Recommendations for an Inclusive Digital Single Market

The European Commission is determined to boost the European digital economy by making the EU’s single market freedoms “go digital”, and releasing new opportunities for citizens and companies in terms of jobs, growth and services. The European Disability Forum (EDF) and AGE Platform Europe (AGE) support the Commission’s commitmentto adopt an ambitious Digital Single Market (DSM) strategy as long as it leaves nobody behind.We understand access to the DSM as a fundamental right that everyone should enjoy.

Facts

  • Over 35% of the EU population is at risk of exclusion from the DSM: 80 million Europeans with disabilities, and 190 million people aged 50+.
  • When they are available, affordable and accessible, persons with disabilities use ICTs to a greater extent than their peers to overcome some of the barriers they find in the offline world. Accessible technologies canenable access to the labour market, an independent life, and participation in all aspects of society.
  • The European Commission has identified the Silver Economy as a key area for jobs and growth. To be successful, ICT solutions must be accessible and usable for older persons too.
  • As State Party, the EU must comply with binding obligations set out in the UN Convention on the Rights of Persons with Disabilities(UN CRPD), the first human rights treaty to address access to ICTs, whichexplicitly requires accessibility for information and communication technologies and systems in article 9.
  • Accessibility is best achieved and most cost effective when incorporated from the outset, and it also represents a potential business opportunity[1].
  • Guidelines and standards to address accessibility are already in place[2] with benefits for all users.

However:

  • One in three persons with disabilities has never used the internet, which represents 54% of those who have never been online. Furthermore, over 69% of people who lack basic digital skills are aged over 55.
  • Due to thelack of accessibility, the rapid evolution of ICT and poor digital literacy,many persons with disabilities and older people are at great risk of not taking full advantage of the possibilities of the future DSM.
  • There is still much room for improvement with regards to accessibility of websites (less than a third are accessible), equal access and choice in telecommunications products and services (huge variations across the EU), and in the accessibility of audiovisual content[3].

Main recommendation: mainstream“accessibility” throughout the DSM Strategy

Accessibility must be understood and addressed as other key characteristics of the digital environment, such as privacy, security or data protection. Therefore, the aim of the DSM should be to ensure that an appropriate level of accessibility is enforced in all legislation linked to the DSM.Requiringinteroperability with assistive technologies should also be highlighted in the strategy in order to give access to the ICTs to peoplethat use technologies such as screen-readers or screen magnification software, hearing aids, etc.

If the DSM strategy lacks a universal design approach that ensures accessibility, it will prevent a broad range of consumers from “going digital”, as well as many European companies from competing with innovative and accessible services and products across Europe. In line with the General Comment Nº 2 of the UN CRPD Committee,the future DSM must ensure full, equal and unrestricted access forall potential consumers, including persons with disabilities and older people, taking full account of their needs, dignity and diversity.To achieve this goal it is necessary toconsult and actively involve them and their representative organisations in the policy making and standards development alike.

Otherrecommendations

  • Facilitate a swift adoption of the proposal for a Directive on the accessibility of public sector bodies’ websites that covers e-services of general interest, including the apps developed by providers to access those services.
  • Publish the long-awaited European Accessibility Act with a broad scope that includes ICT products and services, and a robust enforcement mechanism.
  • Ensure an accessible e-commerce throughout the whole chain of value: from accessible information to accessible reliable and trustworthy payment mechanisms, and including the customer services and right to redress.
  • Adjust copyright rules to allow the free movement of accessible content. The EU has signed the Marrakech Treaty, but has not yet ratified it.
  • Ensure equal access and choice fortelecommunication goods and services. Persons with disabilities and older people use alternative means of communication (such as relay services), yet these services are not currently available in all Member States. This also affects emergency services.
  • Strengthen media rules to enable greater access to audiovisual services. The current provision in the AVMS Directive is only an “encouragement” to improve access for people with visual and hearing impairments.
  • Protect the data of all citizens, including those deprived of their legal capacity. Clear information on how personal data will be used is crucial to take informed decisions.
  • Promote and support accessible e-Skills training programmes, in which the needs of persons with disabilities and older people are taken into consideration, as well as theaffordability of theaccessible ICT solutions suitable for them to participate in the DSM.
  • Raise awareness of the importance of e-accessibility among ICT professionals, including within their educational programmes to ensure a minimum qualification on accessibility.

About us

AGE Platform Europe –

AGE Platform Europe is a European network of organisations of seniors and representing over 40 million older people in Europe. AGE aims to voice and promote the interests of the 190 million citizens aged 50+ in the European Union and to raise awareness of the issues that concern them most.Contact person: Julia Wadoux, Policy and Project Coordinator for Health, ICT and Accessibility ().

European Disability Forum –

EDF is the European umbrella organisation representing the interests of 80 million persons with disabilities in Europe. EDF mission is to ensure persons with disabilities full access to fundamental and human rights through their active involvement in policy development and implementation in Europe. EDF is a member of the Social Platform and works closely with the institutions of the European Union, the Council of Europe and the United Nations.Contact person: Alejandro Moledo, New Technologies and Innovation officer ().

[1] eAccessibility impacts:

[2] Some examples are the worldwide acknowledge Web Accessibility Guidelines ( or the European Standard 301549 on accessibility requirements of ICT products and services:

[3] Study on Assessing and Promoting E-Accessibility 2013: