New EMN inform on digital accessibility and inclusion in legal migration procedures – coordinated by EMN Sweden

The EMN inform “Bridging the digital divide – digital services in legal migration procedures for accessibility and inclusion”, provides a comparative overview of how digital services in legal migration procedures can be made more accessible for persons with disabilities and other groups at risk of digital exclusion. Coordinated by EMN Sweden, the inform brings together contributions from 25 EMN Member and Observer Countries, including Norway and Ukraine. It identifies common challenges and highlights examples of good practice in fostering accessibility and digital inclusion.

Digitalisation of legal migration procedures

Digital services play an increasingly important role in legal migration procedures across EMN Countries. They are used to submit applications, communicate with authorities and monitor the progress of applications. In most countries, however, identity verification and the collection of biometric data still require an in-person appointment.

The level of digitalisation varies across countries. While some countries provide fully digital procedures for residence permit renewals or certain residence permit applications, others continue to require applicants to attend several in-person appointments.

Common frameworks for accessible and inclusive digital services

As digitalisation progresses, ensuring that digital services are accessible and inclusive has become increasingly important. Expanding the availability of online services alone is not sufficient; these services must also be accessible and usable by everyone. EMN Countries face similar challenges, but common European and international standards support the development of more accessible digital migration services.

• Nineteen EMN Member Countries and Norway develop their digital services in line with the EU Web Accessibility Directive, WAD (Directive (EU) 2016/2102), the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) and relevant national legislation.
• Ten EMN Member Countries, including Greece, Spain and Sweden, reported implementing accessibility measures in legal migration procedures that go beyond the minimum legal requirements.

Despite these common frameworks, implementation continues to vary across countries. Several countries are integrating accessibility requirements into the design phase of new digital services. Examples include text-to-speech functions, sign language videos and digital assistants that guide applicants through the application process.

Support for applicants and protection of personal data

In most EMN countries, applicants can inform the responsible authorities of their support needs through online forms, email or during in-person appointments. Several countries also provide assistance through dedicated service centres, where applicants receive practical support with completing applications, uploading documents and using digital services.

Information relating to disabilities and other support needs is processed in accordance with the General Data Protection Regulation (GDPR).

A selection of examples of good practice

• Cyprus is developing its digital services, including those related to legal migration, in accordance with accessibility-by-design principles.
• Latvia provides text-to speech tools, video relay services (VRS), sign language videos, easy-to-read content.
• Germany offers sign language interpreters, Braille services and transport assistance for scheduled appointments.
• Croatia, Lithuania and Ukraine may provide home visits in exceptional cases.
• Spain provides dedicated support services where applicants can receive assistance in using digital services, including legal migration procedures.
• Greece deploys mobile teams to applicants who are unable to travel to the competent authority to provide biometric data due to permanent disability or long-term illness.
• The Czech Republic, Estonia, Finland, Hungary, Latvia, Luxembourg, the Netherlands and Sweden continue to provide non-digital alternatives for persons with disabilities or applicants with limited digital skills or access to digital services.

Situation in Sweden

Sweden offers digital passport checks for certain residence permit applicants, reducing the need to travel to a Swedish mission abroad. Language support is available through glossaries, translation functions and text-to-speech services. Applicants may also authorise a representative, by means of a power of attorney, to submit an online application on their behalf.

The National Government Service Centre provides practical guidance to individuals who require assistance in using the Swedish Migration Agency's digital services. As in many other EMN Member Countries, Sweden is continuing its work to improve accessibility in legacy digital systems.

Challenges and future developments

Twelve EMN Member and Observer Countries reported challenges in developing accessible digital services. Common barriers include legacy IT systems, technical and procurement-related constraints, varying levels of digital literacy among applicants and difficulties in involving persons with disabilities in user testing and service development.

To address these challenges, countries have adopted different approaches. Some are embedding accessibility into digital services from the outset through comprehensive strategies, while others are investing in practical support measures for applicants. Regular accessibility reviews and user feedback also contribute to the continuous improvement of digital migration services.