Europaudvalget 2015-16
KOM (2012) 0721 Bilag 5
Offentligt
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Open letter
To
Ministers in charge of Digital Affairs in all EU member states
Chairs of National Parliament’s Committees in charge of Digital Affairs
Permanent Representatives of all EU member states
Copy:
Permanent Representatives, Dutch Presidency
Dita Charanzová MEP, Rapporteur
Vicky Ford MEP, Chair of IMCO Committee
Members of the European Parliament Disability Intergroup
Members of the European Parliament Intergroup on Ageing and Solidarity between Generations
Roberto Viola, Director DG Connect, European Commission
10 March 2016
Re: Trilogue Negotiations on EU Directive on Accessibility of Public Sector
Bodies’ Websites
We are writing to publicly raise our concerns about recent Council proposals to
significantly reduce the scope of the above EU directive.
We strongly object to the far-reaching exemptions proposed by the Council as these
would prevent millions of citizens from accessing digital content and services that
every citizen takes for granted today. We are calling on Member States to ensure
that the 80 million persons with disabilities, and the 150 million older people, who live
in the European Union have equal access to the Digital Single Market and the online
public services provided to citizens in the EU.
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 kom (2012) 0721 - Bilag 5: Henvendelse af 10/3-16 fra Danske Handicaporganisationer vedr. forhandlinger om EU's webdirektiv om tilgængelig hjemmesider
Equal access to information is a human right enshrined in the United Nations
Convention on the Rights of Persons with Disabilities (UNCRPD). Equal access to
online public services, regardless of the entity providing those services, is something
to which every European citizen is entitled.
It is not acceptable to adopt legislation that would potentially deny millions of citizens
access to the digital world we live in today. It is not acceptable to legalise digital
barriers to employment. It is not acceptable to exclude millions from full participation
in society.
The following essential requirements should be taken on board to ensure that the
directive makes a difference in people’s lives:
All public sector bodies' websites and websites delivering public services should
be accessible to all, including when these services are delivered by private
entities.
Most digital content is now accessed on mobile devices and through mobile
applications, therefore the directive must ensure accessibility of both mobile web
and mobile applications.
As most online processes require interaction with downloadable documents,
these should be accessible too.
Furthermore, we believe that accessibility should be a prerequisite wherever public
money is used to fund the development of websites, digital content, mobile apps or
other digital content or software, in line with requirements in the UNCRPD and the
2014 EU Public Procurement Directive. Public funds should never be used to fund
inaccessible content.
Fragmentation among national regulations and standards reduces the benefits of the
Digital Single market for companies and consumers with disabilities and older
consumers alike. A harmonised approach is needed to increase social benefits,
reduce costs and stimulate innovation. The more exclusions allowed in the directive
and the more reduced its scope, the less effective harmonisation will be.
We also want Ministers to ensure that provisions in the directive are articulated with,
and complementary to, those in the future European Accessibility Act. It is
paramount that no essential or general interest services are excluded.
Technologies are converging. Web, non-web and software interconnect all the time.
A European standard on accessibility of information and communication
technologies (EN 301 549) was adopted in 2014. We believe that this standard
should be used in full for the purpose of this directive.
For this legislation to make a difference and have meaningful impact, users need to
have an effective right to redress. Robust enforcement should therefore include
dedicated national enforcement bodies, as well as penalties that are effective,
proportionate and dissuasive.
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 kom (2012) 0721 - Bilag 5: Henvendelse af 10/3-16 fra Danske Handicaporganisationer vedr. forhandlinger om EU's webdirektiv om tilgængelig hjemmesider
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We are therefore urging Ministers to ensure that they instruct their negotiating teams
to uphold the rights of all citizens when discussing the provisions in the
aforementioned Directive with Members of the European Parliament.
We believe that governments should work to ensure that everyone can benefit from
the digital revolution. Although many persons with disabilities and older people face
barriers in the physical world, there is no reason to create new barriers in the digital
world. We are urging ministers to seize this unique opportunity to make a difference
to the lives of millions of citizens with disabilities and older people, people who
should benefit from wider access to digital public services in order to enjoy their
fundamental rights, as well as Internal Market rights of freedom of circulation and
services provision. We are urging Ministers to make our collective digital future fully
inclusive and not to fail European citizens.
No one should be left behind.
Signatories:
Yannis Vardakastanis
President, European Disability Forum
Markku Jokinen
President, European Union of the Deaf
Anne Sophie Parent
Secretary General, AGE Platform
Europe
Marcel Bobeldijk
President, European Federation of
Hard of Hearing People
Stephen Russell
Secretary General, ANEC
Kapka Panayotova
President, European Network of
Independent Living
Wolfgang Angermann
President, European Blind Union
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Zsuzsanna Szilvasy
President, Autism Europe
 kom (2012) 0721 - Bilag 5: Henvendelse af 10/3-16 fra Danske Handicaporganisationer vedr. forhandlinger om EU's webdirektiv om tilgængelig hjemmesider
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Boris Sustarsic
President, European Alliance of
Neuromuscular disorders association
Lieven Bauwens
Secretary General, International
Federation for Spina Bifida and
Hydrocephalus
Sonia Zamora
President, European Federation of
Parents of Hearing Impaired Children
Maureen Piggot
President, Inclusion Europe
Michael Kalmár
Chairman, European Dyslexia
Association
Olga Kalina
Chair, European Network of (Ex)Users
and Survivors of Psychiatry
Lieke Zaeyen
Vice President, Action Européenne
des Handicapés
Miguel Ángel García Oca
President, International Federation of
Persons with Physical Disabilitity
Ricard López
President, European Deafblind
Network
Jean-Luc Simon
Chair, Disabled Peoples’ International
European Region
Teresa Amat
President, European Association of
Cochlear Implant Users
Christina Fasser
President, Retina International
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