Voices - EDF

Alejandro Moledo

Alejandro Moledo del Río
Deputy Director & Head of Policy

European Disability Forum (EDF)

EDF has been at the heart of EU accessibility policy for decades. We asked Alejandro Moledo del Río, Senior Policy Expert at EDF since 2013, what has changed since June 2025 and what businesses still get wrong.

As a Senior Policy Expert, Alejandro has played a key role in shaping EU accessibility laws, including the Web Accessibility Directive and the European Accessibility Act. His work helps ensure that accessibility is treated not only as a technical requirement but also as a human right.

 

How did you react when you heard about the scope of the Directive? Were you satisfied or did you feel like something was missing? 

When the European Commission presented the draft of the European Accessibility Act, EDF was pleased to see a strong focus on ICT products and services. It was in line with what we had been advocating for years – accessibility as a key part of the digital market. We also welcomed the link to public procurement and EU funds which make accessibility part of mainstream policy.

At the same time, something was missing. In every consultation with our members, people pointed to everyday barriers, including inaccessible buildings, transportation, or household products. Unfortunately, the built environment was largely excluded, and Member States resisted extending the scope of the Act. That gap still needs to be addressed because accessibility must reach beyond technology into the spaces where people live and work.

What are your observations concerning the implementation of the law at the European level? Have you noticed any particular trends or any concerns?  

Implementation has been uneven. Some countries moved forward quickly, while others struggled or delayed the process. Numerous Member States failed to meet the transposition deadline, forcing the European Commission to start infringement procedures. In a few cases, such as Greece and Bulgaria, national governments either misinterpreted the law or did not transpose it at all. This shows a worrying lack of commitment to accessibility.

EDF does not negotiate with governments directly – that is the role of our national members. However, we provide them with guidance, materials and peer support to strengthen their advocacy. We are also looking forward to the creation of the Working Group where Member States authorities, stakeholders and disability organisations can share progress. Consistency is vital: the EAA regulates products and services on the single market, so implementation must be coherent across the EU.

Different enforcement models also affect results. Some countries have centralised oversight, while others divide responsibilities among several agencies. What matters most is coordination and the meaningful involvement of persons with disabilities. The principle "Nothing about us without us" should also guide every stage of implementation, monitoring and enforcement.

Besides the standards and compliance metrics, what in your and EDF's view would be the real impact when it comes to EAA and accessibility for persons with disabilities?

The EAA is a market access law, but accessibility is much more than a regulatory obligation – it is a human right and a precondition for enjoying other rights such as education, employment, or healthcare. We encourage companies to move beyond compliance and treat accessibility as a driver of innovation, inclusion and customer satisfaction.

Real change happens when businesses involve persons with disabilities in product design and usability testing rather than reacting only to legal deadlines. Compliance is about ticking boxes, inclusion is about changing culture.

Measuring impact should also go beyond statistics. We need to know whether people with disabilities can actually use products and services without barriers. Companies should track both technical compliance and user experience, for example, accessibility testing results, customer feedback and staff training levels. These are meaningful indicators that show whether accessibility delivers real-world results.

Do you see emerging technologies, like AI, as something that could bring accessibility closer to everyone, or as a challenge for the accessibility framework?

Artificial intelligence brings enormous potential for accessibility. It can automatically generate captions, transcribe speech or simplify complex texts. It can make digital content easier to understand and navigate. Yet, AI also poses serious risks if accessibility is not built in from the start.

When data sets do not reflect persons with disabilities, algorithms can and do discriminate. We have seen this in recruitment, education, even in social services, where automated systems flag people unfairly because they fall outside the "average" data profile. That is why EDF worked hard to ensure that the EU AI Act includes fundamental rights safeguards, and is linked to the Accessibility Act so that accessibility becomes a design principle for all emerging technologies.

Regulation rarely keeps pace with innovation, but we are starting to see positive change. New EU initiatives such as the digital wallet, digital euro and e-signature frameworks all reference the Accessibility Act. This shows that accessibility is gradually becoming a built-in requirement across digital legislation, not an afterthought.

Which element of EAA will likely need revision within five years due to technological or social changes? 

The first priority for revision should be the built environment. After all, it makes no sense to have a digitally accessible ATM in a bank office or a ticket machine at a station which is physically inaccessible. Accessibility must apply to both physical and digital spaces.

We also need to extend the EAA to cover household appliances and connected devices as these now usually have digital interfaces. Smart home and Internet of Things technologies hold great potential for independent living, provided they are designed inclusively.

Some sectors are still "waking up" to accessibility. Telecom operators, for example, must ensure real-time text and accessible emergency communication under the EAA, yet progress remains slow. Governments should coordinate enforcement more effectively (whether through centralised agencies or coordinated networks) and always include disability organisations in decision-making.

Businesses also have a significant role to play. We tell them not to focus on exceptions and deadlines but on opportunity. Accessibility improves usability, strengthens brands, and creates a fairer internal market. It is both a moral duty and a smart business move. 

Looking further ahead, EDF would like to see a dedicated European accessibility agency, similar to what exists in the United States, to provide expertise and to ensure consistency across Member States. For now, cooperation is key to success. The European Accessibility Act laid a foundation. Now governments, companies and persons with disabilities must work together to make accessibility part of everyday life across Europe.

Interview by Karolina Mendecka
Business Accessibility Forum Director