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The regulatory fragmentation with regard to accessibility requirements for hospitality services and websites across the EU is not only an obstacle for disabled amminidtrazione.filetype intending to travel across borders, but also for businesses that intend to provide accessible hospitality services in different Member States.

Currently, all Member States require built environment elements to be designed to be accessible for persons with disabilities but the bencgmarking technical specifications for the accessibility requirements vary across Member States.

This could lead to a strongly fragmented regulatory landscape. It is also important that the user is able to communicate with the e-shop management.

Economic operators, and public authorities in the area of public procurement, suffer from a lack of legal certainty, as to how exactly to cover accessibility requirements and cannot fully benefit from the size of the internal market lack of economies of scale. These countries are likely to develop requirements that may benchmwrking be fully aligned with already existing requirements and create further differences in line with previous sections related to their user interface, design and physical characteristics.

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The differences in the impacts of those two policy options mainly relate to the degree of effectiveness, the related costs savings, and their justification in line with the principle of proportionality. The lack of legal certainty as to what requirements are practised aministrazione.filetype other Member States including how the accessibility obligation is interpreted also hinders free bencmharking in the sense that the economic operator will often rather focus on the better known national markets instead of investing time and money to trade cross-border.

Baseline For the baseline scenario, the potential for additional fragmentation to occur in appears to be high. Interoperability, in turn, can only be achieved at EU level; the Interoperability Directive states that “interoperability within the rail system in Community-wide scale, cannot be sufficiently achieved by the Member States since no individual Member State is in a position to take the action needed in order to achieve such interoperability and can therefore be better achieved at Community level”.

Consistency with other EU policies. The divergence in accessibility requirements concerns for example, the amministrazione.filetgpe of rooms that need to be accessible, and technical accessibility requirements that vary largely across the EU. While most national rules for DTT equipment relates to the Digital Video Broadcasting DVB family of standards, fragmentation relates to the selected components of the specifications of that family, the compression rules used, the technical rules for the support of subtitles and audio description sometimes using the circuitry of the receiver to mix the signals.


Website visitors should have the opportunity to browse a catalogue, search for goods and services, add items in their shopping carts, manage the shopping cart and then proceed to check-out in order to end their order. In practice, a lack of consumer information causes consumers to stick to what they know and to be reluctant to consider new products.

All participants supported the Commission’s goal of improving accessibility of goods and services in the EU by applying an Internal Market logic and in line with the UN Convention of the Rights of Persons with Disabilities.

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Based on the current legislative situation described in Annex 6, it is estimated that by18 Member States are likely to have introduced technical accessibility requirements regarding ticketing machines and check-in machines. The intention is that buses can be easily used by all passengers including persons using wheelchairs, travellers carrying suitcases or parents with children in prams using the same entrance facilitated by a ramp instead of having a separate lift only for disabled persons.

If those banking services are not fully accessible for all consumers, this prevents certain consumers from fully benefitting from all available services. This section contains a description of the current situation and baseline for these areas.

Whether in the transport, hospitality, banking or retail service, offering accessible services online to individuals with disabilities requires web-accessibility, i. The regulatory fragmentation, for instance with regard to the minimum number of accessible rooms in a facility, impedes the use of standardised building plans and thus the realisation of economies of scale. Operators need to develop different national solutions in the Member States and users of these services have difficulties to access them from another Member State.

Ensuring free movement of accessible goods and services will have positive economic effects. Option 4 would have the biggest impact for the harmonisation of the internal market and would have greater social impacts but it would also be more expensive. Terminal equipment can be subdivided into fixed and mobile phones. Whereas accessibility was not obligatory in public procurement, following the adoption of the revised Public Procurement Directives it has become compulsory.

Currently, this is left mainly to the discretion of national authorities, which has resulted in the current patchwork of divergent accessibility requirements.

The UN Convention has been ratified by 25 Member States while the remaining three Member States are finalising the ratification process.

The current accessibility problems related to these three elements are described in the sections above on architect services, private sector websites, and self-service terminals. The built environment, Information and Communication Technologies ICTand transport were identified as the most problematic areas focusing on their use in some key services.

The diversity of the regulatory framework, where some Member States have complex national rules regulating accessibility, whereas others do not have any binding measures, results in economic disadvantages for those economic operators whose goods and services must fulfil those accessibility requirements, for example to sell to public authorities of the Member State of origin.


The problems experienced by economic operators today as a result of legislative fragmentation also relate to lack of legal certainty at the level of the accessibility requirements. EU Directive defining common accessibility requirements for the selected goods and services as well as in the area of public procurement – applicable to the Member States when they regulate on accessibility.

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It is important to note that EU funding from programmes like the European Structural and Investment Funds or the Connecting Europe Facility are often spent through public procurement. However, the proposal does not harmonise the existing specific provisions for persons with disabilities under the EU regulatory framework which would remain subject pubbblica national transposition and implementation measures, such as the relevant provisions focusing on the provision of information about measures taken to ensure equivalence in access and choice for disabled end-users and about more specific details of goods and services designed for disabled persons.

They will not be able to benefit as other consumers from the benefits of the internal market in terms of price, choice and quality. These industry players have to learn several sets of rules if benchmarkkng want to trade cross-border within the EU, which constitutes a barrier to the smooth functioning of the internal market. Specification of the technical accessibility requirements is left to the individual contracting entities 99 which makes it even more difficult for potential bidders from other Member States to participate in cross-border public procurement.

Account is also taken of the costs that firms will incur in adapting their products to meet different national accessibility i, and the costs of understanding these different requirements. According to feedback from consumers, there seem to be insufficient accessible mainstream goods and services on the EU market A full list of the consulted studies is provided in Annex 1.

Finally, stakeholders’ views have been more benchmafking referred to throughout the report. Impact assessment on Proposal for a Directive of the European Parliament and of the Council on the harmonisation of the laws of the Member States relating to accessibility requirements of goods and services.

Based on the current legislative situation described in Annex 6, it is estimated that all Member States will maintain diverging technical accessibility requirements for the transport-related built environment by