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EDF answer to the public consultation on the use of Identity cards and Residence documents in the EU

About EDF

Introduction

EDF recommendations on the accessibility of identity and residence cards

Contact person at the EDF Secretariat

EDF answer to the public consultation on the use of Identity cards and Residence documents in the EU

About EDF

The European Disability Forum (EDF) is an independent NGO that represents the interests of 80 million Europeans with disabilities. EDF is a unique platform which brings together representative organisations of persons with disabilities from across Europe. EDF is run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.

Introduction

EDF welcomes the European Commission’s public consultation on the use of Identity and Residence cards aiming at identifying obstacles in identification faced by European Union (EU) citizens and their families when exercising their freedom of movement across the EU. Information about this consultation can be found at this European Commission’s webpage.

In addition to the obvious benefits of an EU harmonised approach towards identity and residence cards in terms of mutual recognition across the EU, EDF would also like to stress the additional barriers that persons with disabilities face when using these kinds of documents. We therefore welcome the questions put forward by the Commission in the survey to individuals regarding the accessibility of identity cards. Nevertheless, the Commission should also be aware that not only blind and partially sighted people face these barriers, and therefore the abovementioned questions should have been posed in a broader manner, as there are many people with other types of disabilities (e.g. motor or intellectual disabilities), as well as an increasing aging population, that also encounter accessibility problems when using these cards. Thus, a more accessible ID or residence cards will be useful to the whole EU population at large.

The United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), ratified by the EU and 27 of its Member States, includes accessibility as one of its general principles (article 3). Thismeans that accessibility is a prerequisite to enjoying all the Human Rights enshrined in the Convention – including, therefore, freedom of movement. Additionally, article 9 on accessibility states very clearly that “to enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures (…) shall include the identification and elimination of obstacles and barriers to accessibility”.

Finally, in article 18, “Liberty of movement and nationality”, paragraph 1(b), of the UNCRPD states that persons with disabilities shall not be “deprived, on the basis of disability, of their ability to obtain, possess and utilize documentation of their nationality or other documentation of identification, or to utilize relevant processes such as immigration proceedings, that may be needed to facilitate exercise of the right to liberty of movement”.

In sum, the European Commission should not miss the opportunity to address and fix the accessibility challenges that persons with disabilities face when using ID & residence cards.

After a brief internal consultation, EDF has identified a set of accessibility requirements that could be easily implemented in future EU identity and residence cards that will facilitate the use of these by persons with disabilitiesenormously. The following list does not mean to be exhaustive whatsoever, and further research and further consultations will be required. EDF remains at the Commission’s disposal to clarify any aspects of the recommendations below, or should further information be needed.

EDF recommendations on the accessibility of identity and residence cards

Maximise readability

The written information included in the cards should be easily legible by the greatest number of people possible. Thus, the following aspects should be considered:

Font type and spacing: a sufficient spacing between letters and lines, as well as a clear font type, preferably sans-serif, as this facilitates reading for people with low vision and with dyslexia, among others.
Font size: the bigger, the better. When creating a new card, the system should modify the font size automatically to fit the text in the limited space of a card, ensuring the bigger font-size possible. This will also facilitate the readability of the ID information in context of use with limited light.
Contrast and brightness: these two aspects should also be studied. Better contrast (dark font over light background or vice versa) will also facilitate reading the card information.
Avoid glare: the card material can create too much glare that can disturb users when reading the information. The visual effects of holograms should also be considered.

Mark orientation

The card should include a tactile discernible reference to blind users to be able to orientate the card correctly (i.e. to know for instance how to insert it in a card-reader). This tactile reference could be just a tiny semi-circular indentation, or a discernible hole close to one of the corners of the card. It is important that this indentation is close to a corner so as to distinguish the front and the back side of the card. Other tactile indications such as where the chip of the card is located can also be useful.

Use of Braille

EDF very much welcomes the question about Braille in the individuals’ consultation. The inclusion of Braille will be necessary and highly beneficial for blind and partially sighted citizens. The Commission should bear in mind though that Braille font size is not adaptable.Braille official standards should be respected in order to make the card readable. The amount of information in Braille that can be placed in a card is therefore limited and consequently, which information is included in Braille will need to be studied carefully and in consultation with representative organisations of blind and partially sighted people. The ID number and the expiration date could be an option that might be useful to be included, as these are often forgotten.

Additionally, the use of Braille will also increase the grip, enabling easier use of the card by all those who require low-slip surfaces(see below).

A low-slip card

Many people with motor disabilities or with dexterity problems will benefit from a card that can be easily grasped, picked up from a flat surface. The material that is used as the card’s protective coating should be selected to facilitate this and reduce the possibility of the card slipping away from the individual at a desk or out of their hands.

Easy to understand

A lot of information is contained on an ID or residence card.It should therefore be studied as to how to make this information easier to understand. For instance, a simple change in language may facilitate thise.g. instead of “expiration date”, a similar and easier expression can be “this card is valid until…”.

This can benefit not only persons with intellectual disabilities but also the vast majority of the population who do not fully understand all the information included on the cards. In some countries, the back side of the card is full of codes and numbers that do not make any sense to citizens. The Commission and Member States should reflect whether all this information is necessary or whether it should be provided in a different and easier way.For instance, though the use of the information saved in the chip of the card.

Provide the card information in alternative formats

All the information included or saved in the identity or residence card should be provided to the citizens in accessible formats, such as accessible digital documents. This is most probably the easiest requirement to fulfil and could even be implemented with the current cards. Unfortunately, many people with disabilities in the EU still need to ask for help to be able to get the information of their personal documents.