Opinion of the European Economic and Social Committee – The future of the EU Strategy on the Rights of Persons with Disabilities post-2025 (own-initiative opinion)
Date: 2025-06-18
Institutions: European Economic and Social Committee
Subjects: EU strategy, access to education, discrimination based on disability, equal treatment, facilities for people with disabilities, fundamental rights, human rights, independence of people with disabilities, integration of people with disabilities, social integration








C_202504205EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/4205


20.8.2025






Opinion of the European Economic and Social Committee
The future of the EU Strategy on the Rights of Persons with Disabilities post-2025
(own-initiative opinion)
(C/2025/4205)


Rapporteur: 
Ioannis VARDAKASTANIS






Advisor


Haydn HAMMERSLEY (for the rapporteur, Group III)




Plenary Assembly decision


27.2.2025




Legal basis


Rule 52(2) of the Rules of Procedure




Section responsible


Employment, Social Affairs and Citizenship




Adopted in section


22.5.2025




Adopted at plenary session


18.6.2025




Plenary session No


597




Outcome of vote
(for/against/abstentions)


117/1/0




1.   Conclusions and recommendations









1.1.


With the EU Strategy on the Rights of Persons with Disabilities 2021-2030 now in the second half of its implementation period and all actions and flagship initiatives planned to date completed, the EESC welcomes the European Commission’s commitment to develop new actions for the period 2025-2030. It also points to the importance of the recent review of the EU by the UN Committee on the Rights of Persons with Disabilities which calls for actions to be continued after the strategy’s halfway point.












1.2.


The EESC considers that there were a number of key successes in the first half of the strategy. However, there were also some areas where more work is required and gaps left by the actions carried out in the 2021-2025 period. In this opinion, the EESC indicates which actions and flagship initiatives it considers the European Commission should focus on from now until 2030.












1.3.


The EESC urges the European Commission to start shaping its action plan for the last five years of the strategy swiftly and to carry out meaningful consultations of persons with disabilities and their representative organisations.












1.4.


As a priority, the EESC calls on the Commission to propose actions that are more binding in nature than those proposed between 2021 and 2025 and that have an impact that will be felt directly by persons with disabilities. An allocated budget should be planned under the next Multiannual Financial Framework to help implement these actions, ensuring a strong cohesion policy and support for organisations of persons with disabilities.












1.5.


In section 4 of this opinion, the EESC lists proposed actions geared to:






—


developing a viable alternative to the Horizontal Equal Treatment Directive;










—


building on the lessons of the Disability Employment Package;










—


filling the gaps left by the EU Disability Card in terms of freedom of movement;










—


ramping up the focus on accessibility and going beyond the AccessibleEU Centre;










—


making progress on protecting women and girls with disabilities where EU legislation has failed;










—


addressing the housing crisis for persons with disabilities;










—


establishing a joint mechanism for the mutual certification of assistive technologies across countries;










—


addressing persistent issues that persons with disabilities face when traveling in the EU;










—


taking a more active and holistic approach to facilitating the shift away from institutional care;










—


protecting persons with disabilities against discrimination by artificial intelligence; and










—


making the EU’s external action more consistent with internal EU policy regarding respect for the rights of persons with disabilities.








2.   Context of the EU Strategy on the Rights of Persons with Disabilities 2021-2030









2.1.


The EU Strategy on the Rights of Persons with Disabilities was initiated in 2021. It is set to run for ten years, ending in 2030.












2.2.


When it rolled out the strategy in 2021, the Commission proposed 64 actions including seven flagship initiatives. These were planned up until the end of 2024. Now, at the halfway point of the strategy, new flagship initiatives and actions need to be developed.












2.3.


The new Commission has confirmed that it intends to continue with the strategy and to update it with a series of new initiatives.












2.4.


On 21 March 2025, the UN Committee on the Rights of Persons with Disabilities (CRPD Committee) delivered its Concluding observations on the combined second and third periodic reports of the European Union, as a State Party to the UN Convention on the Rights of Persons with Disabilities. Point 13 of the concluding observations recommended that the EU ‘establish a process to adopt new specific actions, measures, and time frames for the implementation of the Disability Rights Strategy for the period 2025-2030’.












2.5.


The EESC played a key role in influencing the content of the first half of the strategy. In 2019, the EESC presented an own-initiative opinion (1). There was a clear overlap between the EESC’s recommendations and the actions in the final strategy.












2.6.


The situation in which the new actions will be rolled out has completely changed from the one which prevailed during the first half of the strategy. The strategy was initiated during the COVID-19 pandemic, but now EU support for marginalised groups is in danger of being sidelined and unjustly treated as less urgent in Europe’s rush to strengthen defence funding and address financial concerns arising from trade tariffs imposed by the US government.












2.7.


On 23 May 2024, over 700 delegates with disabilities from all over Europe met at the 5th European Parliament of Persons with Disabilities and adopted a manifesto on the European elections 2024 and the future European Commission and European Parliament mandates (2). The points raised in the manifesto have been used to guide this EESC opinion. The EESC underlines the need to continue and enhance consultation with persons with disabilities and their representative organisations when developing actions under the strategy.




3.   The EESC’s evaluation of the strategy so far









3.1.


The EESC welcomes the European Commission’s conscientious and consultative approach to devising its flagship initiatives and actions for the first half of the strategy. The monitoring framework (3) has ensured that the status of the actions and their links to final outcomes are transparent.












3.2.


The EESC welcomes the quality of the deliverables of the strategy’s actions, and the extent to which they reflected input given by persons with disabilities and their representative bodies.












3.3.


There are several particularly positive points, including the agreement on the EU Disability Card and Parking Card (4), the EU Guidance on independent living and inclusion in the community (5) and the creation/development of the AccessibleEU Centre (6).












3.4.


The EESC points out that in some cases the quality of the work accomplished was undermined by a lack of binding measures, creating a risk that persons with disabilities might not directly experience the benefits. This is the case for the Disability Employment Package (7), which presented very valuable but entirely optional information and guidance for employers and national authorities. The EU Guidance on independent living and inclusion in the community also has clear instructions but since it has no legal basis, national managing authorities are not required to abide by it.












3.5.


Other initiatives fell short of what the EESC had called for. The AccessibleEU Centre is a scaled-down version of the fully-fledged EU Accessibility Agency it had recommended. The EU Directive on combating violence against women and domestic violence failed to address the issue of forced sterilisation faced by women and girls with disabilities in a number of Member States.












3.6.


The EESC also notes that the Commission was unable to make progress on fostering an agreement on the Horizontal Equal Treatment Directive. The EESC regrets that the Commission decided to withdraw the proposed directive from its work programme for 2025.




4.   Priorities for the second half of the EU Strategy on the Rights of Persons with Disabilities









4.1.


With five years left to go, the EESC points out that the Commission must remain ambitious and proactive in proposing and delivering new flagship initiatives and actions for the strategy. Taking stock of what has been done since 2021, these new actions should build on what was achieved during the first half of the ongoing strategy and the 2010-2020 strategy, and act to correct any gaps and shortcomings.












4.2.



Develop a viable alternative to the Horizontal Equal Treatment Directive: Given the Commission’s decision to drop the crucial Directive No 2008/0140, the EESC flags up the urgent need to develop a new proposal that will guarantee the rights of persons with disabilities and other marginalised groups. This is supported by point 19A of the CRPD Committee’s concluding observations.












4.3.



Build on the lessons of the Disability Employment Package: The EESC calls on the Commission to channel the deliverables of the Employment Package into a practical initiative that will have a direct impact on the employment outcomes of persons with disabilities in the open labour market. The EESC supports the establishment of a Disability Employment and Skills Guarantee which would function in a similar way to the Youth Guarantee (8). It would use the European Social Fund to support both persons with disabilities of all ages as they enter employment, training or lifelong learning, and employers and educational establishments as they welcome and support them by adapting to their needs. This should be flanked by increased EU support for quality inclusive education that fosters personal development and the skills needed for the open labour market.












4.4.



Fill the gaps left by the EU Disability Card regarding freedom of movement: The EESC asks the Commission to live up to its commitment set out in the final agreement on the EU Disability Card by continuing to address barriers to freedom of movement in the EU faced by persons with disabilities. It notes that points 47A and 47B of the CRPD Committee’s concluding observations would mean calling on the Commission to explore the possibility of a directive on the freedom of movement of persons with disabilities. It also notes that such a directive would aim to establish shared responsibility among the Member States for funding support services and disability allowances for persons with disabilities moving to a new Member State, until such time as they have received their disability assessment in their new country of residence.












4.5.



Ramp up the focus on accessibility and go beyond the AccessibleEU Centre: To match the ambition of what it called for in its opinion (9), the EESC renews its push for a fully-fledged regulatory European agency for accessibility. This agency should have a stronger mandate than the AccessibleEU Centre. It should monitor the implementation of EU accessibility legislation effectively and support the Commission when it prioritises future legislation and initiatives.












4.6.



Make progress on protecting women and girls with disabilities where EU legislation has failed: The EESC points out that the Directive on Combating Violence against Women and Domestic Violence failed to criminalise forced sterilisation. The strategy needs to take a strong stance on this issue, with no exception based on disability or legal capacity. These measures must enforce action at EU and Member State level to prevent forced sterilisation, ensure equal access to sexual and reproductive healthcare, justice and compensation for victims, and encourage all EU Member States to ratify the Istanbul Convention. An EU-level campaign against forced sterilisation could be carried out by the EU institutions. These actions are supported by points 43, 44 and 45 of the CRPD Committee’s concluding observations.












4.7.



Adapt to current priorities regarding the housing crisis: The EESC calls strongly for the Commission to mainstream accessibility into its work on affordable housing. The EESC endorses calls for a Fund for Accessible Housing under the next Multiannual Financial Framework. This would boost the building of new accessible housing aligned with the needs of the EU’s changing demographics and make existing dwellings accessible where possible and requested. This is supported by point 67C of the CRPD Committee’s concluding observations.












4.8.



Make assistive technology affordable to those who need it: The EESC strongly encourages the Commission to develop legislation that will guarantee the availability and affordability of assistive technologies for persons with disabilities in the EU single market and to take into account the recommendations made in its opinion (10) on new technologies and AI. Legislation should tackle the issue of national certification schemes preventing persons with disabilities from accessing the assistive technology best suited to them, and ensure that economic operators and users take full advantage of the EU single market and benefit from the free movement of products and services. A joint mechanism for the mutual certification of relevant assistive technologies across countries should be set up. This is supported by point 53D of the CRPD Committee’s concluding observations.












4.9.



Address persistent issues that persons with disabilities face when travelling in the EU: The EESC calls on the EU to finally put an end to the turmoil too often confronting travellers with disabilities in the EU. The second half of the EU Strategy on the Rights of Persons with Disabilities should provide for in-depth revisions of the Regulation on Air Passenger Rights (11) and the Regulation on Accessibility of Rail Infrastructure for Persons with Disabilities (12). This is supported by point 51A of the CRPD Committee’s concluding observations.












4.10.



Take a more active and holistic approach to facilitating the transition away from institutional care: The EESC calls on the Commission to develop a holistic EU strategy for the transition from institutions to independent living and community-based services. This should comprise improvements in how data is collected on people living in institutions across the EU, how EU funds are used to support the Member States with this transition, how support workers are trained to offer more personalised support in line with the UN Convention on the Rights of Persons with Disabilities, and to bolster the sector of service provision for persons with disabilities and families caring for persons with disabilities in order to prevent their being institutionalised. The EESC also believes that the Commission must ground its new Guidance on independent living and inclusion in the community in the funding regulations for the next Multiannual Financial Framework, particularly the European Social Fund, the European Regional Development Fund and the Common Provisions Regulation. This is supported by points 48 and 49 of the CRPD Committee’s concluding observations.












4.11.



Protect persons with disabilities against discrimination by artificial intelligence (AI): The EESC points to the particular threats that AI can pose to persons with disabilities, as recognised by the AI Act (13). AI-based recruitment and employment assessment applications can be discriminatory if they do not factor in the particular issues and common educational and labour-related obstacles that persons with disabilities face. In case of future legislation, which the Commission is already reported to be considering (14), the EESC stresses the need to ensure that this legislation very clearly removes the risks of discrimination towards candidates and employees with disabilities. This is supported by point 54 of the CRPD Committee’s concluding observations.












4.12.



Make the EU’s external action more consistent in its work on disability: The EESC strongly believes that the European Commission should act fast to counter cuts to US funding for international development and humanitarian aid. It is therefore the EESC’s view that the Commission should develop a Disability Action Plan in EU External Action as part of the EU Strategy on the Rights of Persons with Disabilities. This action plan should cover five main thematic areas: upholding and mainstreaming the rights of persons with disabilities; establishing funding mechanisms and clear monitoring; ensuring full and effective participation and accessibility; developing and implementing fully inclusive policies and programmes; and strengthening internal and external disability-inclusive cooperation, coordination and partnership. This is supported by points 21D, 23A, and 57 of the CRPD Committee’s concluding observations.












4.13.



Do more to make the EU institutions disability-inclusive: The EESC stresses the need for the Commission and the other EU institutions to be more inclusive, particularly when it comes to making them a place where persons with disabilities can contribute in a professional capacity. There must also be greater emphasis on supporting trainees with disabilities when they take part in the institutions’ traineeship schemes.












4.14.



Analyse and assess the implementation of actions during the first half of the strategy and the previous strategy: While the EESC urges the Commission to be forward-looking, it also points to the need to monitor carefully the implementation of measures introduced during the first half of the strategy and prior to 2021. This is particularly important for the transposition of the Directives on the EU Disability Card and Parking Card, as well as for assessing the implementation of the EU Accessibility Act (Directive (EU) 2019/882) (15) and the Web Accessibility Directive (EU) 2016/2102 (16). A comprehensive assessment should be carried out before 2027 to inform the Commission of whether a post-2030 Disability Strategy will be needed and what issues it will need to address.












4.15.



Address other major barriers affecting persons with disabilities in the EU: This should include taking steps to ensure that persons with disabilities can exercise their right to vote and that the 2028 EU elections have no barriers; focusing on and reducing the stigma associated with mental health; addressing the representation/perception of persons with disabilities in the media; taking action against hate speech and online violence faced by persons with disabilities; and safeguarding the safety and security of persons with disabilities.












4.16.



Ensure a robust budget for cohesion: The EESC points out that delivering on these flagship initiatives and actions and upholding the EU’s commitment to the CRPD are reliant on robust and ambitious funding for cohesion policy under the next Multiannual Financial Framework.






Brussels, 18 June 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  Opinion of the European Economic and Social Committee on ‘Shaping the EU agenda for disability rights 2020-2030: a contribution from the European Economic and Social Committee’ (own-initiative opinion) (
OJ C 97, 24.3.2020, p. 41).

(2)  
            https://www.edf-feph.org/publications/eppd-manifesto-2023/.

(3)  
            Monitoring framework.

(4)  Opinion of the European Economic and Social Committee on 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 — 2023/0311 (COD)) (OJ C, C/2024/1595, 5.3.2024, ELI: http://data.europa.eu/eli/C/2024/1595/oj).

(5)  
            EU guidance on independent living and inclusion in the community.

(6)  
            AccessibleEU Centre.

(7)  
            Disability Employment Package.

(8)  
            Reinforced Youth Guarantee.

(9)  Opinion of the European Economic and Social Committee on ‘Shaping the EU agenda for disability rights 2020-2030: a contribution from the European Economic and Social Committee’ (own-initiative opinion) (
OJ C 97, 24.3.2020, p. 41).

(10)  Opinion of the European Economic and Social Committee – Inclusion of persons with disabilities in the context of the development of new technologies and AI – possibilities, challenges, risks and opportunities (exploratory opinion requested by the Polish Presidency) (OJ C, C/2025/2959, 16.6.2025, ELI: http://data.europa.eu/eli/C/2025/2959/oj).

(11)  Regulation (EC) No 1107/2006 of the European Parliament and of the Council of 5 July 2006 concerning the rights of disabled persons and persons with reduced mobility when travelling by air (OJ L 204, 26.7.2006, p. 1, ELI: http://data.europa.eu/eli/reg/2006/1107/oj).

(12)  Commission Regulation (EU) No 1300/2014 of 18 November 2014 on the technical specifications for interoperability relating to accessibility of the Union's rail system for persons with disabilities and persons with reduced mobility (OJ L 356, 12.12.2014, p. 110, ELI: http://data.europa.eu/eli/reg/2014/1300/oj).

(13)  
            https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai.

(14)  
            EU Commission mulls rules on algorithmic management in workplace for next mandate - Euractiv.

(15)  Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services (OJ L 151, 7.6.2019, p. 70).

(16)  Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of the websites and mobile applications of public sector bodies (OJ L 327, 2.12.2016, p. 1).


ELI: http://data.europa.eu/eli/C/2025/4205/oj
ISSN 1977-091X (electronic edition)