilities  who  do  not  travel  abroad  cite  financial  reasons,  which  is  one  dimension  particularly 
impacted by the policy options. Using this share, the exercise performed above is updated considering 

185 

 
 
 
 
the upper bound to be 68% of the travel gap, thus 68% * 6.3 = 4.28 percentage points. The results are 
reported in Table 2 below and are considered as more realistic estimates of the potential impacts of 
the policy options on the travel gap between persons with disabilities and the general population. The 
table  also  reports  the  impacts  expressed  in  terms  of  value  added  in  the  market  for  accessible 
tourism obtained from the DG Grow report.327 It is important to underline that, given the way it is 
calculated, this figure includes the value added generated by persons with disabilities given all their 
activities and spending when travelling. As such, it is not limited to activities carried out within the 
specific sectors covered or not by the policy options (A1 or A2). In short, it has to be understood as 
the extra value added generated by all activities of persons with disabilities when travelling. For each 
policy option, the impact is calculated by multiplying the impact in terms of the travel gap with the 
value added of the market due to travels from persons with disabilities obtained from the DG Grow 
report and adjusting it for inflation over the period 2012-2023.  

Table 2 Estimated impact of the policy options in terms of travel gap reductions and value 
added in the market for accessible tourism 

Policy 
Options 

Scenario  1  –  assuming  a  higher 
reduction of the travel gap 

Scenario  2  –  assuming  a  moderate 
reduction of the travel gap 

Travel  gap reduction 
(percentage points) 

Accessible 
tourism 
added  

Travel  gap reduction 
(percentage points) 

value 

1.94 

4.12 

1.5 billion EUR 

3.1 billion EUR 

1.32 

2.8 

Accessible 
tourism 
added 

value 

1 billion EUR 

2.1 billion EUR 

negligible 

- 

Negligible 

- 

0.4 

0.3 billion EUR 

0.27 

0.2 billion EUR 

A1 

A2 

B1 

B2 

To conclude, it is estimated that A1 may reduce the 6.3 percentage points travel gap by between 1.32 
and  1.94  percentage  points.  The  impact  of  A2  is  expected  to  be  roughly  twice  as  large,  ranging 
between 2.8 and 4.12 percentage points. While B1 is expected to have a small impact, impossible to 
quantify ex-ante given the largely voluntary nature of the policy option, for B2 the estimated impact 
ranges  between  0.27  and  0.4  percentage  points.  In  terms  of  yearly  value  added  in  the  market  for 
accessible tourism, the estimates range from 1.32 to 1.94 billion EUR for A1, from 2.8 to 4.12 billion 
EUR for A2, and from 0.2 and 0.4 billion EUR for B2. As highlighted, in the absence of richer data, 
several  strict  assumptions  were  made  which  imply  that  such  estimates  should  be  treated  only  as 
suggestive and interpreted with caution. 

Potential net benefits of the policy options  

327 The following formula is taken into account to calculate the direct economic contribution in the DG Grow report. Daily 
spending accounts for all possible activities. Direct economic contribution = 
daily spending × length of stay × people with access needs × travel propensity × travel frequency 

186 

 
 
 
 
To compute the net benefits of the policy options, a conservative approach is taken, considering in 
the calculations the lower bound of the accessible tourism value added impacts and taking the upper 
bound of potential costs, wherever applicable. The increased value added, generated by persons with 
disability travelling more, comprises all the aggregated benefits of the policy options. The costs of 
providing preferential conditions, which are necessary as a result of the EDC, are included in total 
costs even though they represent at the same time a saving for persons with disabilities and would 
cancel each other out. Thus, the final estimate, given the available data and assumptions made,  is 
expected to be a lower bound estimate of the overall net benefit of the policy options.  

Starting with the policy options in policy area A, the following quantified costs are considered:  

•  Cost of offering preferential conditions for service providers: Based on the analysis of costs 
in the transport sector, travel journeys, mapping of preferential conditions and the perceived 
relative  value  of  the  sectors  in  A1  and  A2,  it  is  estimated  that  the  costs  of  providing 
preferential conditions would vary roughly between 190 and 264 million EUR yearly for A1 
and between 254 and 353 million EUR yearly for A2.  

•  Cost of producing the card: Full take-up of the card is assumed for both policy options A1 
and A2 (could potentially affect up to 32.2 million persons with disabilities, depending on 
national rules), which allows to calculate maximum aggregate production and delivery costs, 
relying on the upper bound estimates of such costs from the EU Disability Card pilot project 
(given the updated security features of the EDC relative to the pilot and adjusting the value 
for inflation) which turns out to be 174.2 million EUR. It is highly unlikely that the take-up 
of the Card will reach such values in one year, especially for A1 which has fewer sectors, but 
this is a conservative approach to the calculation of net benefits.   

•  Additional  costs:  digital costs,  administrative  costs,  national  websites  costs  and  awareness 

raising costs, totaling up to 5.14 million euros in 2023.  

Taking the lower bound of the value-added estimates (1 billion EUR for A1 and 2.1 billion EUR for 
A2), results in a net benefit of 0.55 billion EUR for A1 and 1.56 billion EUR for A2.  

For  the  policy  options  in  policy  area  B,  the  calculations  are  performed  only  for  B2  given  the 
uncertainty  regarding  the  take-up  of  B1  across  Member  States.  Nonetheless,  an  explanation  is 
provided regarding what can be expected for B1 at the end of the paragraph.  

•  Cost of offering preferential conditions for service providers: In the absence of data, the costs 
of providing preferential conditions are assumed, based on the analysis of the relative value 
of sectors, to be about one fifth with respect to  A1, thus varying roughly from roughly 40 
million EUR to 55 million EUR yearly.  

•  Cost  of  producing  the  card:  The  take-up  of  the  card  is  assumed,  given  the  reduction  in 
uncertainty, to be twice as large as what is currently observed (50% relative to the 25% current 
estimated value). Multiplying this with the unit production and delivery costs and with the 
number of persons with disabilities, results in a cost of 87.7 million EUR.  

•  Additional cost: costs of the website are included; other costs included in the policy option 
(such  as  the  database)  are  assumed  to  be  zero  because  they  can  be  integrated  in  existing 
systems. 

This results in a net benefit of 56.24 million EUR, considering the lower bound estimate of value-
added impact (0.2 billion EUR). For policy option B1 the net benefit is expected to be at most 

187 

 
 
this  value  if  all  Member  States  comply.  However,  the  net  benefit  is  not  expected  to  increase 
linearly with the number of Member States. While costs may have a more linear increase, benefits 
are expected to follow an S shaped curve relative to the number of Member States complying – 
i.e. to grow slowly initially and then much faster as more Member States join the initiative. Thus, 
it  is  preferable  in  terms  of  net  benefits  if  a  high  number  of  Member  States  comply,  a  feature 
guaranteed by B1.  

Table 3 Total estimates of benefits, costs and net benefits of the policy options 

Policy 
Options 

Lower  bound 
accessible tourism value added 

total  benefit 

- 

Upper 
total costs  

bound 

Conservative 
benefit estimate 

net 

A1 

A2 

B1 

B2 

1 billion EUR 

2.1 billion EUR 

0.44 billion 
EUR 

0.53 billion 
EUR 

0.55 billion EUR 

1.56 billion EUR 

- 

- 

- 

0.2 billion EUR 

0.14 billion 
EUR 

0.056 billion EUR 

188