Guidelines and gaps

The European Commission has issued guidelines that require member states to guarantee that citizens can survive at least three days of a severe disruption without external assistance. The measures form part of the European Union Preparedness Union Strategy and address stockpiles, early‑warning systems and basic infrastructure.

Disability advocates argue that the guidelines do not ensure that personal assistance needed by some people is maintained during a crisis. Maria Alvarez, a disability‑inclusion consultant who has worked on crisis‑preparedness projects across the EU, says that the essential unit of analysis should be the human function enabled by a service rather than the service itself.

The EU analysis of thirty‑eight countries found that inclusion of disability considerations in emergency planning is inconsistent, fragmented and largely left to discretion. The Commission’s Enhanced Disability Strategy, announced earlier in the year, provides a gap analysis, guidance and training for first responders but does not test whether promised support actually reaches individuals when systems break down.

Human continuity test

Critics point out that the current approach measures continuity of services rather than continuity of the human functions those services enable. For example a home‑care provider may remain operational during a storm but a missed visit could prevent a wheelchair‑bound person from eating or getting out of bed. Likewise an emergency broadcast may be transmitted but remain inaccessible to a person with a hearing impairment.

Disability organisations have drafted a human continuity test consisting of six steps that assess essential functions, supporting systems, time to harm, availability of accessible substitutes, performance under multiple disruptions and the ability to exercise rights. The test uses a weakest‑link principle meaning the overall score is determined by the lowest rating among the six dimensions. It is intended to highlight that a seventy‑two hour planning horizon does not represent a universal survival threshold for all individuals.

Potential law and recommendations

The discussion of disability inclusion also applies to older adults, children, people with chronic illnesses, displaced families and others who depend on care. A spokesperson for the European Disability Forum, who chose to remain anonymous, warned that urging individuals to stockpile food, water and medication shifts responsibility onto the most vulnerable and describes it as a form of social dumping.

The Commission is evaluating the need for an EU Preparedness Law that would set common standards and long‑term targets for essential societal functions. The draft law would include minimum preparedness requirements for member states and a monitoring mechanism to track compliance. Advocates suggest that the law should incorporate the human continuity test as an outcome measure rather than as a separate equality goal. They argue that success should be measured by whether people can continue to live, make decisions and participate during the seventy‑two hour period, not merely by whether services remain open or warnings are issued.

Implementing such a measure would require assessing the physical accessibility of shelters, the usability of sanitation facilities for people with mobility impairments and the availability of personal assistance on site. If the current approach proceeds without the human continuity test, the preparation burden could fall on households already facing high energy costs and limited disposable income. Families with disabled members often spend a large portion of their budget on specialised equipment, medication and private care services. Adding an emergency kit with backup power, specialised communication devices and extra medication could increase financial strain for vulnerable households.

A more inclusive preparedness framework could create market demand for accessible emergency technologies and encourage public investment in resilient transport and communication networks. The Commission intends to launch a public consultation on the proposed law later in the year, inviting input from civil society, trade unions, industry and national authorities. Disability groups have requested a mandatory impact assessment to evaluate how each proposed measure affects the most dependent citizens.