Where Are We… With Accessibility?

In this new series of blogs, we explore the state of play with the main topics in public safety. With rapidly evolving legislation, different stages of implementation across Europe and beyond, it can be difficult to keep up. Where are we in terms of deployment, EU legislation, EENA’s work on the topic and future updates? These blogs will be a one-stop guide for everything you need to know on the current state of the most important topics in public safety. Today, we cover accessibility.

With at least 650 million people with disabilities worldwide, and 100 million people with disabilities in the European Union alone, accessibility matters. So why is it that most emergency services can still only be reached via voice call? With EU legislation deadlines looming, let’s explore the obstacles – and solutions – for accessible emergency communications.

Why Accessibility – and Why Not?

Voice call being the de facto method of contacting emergency services prevents a significant proportion of the population from getting help in an emergency – for example, those who are deaf/hard of hearing (9% of Europe’s population reports as such).

While it seems obvious that accessible communications will have a positive impact on access to emergency services, the reasons that many Public Safety Answering Points (PSAPs) have not implemented some accessible measures are multiple. Enabling a PSAP to handle other modes of communication – such as text services, communications in a sign language, and video communications – requires both upgrading the PSAP systems, adapting operations policy (training call-takers to use text), and even employing sign language interpreters. All of these measures are both costly to implement and require both the PSAP and the user to have fully functioning and compatible software.

EU Legislation: What Do EU Member States Need to Do?

There are two pieces of legislation that directly affect accessible emergency communications: the European Electronic Communications Code (EECC) and the European Accessibility Act.

The European Accessibility Act (EAA) includes some requirements on emergency access that complete the EECC and clarify the scope of ‘emergency communications’. It specifies that, at a minimum, real-time text (RTT) should be implemented – and that PSAPs should respond with the same communication method as that received (video responding to video, text responded to by text, for example). These provisions must have been transposed in EU Member states’ national law by 28 June 2022 and must be applied no later than 28 June 2025.

The EECC is a directive that was adopted in December 2018 and serves as the main legal reference for emergency communications since December 2020. It states that end-users with disabilities must be able to access emergency services on an equivalent basis with other end-users, and that 112 awareness must also showcase accessibility features.

There are also significant updates to accessibility requirements through the delegated regulation of the EECC. The delegated regulation specifies the ‘functional equivalence requirements’ that need to be met for means of access to emergency services for people with disabilities. The criteria are: Two-way interactive communication; availability in a seamless way, without pre-registration, to people travelling to other member states; communication should be free of charge for the end-users; routing of the communication “without delay” to the most appropriate PSAP and appropriate handling of the communication by the PSAP; equivalent caller location accuracy and reliability compared to means of access for other end-users, and awareness campaigns to promote the existence of these means of access. EU Member States are required to assess how their national systems meet the new ‘functional equivalence requirements’ outlined here. They must do this by March 5^th, 2024.  

Where Are We With Implementation?

With the deadlines specified by EU legislation looming, we will naturally have a clearer picture of where individual countries are soon. For now, implementation differs across Europe. There are a number of solutions that can satisfy the requirements of the EECC. Our document ‘Real-Time Text and Total Conversation in Europe’ outlines examples of these in action in both Europe and North America.

At the EENA 2023 Conference, we explored some RTT implementation plans and projects and consider what a functionally equivalent Real-time Text service looks like in our panel ‘Implementing Real-Time Text in the Framework of the European Accessibility Act’.

Naturally, many will ask whether Next Generation 112 (read our Where Are We… blog on NG112 here) will help or hinder the development of accessible communication. The NG112 architecture enables the modernisation of emergency communications, allowing for far more data collection (text, video, location or additional data). Offering text and video communications alongside traditional calls can help ensure equivalent access for people with disabilities. Read more about this in our blog, ‘NG112 with Accessibility in Mind’.

What is Next?

To find out more about the state of accessible emergency communications in Europe, read our document ‘Emergency Services Accessibility for Persons with Disabilities’.

EENA hopes that the requirements imposed on other aspects of emergency communication will also put accessibility in the spotlight, as PSAPs upgrade their equipment to conform with EU legislation. For example, the requirement for Member States to produce within nine months a roadmap detailing the country’s plan for PSAPs to be able to “receive, answer and process emergency communications through packet-switched technology” (deadline December 5^th, 2023) can be a great opportunity for PSAPs to consider the ability to accept emergency communications via text or video.

And for even more information, check out our accessibility special focus page.