Part II Conclusions and recommendations

1.13Recommendations

The 2015 CRPD Committee Concluding Observations to the EU are the most significant and authoritative recommendations regarding EU disability policy. They will remain valid until 2021 when the EU is next due for a review by the Committee. Some of the Committee recommendations echo the recommendations of this review made in previous years.

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  A comprehensive review of European law and policy in light of the EU’s obligations under the CRPD would be very useful. It would help identify the compatibility of instruments with the Convention; clarify the extent of EU competences in different areas; and provide for a workable schedule of substantive revision that may need to follow. The CRPD Committee specifically recommends ‘the adoption of a strategy on the implementation of the Convention, with the allocation of a budget, a time frame for implementation and a monitoring mechanism’ (para 9 of the Concluding Observations).
  
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  Legal certainty concerning the implications of the CRPD on the EU legal order could be helped by the Commission issuing an explicit declaration which complements the guidelines on the impact assessment guidelines,⁷⁵ whereby the Commission commits to interpreting all pre-CRPD instruments in light of the Convention.
  
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  Disability impact assessments should be reinforced as part of the fundamental rights impact assessment that is required for all new legislative initiatives.⁷⁶ The CRPD Committee recommends a review of the impact assessment guidelines ‘to include a more comprehensive list of issues to better assess compliance with the Convention’ (para 13 of the Concluding Observations).  Disability impact assessments should be based on a human rights-based indicators system developed in cooperation with representative organisations of persons with disabilities (para 73 of the Concluding Observations).
  
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  In the same vein, Eurostat should continue to develop their disability database as a basis for regular publication and disaggregated disability statistics from the major EU surveys, and work with national statistical agencies through the European Statistical System to harmonize where possible the collection of disability data within the core EU surveys, such as the Labour Force Survey. FRA should be encouraged to develop the work they have begun on specific CRPD articles towards the development of a comprehensive rights based indicator system.
  

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  Building on the above recommendation, it is essential that the staff of the EU institutions involved in the law- and policy-making process be trained in how to assess the impact of the EU policies on persons with disabilities. In this vein, the CRPD Committee suggests that a comprehensive and accessible campaign about the CRPD be developed. One of its target audiences should be staff of all EU institutions (paras 26, 27 of the Concluding Observations). Staff training is especially important in the fields where the medical approach to disability has been historically predominant (e.g. health, education) or where the disability dimension has not been strongly present up to date (e.g. consumer protection, migration).