Explore the changes in current European and UK legislation that are helping improved accessibility to our emergency services.
Disability affects a high proportion of our populations around the world. In the UK alone, there are 14.1 million people living with a disability, including 19% of working-age adults and 44% of pension age adults, and almost 1 in 10 children. In Europe, around 87 million people identify as having some form of disability, according to EU statistics.
With this in mind, in March 2021, the European Commission launched an ambitious strategy for the Rights of Persons with Disabilities 2021-2030 to ensure full participation in society, on an equal basis with others in the EU and beyond, in line with the Treaty on the Functioning of the European Union and the Charter of Fundamental Rights of the European Union, which establish equality and non-discrimination as cornerstones of EU policies.
When we consider this movement towards more inclusivity and accessibility in the context of emergency response, one of the most important areas is understanding initial contact with emergency services organisations. Specifically, calls are being made for a wider set of communications options for the public in contacting the emergency services, because when only accessible via a voice call, those with certain disabilities can become more vulnerable in particularly dangerous situations in times of emergency.
Let’s look at what this movement is all about, and what it hopes to achieve in terms of inclusion and accessibility for our communities while providing insight for control room leaders in the UK and across Europe.
European Electronic Communications Code
The need to provide accessible emergency services has been addressed in the recent European Electronic Communications Code (EECC), which will help to ensure that all people have equivalent access to emergency services. In the past, legislation has been vague about the meaning of “equivalent access” for persons with disabilities, but the new legislation clarifies this with a shift from emergency calls to emergency communications. This addresses the need to provide services beyond voice calls, such as SMS, video, messaging, and total conversation. The deadline for transposition of the text was 21 December 2020.
While not explicitly mandated in legislation, the change of vocabulary from ‘emergency calls’ to ‘emergency communications’ means that the requirements to provide location information to the emergency services also include the way the public contacts 999 or 112.
One of the main limitations regarding the current means of accessibility for deaf and hard-of-hearing persons within Europe is that the means of contacting emergency services in an accessible manner are different from one country to another. Also, the use of some channels may also require pre-registration or the download of an application. This can be problematic when people travel to other countries and cannot contact the emergency services due to lack of awareness or technical limitations. The EECC requires the European Commission and national regulatory authorities to adopt specific measured to address this issue.
European Accessibility Act
The European Accessibility Act (EAA) was adopted in April 2019 and intends to harmonise the accessibility requirements for products and services in the European single market and include some requirements on emergency services access that complete the EECC and clarify the scope of emergency communications.
A summary of the EEA requirements is highlighted below:
Persons with disabilities must be able to contact emergency services on an equivalent basis compared to other end-users.
As of June 2025, at least real-time text will have to be deployed in the Member States.
Means of access to emergency services should be free of charge to the user.
Location information of the person contacting 112/999 should be provided to the emergency services.
Relevant authorities should seek to facilitate the way citizens with disabilities can contact emergency services in other EU countries, “where feasible without any pre-registration”.
Current requirements might be completed by a delegated act in 2022.
UK – Ofcom Consultation on Emergency Video Relay
In December 2019, Ofcom, the UK’s communications regulator, published proposals to require communications providers to make available a free, 24/7 video relay service for deaf British Sign Language (BSL) users to enable them to communicate with the emergency services. Their proposal was part of a package of measures to improve protection for consumers as part of the implementation of the European Electronic Communications Code (EECC) directive.
Video relay involves a deaf BSL user signing via a video link to an interpreter in a location such as a call centre using a connected device such as a smartphone, tablet, or PC. The interpreter translates what is signed to the emergency services via a voice call and signs the responses from the emergency services back to the deaf BSL user.
Whilst proposals put forward in this initial consultation received broad support from communications providers, consumer bodies, advocacy groups, industry bodies and other organisations, responses raised some specific points which are now subject to a further consultation published in February 2021.
The majority of respondents agreed that emergency video relay would further equivalence of access to the emergency services. Respondents who experienced deafness, in particular, said that this service would improve their welfare and health. However, some implementation points were raised, and consequently, Ofcom has decided to consult further on four points:
Recovering the costs of the emergency video relay supplier and any wholesaler
Providing emergency video relay on fair, reasonable and non-discriminatory terms
Zero-rating of data
Registration-free use of emergency video relay
In their final statement due in Summer 2021, Ofcom will provide further information and/or clarification on some other issues raised in responses to the Initial Consultation. These include the following areas, which we’ll keep up to date with and report on when available.
Alternatives to emergency video relay
The scope of the obligations on regulated providers
Responsibilities of the emergency video relay supplier
Alternatives to a wholesale model
The need for a data connection
Uninterrupted access to data networks
Interpreter qualifications, interpreter registration and interpreter welfare
Operational matters
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