- The EESC proposes a gradual expansion of the scope of the proposed directive after evaluation of the implementation of this proposed directive and in consultation with the stakeholder in order to cover payment terminals, hospitality services, insurance services, electronic magazines and newspapers as well as the physical premises and websites allowing access to products and services otherwise covered by the directive.
- The EESC encourages all parties concerned to broaden the interpretation of the legal base of the proposal and to include transport infrastructure and vehicles not otherwise covered by EU regulation regarding accessibility explicitly in the scope of the directive in order to avoid unintended regulatory gaps.
- The EESC recommends including a specific provision stipulating that from the entry into effect of the Directive, its obligations are only to apply to new products or services. This will avoid losses incurred from investment in accessibility that has already taken place.
- The EESC proposes the introduction of an EU-wide accessibility labelling scheme as a means of ensuring that persons living with functional limitations are able to find reliable and easily available information about the accessibility of products and services.
- The EESC recommends that the directive provide for strong and well-equipped enforcement bodies capable of cooperating across Member States with a view to the creation of a level playing field for economic operators regarding accessibility requirements.
- The EESC underlines the importance of active market surveillance in order to avoid compliance with the European Accessibility Act by all relevant parties depending too heavily on individual complaints from consumers living with functional limitations.
- The EESC recommends considering the inclusion of "understandable" as a requirement in relation to all relevant products and services covered by the scope of the Directive.