The EMN report examines how European countries address digital exclusion in migration procedures, focusing on access to and use of digital services by people with disabilities and others facing digital barriers.
Read the report on the European Commission's website. (external website)
Key points to note
- Most responding European Migration Network (EMN) Member and Observer Countries have adapted their digital services in legal migration procedures in accordance with the accessibility requirements of Directive (EU) 2016/2102 (the Web Accessibility Directive, WAD), the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), and corresponding national legislation to varying extents.
- Ten countries reported taking steps beyond their legal obligations by integrating accessibility into digital service design or offering measures such as text-to-speech tools, video relay services (VRS), or easy-to-read formats.
- Mechanisms for communicating special support needs vary. Common digital channels include contact forms and email. In some countries, applicants can raise support needs in person or through representatives.
- Countries highlighted that interactions with authorities are often hybrid and that in-person assistance is frequently available.
- In countries where applicants can indicate disability-related support needs, Regulation (EU) 2016/679 (the General Data Protection Regulation, GDPR) imposes safeguards by limiting the data collected, restricting access to authorised staff, and avoiding systematic storage of sensitive information.
- Measures supporting digitally disadvantaged applicants are generally broad and not necessarily targeted specifically at legal migration procedures.
- The degree of digitalisation of legal migration procedures varies widely. Some countries have not replaced any in-person steps with digital procedures, while others offer certain migration procedures fully online. Most still require some in-person steps, such as biometric data collection, identity verification, or the submission of original documents.
- There is limited target-group involvement in the development of digital services for legal migration procedures. Most countries rely on indirect feedback channels, and only a small number involve people with disabilities or digitally disadvantaged applicants directly.
- Countries identified challenges such as technical constraints affecting accessibility, difficulties involving users with disabilities in testing, procurement limitations, data protection considerations, and limited digital literacy among applicants.
- Good practices reported include accessibility-by-design approaches, practical accessibility tools, hybrid support models, and regular accessibility reviews to improve usability and inclusion.