COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive 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

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   EUROPEAN COMMISSION  Brussels, 6.9.2023  SWD(2023) 291 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document  Proposal for a Directive 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) 290 final}  
 
 
A.  Need for EU action 

What is the problem being addressed? 

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, especially because their 
disability cards or certificates issued at national level are not always recognised when they try 
to  access  services  under  the  same  preferential  conditions  as  those  available  to  persons  with 
disabilities in the visited country during short trips to other Member States. This has practical 
implications for persons with disabilities who wish to travel to other Member States. 

In the absence of any  regulatory obligations, the acceptance of national  disability cards and 
certificates of non-residents is voluntary and therefore limited across the EU. Moreover, there 
is insufficient awareness and knowledge about different national disability cards/certificates. 
As a result,  when  persons  with  disabilities  travel  to  or visit other Member States, their 
access  to  preferential  conditions,  including  those  related  to  services  for  and  not  for 
remuneration,  is  hampered.  This  may  lead  to  indirect  discrimination  on  the  basis  of 
nationality in some cases, or at least to uncertainty as to whether an individual will be able to 
use their disability card/certificate when accessing services. Persons with disabilities and their 
families can face costs to access and use services that would be free for their counterparts in the 
destination  country  and  miss  out  on  preferential  conditions  such  as  monetary  support, 
exemptions from paying for particular services and other types of support. As a consequence, 
persons with disabilities may be discouraged from travelling to other Member States.  

Public  authorities  receive  information  requests  regarding  recognition  of  disability  cards  or 
certificates issued by another Member State, adding to their administrative burden. They also 
face  legal  uncertainty,  as  they  do  not  have  the  means  to  confirm  the  validity  of  these 
cards/certificates.  

Furthermore,  service providers  have  difficulties in  recognising  the diverse  range of national 
disability  cards  and  certificates  that  are  necessary  for  granting  preferential  conditions.  The 
tourism sector also faces economic losses due to missed opportunities for travel by persons with 
disabilities. 

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 
way of getting around independently. The availability of parking facilities reserved for persons 
with disabilities is therefore key. The EU Parking Card for persons with disabilities, created by 
the  Council  Recommendation  98/376/EC,  was  designed  to  facilitate  this.  However,  its 
effectiveness is undermined by national differences in the format used for the card, a lack of 
information on the conditions granted to cardholders across the Member States, and cases of 
fraud and forgery of the card. It is therefore often unclear to cardholders how they can use their 
card, where they can drive and park, and how they can adhere to traffic rules outside their place 
of residence. The non-recognition of the EU Parking Card results in practical disadvantages for 
persons  with  a  disability,  such  as  not  being  able  to  park  near  the  entrance  of  premises  or 
financial fines. It may limit their use of services, leading to unequal treatment compared to the 
persons  with  disabilities  with  a  parking  card  issued  by  the  visited  country,  and  ultimately 
discourage these individuals from travelling.  

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If no action is taken, persons with disabilities are likely to continue to face uncertainty as to 
whether their national disability card or certificate will be accepted when travelling in the EU. 

The impact of the EU Disability Card pilot is expected to be modest because of its voluntary 
nature and the limited number of Member States and sectors participating. On the other hand, 
the positive role of the EU Parking Card in promoting the free movement and parking rights of 
persons  with  disabilities  will  continue.  However,  problems  with  its  recognition  by  Member 
States are expected to increase due to technical and digital developments, which increase the 
divergence of the models. 

The ageing of the population is expected to increase the problem as there is a higher prevalence 
of  disability  in  people  aged  65+  (currently  48.6%  of  people  in  that  age  group).  In  addition, 
travelling patterns of the general population are expected to rise, as was the trend until 2019 
before the Covid  pandemic. For persons  with  disabilities, four scenarios are made based on 
assumptions about how the gap between this group of people and the general population will 
develop as regards travel propensity1. The basic scenario assumes that the gap remains constant. 
The  increasing  gap  scenario  assumes  that  the  participation  in  tourism  of  persons  with 
disabilities does not grow in parallel with that of the general population. Two more optimistic 
scenarios assume either a minimal decrease or closure of the travel gap. However, in the case 
of  no  action  the  most  likely  scenario  is  that  the  estimated  gap  between  the  travel 
participation  of  persons  with  disabilities  and  the  general  population  will  remain 
unchanged if the uncertainty regarding the recognition of disability cards/certificates remains. 

What is this initiative expected to achieve? 

The general objective of the European Disability Card initiative is to facilitate free movement 
and equal access to preferential conditions to services provided for persons with disabilities, no 
matter  where  they  travel  in  the  EU.  Specifically,  it  aims  to  facilitate  mutual  recognition  of 
disability cards for the purposes of accessing services when persons with disabilities travel to 
or visit other Member States. It also aims to facilitate the use of the EU Parking Card and ensure 
legal certainty surrounding that card. 

When accessing services covered by its scope, whether with or without remuneration, holders 
of the European Disability Card would benefit from the same preferential conditions provided 
to  persons  with  disabilities  in  the  Member  State  they  are  visiting.  In  addition,  the  initiative 
intends  to  improve  the  functioning  of  the  EU  Parking  Card  for  persons  with  disabilities, 
improving its mutual recognition, awareness and preventing its forgery and fraudulent use. 

What is the added value of action at EU level?  

The problems identified have a cross-border aspect that cannot be solved by Member States on 
their own. The need for EU action is directly linked to cross-border travel and related challenges 
faced  by  persons  with  disabilities  travelling  within  the  EU.  It  is  necessary  to  ensure  a 
coordinated approach between Member States to enable persons with disabilities who hold a 
disability card or certificate to enjoy the same preferential conditions no matter where in the 

1 The scenarios are based on the information collected on past trends in travel propensity of the population aged 
15-64 (Eurostat database, TOUR_DEM_TOTOT. Available at: link) and survey data on persons with disabilities 
in  the  same  age  group  (Economic  Impact  and  Travel  Patterns  of  Accessible  Tourism  in  Europe  -  Full  Report, 
08/03/2015.DG GROW European Commission. Available at: link). 

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EU  they  travel  to.  Should  the  EU  not  intervene,  current  differences  in  national  disability 
cards/certificates would increase, and the different treatment of persons with disabilities across 
the Member States would continue or increase, undermining their free movement rights. 

B.  Policy options 

What  legislative  and  non-legislative  policy  options  have  been  considered?  Is  there  a 
preferred choice? Why? 

The assessment considered policy options aimed at facilitating mutual recognition of disability 
status in the EU in relation to access to services when visiting another Member State (A), and 
facilitating use and legal certainty in the use of the EU Parking Card for persons with disabilities 
(B), which, taken together, address the identified challenges. Several options such as voluntary 
arrangements, or selection of services were discarded. 

The preferred option is  a combination of policy  option A2 (mandatory European Disability 
Card model in all Member States for travel for travelling and/or visiting purposes - covering all 
service sectors) with option B2 (mandatory EU Parking Card model).  

Option A2 is most effective at facilitating the mutual recognition of disability cards in relation 
to access to services when visiting another Member State, as it mandates the creation of the 
European Disability Card, to be used precisely for that purpose and that can be easily recognised 
across  the  Member  States.  The  Card  would  eliminate  uncertainty  both  for  service  providers 
having to check the disability status of customers and for persons with disabilities travelling to 
and/or visiting other Member States.  

Option B2 is most effective at facilitating the recognition of the EU Parking Card. 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  more  homogeneous  format  of 
national parking cards would reduce uncertainty linked to their recognition for persons with 
disabilities travelling by car in the EU. This would allow cardholders to travel by car, without 
the risk of their parking card not being recognised abroad. It would also lead to cost savings for 
those concerned, due to using public parking slots reserved for persons with disabilities. 

In terms of choice of the legal instrument, a Directive is regarded as a suitable, proportionate 
and  effective  instrument  to  deliver  the  objectives  of  the  initiative  and  is  in  line  with  the 
identified legal bases.  

Who supports which option? 

The European Parliament in its 2022 Resolution strongly believes that the European Disability 
Card should be based on a binding EU legislative act covering a range of different areas beyond 
culture, leisure and sport.  

Persons with disabilities and their organisations mainly support extending the initiative beyond 
the  areas  covered  by  the  pilot  EU  Disability  Card.  In  the  public  consultation,  a  majority  of 
respondents (from a total of 3 361) stated that the main sectors that should be included in the 
European Disability Card are public transport (1 821), cultural activities (1 566) and parking 
(1 534).  

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There is consensus among Member States that the problem exists, that EU action is needed, and 
that a binding initiative is an  appropriate means to tackle it. There is also consensus  among 
users and Member States that the European Disability Card and the EU Parking Card should be 
kept  as  separate  cards  and  that  both  physical  and  digital  cards  should  be  available  to 
cardholders.  

There is also a strong support among the stakeholders for a legislative instrument.  

C. Impacts of the preferred option 

What are the benefits of the preferred option? 

The  analysis  suggests  that  the  implementation  of  the  preferred  option  would  have  several 
benefits for persons with disabilities, service providers and national authorities. 

For persons with disabilities:  

•  Decreased uncertainty and increased participation in tourism (it is estimated that option 

A2 would reduce the travel gap by between 2.8 and 4.12 percentage points). 

•  Direct  monetary  benefits  for  around  44%  of  persons  with  disabilities  that  have 
previously been denied preferential conditions when travelling to another Member State 
according to results of the public consultation. These are in the range of EUR 30-120 (if 
travelling alone) and EUR 80-250 (if travelling with a personal assistant) for trips of up 
to 4 days and up to EUR 100 to 400 per trip (per person) for trips of up to 2 months. 

•  Reduced risk of having to pay fines because the EU Parking Card is not recognised or 
of  having  to  pay  for  parking  spots.  Savings  can  be  quantified  as  generally  below 
EUR 300 due to avoided parking fines across the EU. Savings of EUR 4 per day or EUR 
3 per hour. 

For service providers: 

•  Decreased  uncertainty  about  the  validity  of  national  cards  and  reduction  in  costs  for 
checking  cards/certificates  including  the  EU  Parking  Card,  increased  turnover2  from 
paying those accompanying the persons with disabilities, and market benefit from more 
persons with disabilities travelling.  The accessible tourism market is expected to grow 
by between EUR 2.1 and 3.1 billion for the preferred option for the European Disability 
Card. These figures relate to all their activities and spending when travelling. For the 
Parking  Card,  the  preferred  option  has  the  potential  to  increase  the  added  value  of 
accessible tourism by between EUR 0.2 billion and 0.3 billion. 

For the national authorities: 

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Increased size of the accessible tourism market, and reduction in enforcement costs for 
the  EU  Parking  Card.  Increased  tax  revenue  from  increased  size  of  the  accessible 
tourism market.  

What are the costs of the preferred option? 

2 In 2012, the DG GROW study on accessible tourism estimated that across the EU, persons with disabilities travel 
with  more  companions  (on  average  2.2)  than  the  elderly  population do  (on  average  1.6)  These  people  will  be 
additional clients for the services concerned. 

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The estimated costs and nature of the costs relating to the preferred option are as follows:  

•  For the European Disability Card, costs relate to: 

o  offering preferential conditions for service providers, e.g., in the case of transport 
costs estimated at between EUR 116 and 161 million for the EU (accounting for 
0.05-0.08% of non-air passenger transport), varying between the Member States;  

o  producing the card, estimated at between EUR 1.02 and 4.54 per card; and  

o  digital  costs,  administrative  costs,  national  websites  costs  and  awareness  raising 
costs, estimated at between EUR 90 000 and EUR 535 000 per Member State.  

•  For the Parking Card, costs relate to: 

o  producing the card, estimated at between EUR 1.02 and 4.54 per card;   
o  costs of the website are included;  
o  other costs included in the policy option are assumed to be zero because they 

can be integrated in existing systems. 

How will enterprises and SMEs be affected? 

No significant impacts on competitiveness and SMEs are expected. The increased participation 
of persons with disabilities in tourism will have a positive impact on tourism, which is a sector 
where SMEs are prevalent.  

Will there be significant impacts on national budgets and administrations? 

There will be also some costs for national authorities: total implementation costs will be roughly 
between EUR 95 000 and EUR 530 000 for the European Disability Card (per country). These 
would include the one-off cost of setting up the national website (roughly between EUR 7 500 
and EUR 23 000) and awareness raising campaigns (costing roughly between EUR 20 000 and 
EUR 70 000). The total EU-27 one-off costs for public authorities to build an IT system for the 
digital European Disability Card are estimated at EUR 1.67 million, with regular 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 that is likely to get issued with 
European Disability Cards). 

For the EU Parking Card, there will be some adjustment costs for updating the card model and 
costs for setting up a national database and national website (costs similar to those above). 

The increased size of the accessible tourism market, especially in the case of option A2, will 
lead to increased tax revenue for national budgets. 

Will there be other significant impacts? 

Strong  positive  effects  on  fundamental  rights  are  expected,  namely  freedom  of  movement 
(Article 45 of the EU Charter of Fundamental Rights (EUCFR)), integration of persons with 
disabilities  (Article  26  EUCFR)  and  non-discrimination  (Article  21  EUCFR).  The  initiative 
would ensure greater social inclusion and integration of persons with disabilities compared to 
the baseline. 

What will be the net cost/benefit balance for the preferred option?  

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Taking the lower bound estimate of value added to accessible tourism of EUR 2.1 billion for 
the preferred option for the European Disability Card and deducting the related estimated costs 
results in a net benefit of EUR 1.56 billion for this option. Taking the lower bound estimate of 
value added of EUR 0.2 billion and deducting the related costs results in EUR 0.056 billion for 
the preferred option for the Parking Card. This adds up to a total of EUR 1 616 billion. 

D. Follow-up 

When will the policy be reviewed? 

In line with the Better Regulation  Guidelines, the Commission  will evaluate the initiative 5 
years after it enters into force, in cooperation with the Member States and after consulting the 
stakeholders concerned. 

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