RD337 - ETNO Reflection Document on the BEREC consultation “Electronic communications services: ensuring equivalence in access and choice for disabled end-users”


  • ETNO welcomes the opportunity to contribute to future BEREC work on the area of “ensuring equivalence in access and choice for disabled end-users”. European telecommunications operators, such as ETNO members, are willing to grant the highest possible level of equivalence in the provision of electronic communications services to their final customers with disabilities, taking into account national circumstances.
  • The new art. 23a of Directive 2009/136/EC allows member states to enable national regulatory authorities (NRAs) to specify requirements to be met by undertakings providing electronic communications services to ensure that disabled end-users have equivalent access to and choice of undertakings and services that are available to the majority of end-users and provides a mechanism to apply relevant obligations to all electronic service providers.
  • ETNO believes that a harmonised approach should be taken regarding the new task of NRAs in this field, allowing them to pay due attention to national circumstances.  We also believe that the views of operators should be taken in the utmost account when implementing the new provisions of the Directive.