COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid 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) 289 final  COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid 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) 290 final} - {SWD(2023) 291 final}  
 
 
Subsidiarity Grid 

1.  Can the Union act? What is the legal basis and competence of the Unions’ intended action? 

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative? 

This proposal has interlinked objectives concerning several policy areas, such as services, transport, 
and  free  movement.  Hence,  the  use  of  different  legal  bases  is  required  to  cover  the  various 
objectives of this initiative. 

Articles  53(1)  and  Article  62  TFEU,  concerning  services  normally  provided  for  remuneration  in  the 
internal market, are relevant as the proposal will grant cardholders of the European Disability Card 
(EDC) the right to benefit from special conditions and preferential treatment when accessing services 
on an equal basis with persons with a disability recognised by the visited Member State. Moreover, 
with  respect  to  special  conditions  and  preferential  treatment  to  access  services  in  the  field  of 
transport,  such  as  parking  facilities,  Article  91(1)(d)  TFEU  provides  the  necessary  legal  base  to  lay 
down any other appropriate measures. In addition, this Article is also relevant since it allowed for the 
adoption of the Council Recommendation in 1998 which created the existing European parking card 
voluntary scheme, which will be replaced by the European Parking Card in the current initiative. To 
cover  those  services  that  do  not  fall  into  the  categories  covered  by  legal  bases  referred  to  above, 
Article 21(2) TFEU, as a residual legal base, provides for the possibility for the European Union to act 
and  adopt  provisions  to  facilitate  the  right  to  move  and  reside  freely  within  the  territory  of  the 
Member States. 

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in 
nature? 

In  the case of  access  to  services,  transport  and  free movement, the  Union’s  competence  is shared 
with the Member States. In particular, as regards the access to services, the legal basis for the shared 
competence  can  be  found  in  Article  4(2)(a)  TFEU,  i.e.  "internal  market".  As  regards  transport,  the 
legal basis is Article 4(2)(g) TFEU, i.e. "transport". And as regards the free movement, the legal basis 
is Article 4(2)(j), i.e. "area of freedom, security and justice". 

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in 
Article  3  TFEU1.  It  is  the  specific  legal  basis  which  determines  whether  the  proposal  falls  under  the 
subsidiarity  control  mechanism.  Article  4  TFEU2  sets  out  the  areas  where  competence  is  shared 
between the Union and the Member States. Article 6 TFEU3 sets out the areas for which the Union has 
competence only to support the actions of the Member States. 

2.  Subsidiarity Principle: Why should the EU act? 

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 24: 

-  Has there been a wide consultation before proposing the act? 
- 

Is there a detailed statement with qualitative and, where possible, quantitative indicators 
allowing an appraisal of whether the action can best be achieved at Union level? 

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN  
2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN  
3 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML  
4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN  

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A consultation was carried out 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 and their access to services to support the preparation of the EDC and the European parking 
card 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 evidence-based analysis. 

A wide range  of stakeholders  operating at 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  the  EDC  and/or  European  parking  card  (e.g.  persons  with  disabilities, 
personal  assistants);  and  (iii)  experts  (e.g.  researchers,  consultancies  and  advisors,  international 
organisations). 

The  stakeholder  consultation  included:  (a)  a  public  consultation  (3361  replies)  (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  (272  replies).  Annex  II  of  the  Impact  Assessment  provides  the  outcomes  of  the 
stakeholder consultation (Synopsis report). 

The 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  civil  society  organisations  representing  persons  with  disabilities, 
which are members of the Disability Platform. In addition, the Commission discussed with Member 
States in the Social Protection Committee meeting of 3 April 2023 and further during the meeting on 
the  EDC  organised  by  Finland  on  17  May  2023  to  support  the  Commission's  preparations.  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  European  parking  card  for  persons  with  disabilities  with  the  EDC  into  a  single  card,  and  no 
coverage of social security and healthcare benefits. 

The  European  Parliament  called  for  the  EDC  in  three  resolutions5.  They  welcome  the  initiative, 
advocating  for  legally  binding  measures and  asked  to  expand  the existing  pilot  project  to  cover  all 
Member  States,  covering  a  range  of  different  areas  beyond  culture,  leisure,  and  sport.  They  also 
asked to ensure that the European parking card is fully observed in all Member States. 

The  European  Economic  and  Social  Committee  adopted  Opinion  SOC/765-EESC6  that  supports  the 
initiative and similarly asked for a legal act introducing the card in all Member States. 

The IA report includes in its annex 7 a table “Monitoring indicators for the preferred policy option”, 
which  contains  operational  objectives,  a  set  of  15  indicators  and  sources  of  data  for  their 
measurement. 

The  explanatory  memorandum  and  the  impact  assessment  contain  a  section  on  the  principle  of 
subsidiarity. More information is available in question 2.2 below. 

5Texts adopted - European disability strategy post 2020 - Thursday, 18 June 2020 (europa.eu);  
TA MEF (europa.eu); 
Texts adopted - Towards equal rights for persons with disabilities - Tuesday, 13 December 2022 (europa.eu); 
6 EUR-Lex - EESC-2023-00525-AS - EN - EUR-Lex (europa.eu) 

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2.2 Does the explanatory memorandum (and any impact assessment) accompanying the 

Commission’s proposal contain an adequate justification regarding the conformity with the 
principle of subsidiarity? 

Yes,  the  explanatory  memorandum  contains  an  adequate  justification  of  why  the  proposal  is  in 
conformity  with  the  principle  of  subsidiarity.  The  following  is  a  relevant  excerpt,  reflecting  the 
arguments presented in the IA report, Section 3.  

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 problems identified have a cross-border dimension that cannot be solved by the Member States 
on  their  own.  The  necessity  of  EU  action  is  directly  linked  to  cross-border  travel  and  related 
challenges  faced  by  persons  with  disabilities  in  the  EU,  thus  the  need  to  ensure  a  coordinated 
approach among the Member States in facilitating their access to special conditions or preferential 
treatment on an equal basis with the persons with disabilities who hold a disability card or certificate 
issued by the host country.  

Absence to act 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 
European 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. 

The initiative does not seek to harmonise the eligibility criteria, conditions, or assessment procedures 
to  obtain  a  disability  status  in  a  Member  State,  for  which  Member  States  remain  competent.  This 
proposal does not affect Member States’ competences to determine the conditions and procedures 
when  assessing  disability  status  and  in  recognising  the  right  to  parking  conditions  and  facilities 
reserved for persons with disabilities and issuing a certificate, disability or parking card for persons 
with disabilities, or any other formal document, be it at local, regional or national level.  

The proposal does not impede either on national competences to determine whether or not to grant 
special  benefits  or  preferential  conditions,  such  as  free  access,  reduced  tariffs,  or  preferential 
treatment  for  persons  with  disabilities  and,  where  applicable,  person(s)  accompanying  or  assisting 
them.  The  proposal  does  not  impose  obligations  to  providers  of  services  whether  to  grant 
preferential conditions. It only ensures that when such special conditions or preferential treatment 
are granted, these should be available on equal terms and conditions to all persons with disabilities 
who are holders of a EDC or European parking card. 

2.3 Based on the answers to the questions below, can the objectives of the proposed action be 

achieved sufficiently by the Member States acting alone (necessity for EU action)? 

The objectives of the proposed initiative cannot be sufficiently achieved by the Member States acting 
alone. They are facing problems that have a clear cross-border dimension and an impact on the EU 
internal market. There is therefore a need for the EU to establish the mutual recognition of disability 
cards  for  the  purpose  of  accessing  services  on  an  equal  basis  with  persons  with  a  disability 
recognised by the visited Member State by creating the EDC and the European parking card. 

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(a)  Are there significant/appreciable transnational/cross-border aspects to the problems being 

tackled? Have these been quantified? 

The initiative focuses on problems that have a cross-border dimension that cannot be solved by the 
Member  States on  their own.  Member  States  acting  alone  may  be  counterproductive  as they may 
increase differences in and risks related to (the use of) the national cards. The necessity of EU action 
is  directly  linked  to  cross-border  travel  and  related  challenges  faced  by  persons  with  disabilities 
travelling  within  the  EU,  facing  legal  uncertainty  as  to  whether  their  disability  status  will  be 
recognised across borders. Hence, the need to ensure an adequate coordinated approach among the 
Member  States  with  a  common  EDC  that  will  be  recognised  in  all  Member  States.  The  EDC  will 
facilitate their access to preferential conditions offered by service providers on an equal basis with 
the persons with disabilities who hold a disability card or certificate issued by the host country. 

As concerns quantification of the problem, 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.  The 
participation  gap  in  tourism,  between  the  general  population  and  persons  with  disabilities  is 
estimated at 6.3%. (IA report, section 2.1)   

(b)  Would national action or the absence of EU level action conflict with core objectives of the 

Treaty7 or significantly damage the interests of other Member States? 

National action or the absence of EU level action would not conflict with core objectives of the Treaty 
or  significantly  damage  the  interests  of  other  Member  States.  However,  national  action  will  not 
facilitate  the  enjoyment  of  persons  with  disabilities  of  their  right  to  free  movement  in  the  Union. 
Hence, there would be no contribution to “the well-being of its citizens” with disabilities as concerns 
facilitating their free movement rights and equal access to services across the EU that the initiative 
intends to improve. 

(c)  To what extent do Member States have the ability or possibility to enact appropriate 

measures? 

The minimum requirements provided for in the intended initiative aim to improve the enjoyment by 
persons with disabilities of their rights and to facilitate equal access to services at Union level. More 
binding or other specific measures can be set by Member States, for example they may impose on 
service  providers  the  provision  of  special  conditions  or  preferential  treatment  for  persons  with 
disabilities.  Member  States  would  be  able  to  establish  bilateral  agreements  for  the  mutual 
recognition of disability cards, but this process would not guarantee the recognition of the same card 
across the Member States of the Union.  

(d)  How does the problem and its causes (e.g. negative externalities, spill-over effects) vary 

across the national, regional and local levels of the EU? 

The problem and its causes are similar across national, regional and local levels of the EU countries. 
The magnitude of the problem, i.e. variability of the national disability or the European parking cards 
is higher in case the cards are issued at local level, which adds to the differences in their appearance 
and consequently triggers more problems with recognition. For example, holders of EU parking cards 
sometimes  have  problems  with  their  recognition  even  in  their  own  country,  when  they  are  issued 
locally (such is the case of the Netherlands). The problem is also evident in those Member States that 
do  not  have  a  disability  card,  in  that  case  their  citizens  with  disabilities  are  not  able  to  easily 
document in other Member States their disability status. 

7 https://europa.eu/european-union/about-eu/eu-in-brief_en  

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(e)  Is the problem widespread across the EU or limited to a few Member States? 

The problem is widespread across the EU, all Member States are facing the same challenges and their 
citizens  with  disabilities  are  confronted  with  similar  obstacles  when  traveling  to  other  Member 
States.  The  EU  complaints’  system  SOLVIT  (Solutions  to  problems  with  your  EU  rights)  confirms 
similar problems faced by citizens of different countries. For example, citizens enquire whether their 
national disability cards would be accepted in another Member State, to what preferential conditions 
they could have access, etc. As concerns the European parking card, from 2018 to 2022, around 260 
enquiries were submitted that 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  European  parking  card  (around  12%  of 
cases).  Also  in  the  public  consultation,  persons  with  disabilities  across  the  Union  reported  similar 
problems  related  to  difficulties  in  recognition  of  the  disability  status  when  travelling  to  or  visiting 
other Member States. 

(f)  Are Member States overstretched in achieving the objectives of the planned measure? 

To tackle the problem of mutual recognition of the disability cards the EU supported the pilot project 
in  8  countries  in  the  areas  of  culture,  leisure,  sport  and  transport.  None  of  those  Member  States 
which  in  addition  continue  to  implement  the  EDC  have  reported  excessive  burden.    They  report 
satisfaction with the results of the initiative and have not indicated the need to additionally engage 
in  any  national  initiative  to  achieve  the  objectives.    The  proposed  measures  are  proportionate,  as 
they  impose  limited  administrative  burdens  on  Member  States  while  bringing  substantial  social 
benefits. More details are provided in section 3.2. 

(g)  How do the views/preferred courses of action of national, regional and local authorities 

differ across the EU? 

There is a high degree of consensus among Member States on the problem, the need for EU action 
and  a  legislative  initiative  as  the  appropriate  means  to  tackle  it.  The  scope  of  the  card  (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.  Some 
Member States prefer to cover only those services covered by the pilot, while others show openness 
to extending the scope. Organisations representing persons with disabilities would prefer to extend 
the  scope  of  the  card  to  all  services  and  to  accessing  social  security  benefits  while  they  await 
disability assessment in a new host country, as does the EESC. However, this is not within the scope 
of the proposal, as social security coordination at EU level is already legislated in a separate acquis.  

On the option of merging the European parking card with the new EDC, opinions vary. There is strong 
consensus  among  Member  States  and  also  civil  society  organisations  representing  persons  with 
disabilities that the European parking card should not be merged with the new EDC. Most individual 
respondents  in  the  public  consultation  supported  the  incorporation  of  the  European  parking  card 
into the new EDC legal instrument. 

2.4 Based on the answer to the questions below, can the objectives of the proposed action be 

better achieved at Union level by reason of scale or effects of that action (EU added value)? 

The objectives of the proposed action can be better achieved at the EU level because the initiative 
has  a  clear  cross-border  dimension.  It  addresses  the  mutual  recognition  of  disability  cards  via  the 
creation of the EDC and the European parking card based on the easily recognisable EU-model. If put 
in place through binding legislation, national authorities and services providers will have certainty of 

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the  cards’  validity  and  their  administrative  burden will  decrease.  Persons with disabilities  will  have 
certainty that their disability card is recognised. The EU value added is strong because the initiative 
will facilitate the free of movement for persons with disabilities in the EU and their equal treatment 
when accessing services. Increased participation of persons with disabilities  in tourism is expected, 
with the increased size in the market of accessible tourism (with possible value added of  up to 3.1 
billion EUR). 

(a)  Are there clear benefits from EU level action?  

There are clear benefits of the EU level action, i.e. creating the EU level “EDC” and “European parking 
card” based on mutually recognised EU-models. These cards would be easily recognisable among the 
countries,  they  will  have  security  features  to  avoid  fraud  and  forgery  and thus  national  authorities 
and  services  providers  will  have  certainty  of  their  validity.  EU  level  action  would  reinforce 
predictability for persons with a disability when travelling to other Member States, legal certainty for 
all  parties  (including  the  Service  providers),  and  equality  of  treatment  of  persons  with  disabilities 
across the EU. 

(b)  Are there economies of scale? Can the objectives be met more efficiently at EU level (larger 

benefits per unit cost)? Will the functioning of the internal market be improved? 

The objectives can be met more efficiently at EU level because the initiative has clear cross-border 
dimension and concerns travelling among the Member States. It deals with the mutual recognition of 
disability status via the EDC and the European parking card. It is expected that the functioning of the 
internal market as concerns services will improve, as persons with disabilities will get equal access to 
preferential  conditions  provided  for  persons  with  disabilities  and  service  providers  will  not  have 
administrative  burden  when  checking  the  cards.  The  increased  size  in  the  market  of  accessible 
tourism is expected, with possible value added of  up to 3.1 billion EUR. 

(c)  What are the benefits in replacing different national policies and rules with a more 

homogenous policy approach? 

EU action adds value by introducing a mutually recognised instrument (the  new EDC and improved 
European parking 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 and accessing parking facilities when visiting another Member State. These EU cards 
provide  legal  certainty  to  key  actors  namely  service  providers,  persons  with  disabilities  and  public 
administrations. Persons with disabilities will see their mobility facilitated, improve their freedom to 
visit other Member States, and be treated equally when accessing services compared to persons with 
disabilities recognised by the host country.  

(d)  Do the benefits of EU-level action outweigh the loss of competence of the Member States 
and the local and regional authorities (beyond the costs and benefits of acting at national, 
regional and local levels)? 

Yes,  significant  benefits  of  EU-level  action  outweigh  any  potential  loss  of  competence  such  as  a 
Member State’s freedom to design its own card. As described in previous sections, the costs of the 
action are negligible when compared to the volume of business in the sectors involved, for example 
transport,  while  benefits  for  the  individual  with  disabilities  travelling  across  the  EU  are  significant. 
Member  States  retain  their  full  competence  in  the  key  area  of  assessing  and  recognising  the 
disabilities in their territory. 

(e)  Will there be improved legal clarity for those having to implement the legislation? 

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Yes, with one single legislative instrument providing for both a “EDC” and a “European parking card”. 
This  legislative  instrument  –  a  Directive  –  is  clear  and  does  not  replace  national  legislation.  The 
European parking cards would replace existing national parking cards. The EDC would not replace the 
national  disability  cards  /  certificates  but  complement  them  for  the  purpose  of  travelling.  The 
Member States will be free, however, to decide whether to also replace national disability cards with 
the  EDC.  The  initiative  caters  for  the  provision  of  information  on  the  card  models,  as  well  as  the 
rights  and  obligations  in  the  Directive  towards  persons  with  disabilities,  and  for  raising  awareness 
among  the  public,  service  providers  and  public  administrations,  thus  contributing  to  legal  clarity. 
These EU-model cards will decrease the administrative burden for national authorities and services 
providers when checking validity of currently different national disability cards and certificates. 

3.  Proportionality: How the EU should act 

3.1  Does the explanatory memorandum (and any impact assessment) accompanying the 

Commission’s proposal contain an adequate justification regarding the proportionality of the 
proposal and a statement allowing appraisal of the compliance of the proposal with the 
principle of proportionality? 

Regarding the principle of proportionality, the form and content of the proposal does not exceed or 
go beyond what is necessary and proportionate to achieve its different, interlinked objectives. 

General, common rules and a common standardised format/template for both cards are set,  while 
taking  into  account  national  differences,  circumstances  and  practices,  the  assessment  of  disability 
status  itself,  establishing  the  necessary  procedures  to  issue  the  cards  and  determining  the  special 
conditions  or  preferential  treatment  in  access  to  services  for  people  with  disabilities  remains  the 
competence of the Member States.  

3.2 Based on the answers to the questions below and information available from any impact 
assessment, the explanatory memorandum or other sources, is the proposed action an 
appropriate way to achieve the intended objectives? 

The proposed action is appropriate to achieve the intended objective, which is to support the access 
on equal  terms  and  conditions  in  all Member  States  by  EDC  and  European  parking  card  holders  to 
special conditions or preferential treatment with respect to services (with or without remuneration) 
and  respectively  parking  facilities.  Therefore,  this  initiative  establishes  the  framework,  rules,  and 
common  conditions,  including  a  common  standardised  model,  for  a  EDC  as  proof  of  a  recognised 
disability  status  and  the  European  parking  card,  as  proof  of  their  recognised  right  to  parking 
conditions and facilities reserved for persons with disabilities. The initiative is limited to the aspects 
where the EU can do better. The choice of the instrument – a Directive - is justified by the legal basis 
and  by  previous experiences  to  improve  the effect  of  non-binding  instruments.  Its  implementation 
will be adjusted to national situations and legal environment. The initiative creates low to moderate 
costs for national authorities and service providers. However, these are expected to be counteracted 
by benefits for all the categories (national authorities, service providers, and especially persons with 
disabilities). A moderate increased size in the market of accessible tourism is expected. 

(a)  Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on 

their own, and where the Union can do better? 

Yes, the initiative is limited to the aspects where the Union can do better as it intends to create the 
EDC  based  on  the  EU  model  and  ensure  its  recognition  among  the  Member  States.  The  European 
parking card would be improved and become mandatory and recognised across the Member States. 
Member States on their own are not in a position to impose a common model of a disability card or a 

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parking card across the EU. 

(b)  Is  the  form  of  Union  action  (choice  of  instrument)  justified,  as  simple  as  possible,  and 
coherent with the satisfactory achievement of, and ensuring compliance with the objectives 
pursued  (e.g.  choice  between  regulation,  (framework)  directive,  recommendation,  or 
alternative regulatory methods such as co-legislation, etc.)? 

Yes, the choice of the instrument is justified and is in compliance with the objectives and shaped by 
the corresponding legal bases. Based on the experiences with recommendations and pilot projects, a 
legal  instrument  -  a  Directive  -  is  proposed to  ensure  the  respect  of  the  European model of  cards, 
mutual recognition of cards and commitment to provide preferential conditions provided by services 
to residents with disabilities also to residents with disabilities from other Member States. 

(c)  Does the Union action leave as much scope for national decision as possible while achieving 
satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum 
standards or use a less stringent policy instrument or approach?) 

Yes,  the  legislative  instrument  that  is  introducing  the  EU  model  cards  is  a  Directive  so  its 
implementation will be adjusted to the national situations and legal environment. Furthermore, the 
back  side  of  the  EDC  is  left  open  for  conveying  nationally  relevant  information.  In  addition, 
enforcement is done at Member State level through already existing bodies that would need to be 
confirmed by Member States during transposition. 

(d)  Does the initiative create financial or administrative cost for the Union, national 

governments, regional or local authorities, economic operators or citizens? Are these costs 
commensurate with the objective to be achieved? 

Yes, the initiative creates low to moderate costs. Total implementation costs are estimated based on 
varied  implementation  of  the  EU  Disability  Card  pilot.  These  ranged  between  roughly  95,000  and 
530,000 EUR per Member State due to different numbers of Cards issued and methods of printing, 
diverse system features (e.g. varied databases of service providers and beneficiaries), as well as other 
factors  that  include:  i)  the  one-off  cost  of  establishing  the  national  website  (which  ranged  roughly 
between 7,500 and 23,000 EUR), and ii) awareness raising campaigns (which ranged roughly between 
20,000  and  70,000  EUR). Production  and  delivery  costs  of  cards  ranged  from 1.02  to 4.54 EUR  per 
card by the national authority responsible for the cards. These costs relate to both the EDC and the 
European parking card. Digitalisation: 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  are 
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). 

As  concerns  costs  and  benefits  for  service  providers,  the  pilot  EDC  showed  that  the  majority  of 
service  providers  experienced  benefits  (monetary  and  non-monetary)  which,  as  a  minimum, 
outweighed  costs:  they  attracted  new  customers  and  gained  visibility.  Even  in  the  most  optimistic 
scenario, where the travel gap of persons with disabilities slightly reduces with respect to the general 
population, the growth in the number of persons with disabilities travelling would not be significant 
enough to negatively impact the client base of service providers from other Member States, and the 
range of persons with a disability would remain between 1 and 2%. On the contrary, it is expected 
that, as persons with disabilities travel with family and friends who pay their own expenditures, there 
will be an opportunity for increased business. 

Potentially it is in the transport sector where most costs are expected. These could range overall per 
year between 1.7 to 31.2 million EUR depending on the Member State (above all on its size, but also 

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on tourism patterns, and availability of preferential conditions, as well as the assumption regarding 
the  share  of  personal  assistants/  accompanying  persons  eligible  for  discounts).  However,  for 
countries in which the size of the passenger transport sector can be obtained, these additional costs 
appear very small relative to overall sector turnover, ranging from 0.01% to 0.31%. Total annual 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. 

All  these  costs  are  commensurate  with  the  objective  to  be  achieved  and  will  be  counteracted  by 
benefits for all the categories.  

1)  Persons with disabilities will have certainty that their disability status will be recognised via 
the  EDC  or  European  parking  card  and  thus  find  it  easier  to  exercise  their  free  movement 
right  and  enjoy  equal  access  to  preferential  conditions  provided  by  different  services  to 
persons with disabilities, as well as direct monetary benefits from preferential conditions and 
reduced fines risks (in case of the European parking cards), and ensured parking availability, 
etc. 

2)  National authorities will obtain somewhat increased tax revenue from increased size in the 
market  of  accessible  tourism;  decreased  additional  administrative  burden  thanks  to 
decreased  number  of  additional  information  requests  about  the  validity  of  the  disability 
cards and provision of preferential conditions, etc. from citizens; decreased legal uncertainty 
as  concerns the  validity  of  foreign  disability  cards.  As  concerns  the  European  parking  card, 
they  will  experience  a  reduction  in  enforcement  costs;  and  reduced  costs  of  checking  the 
validity of European parking cards. 

3)  Service providers will experience decreased uncertainty about the validity of national cards 
and  reduction  in  costs  for  checking  cards/certificates;  increased  turnover  from  paying 
persons accompanying persons with disabilities (such as family and friends - on average 2.2 
persons); increased size in the market of accessible tourism. 

(e)  While respecting the Union law, have special circumstances applying in individual Member 

States been taken into account? 

The initiative is proposing the EDC and the European parking card and their mutual recognition in the 
area of access to services and parking facilities respectively. For the EDC, the main principle is that 
preferential conditions that are available to residents with disabilities of a Member State should be 
available to persons with disabilities travelling from other Member States as well. Thus, the initiative 
is not creating any new preferential conditions or systems. It aims to be as simple as possible. For the 
European parking card the main principle is that parking card conditions applicable to residents with 
disabilities will  be  also  applicable  to  persons with  disabilities travelling  from other Member  States. 
The cards will be issued nationally and the Member States will have the competence to determine 
eligible beneficiaries based on national rules and practices as concerns the recognition of disability 
status.  The  initiative  therefore  fully  respects  the  national  competencies  and  has  the  flexibility  to 
cater for possible special circumstances in individual Member States. 

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