DIGITALEUROPE Proposal for the European Accessibility Act (EAA)

EXECUTIVE SUMMARY

1. A European Accessibility Act should support the ICT industry in its on-going endeavour to act as an enabler of the social, economic and political inclusion of persons with disabilities.

2. The alignment of the European Accessibility Act with the New Legislative Framework as suggested in the current proposal would lead to an unenforceable and ineffective Directive, and have negative impacts on consumers and economic operators.

3. Accessibility cannot be subject to a generic pass/fail assessment because user requirements vary and usability is subjective.

4. DIGITALEUROPE proposes a requirement for the provision of accessible consumer information in order to enable informed purchasing decisions.

5. Furthermore, we suggest the introduction of a reporting obligation using a self-assessment approach based on future proofed functional performance statements and in a format that acknowledges that accessibility is not a simple ‘pass/fail’ assessment.

6. Similarly, public procurement should support innovation and competition by adopting international best practice (the use of award criteria and the ‘best meets’ principle) rather than embedding specific technical requirements.