Research Stream: Social Structures
Author: Lazar Stefanovic, PhD, Research Assistant at ALL Institute, School of Law & Criminology, Maynooth University
The European Commission published the latest European Heritage Label (EHL) Monitoring Report in April 2025, coinciding with the announcement of the pre-selected EHL sites for 2025. This provides an opportune moment to assess these developments through the lens of accessibility for persons with disabilities at European heritage sites, which is the purpose of this blogpost.
The EHL promotes the shared cultural identity of European Union (EU) Member States. It started as an intergovernmental initiative in Granada in 2006, before being formally established with the Parliament and Council Decision in 2011. Its main goals are to foster a sense of European belonging, promote respect for cultural diversity, and encourage dialogue between different cultures (Lähdesmäki et al., 2020). The underlying aim of such actions is to contribute to the European integration, while respecting the cultural diversity of its Member States. This interplay between respecting and promoting the Member States’ cultural diversity and foregrounding a shared European identity is embedded in Article 167(1) of the Treaty on the Functioning of the European Union (TFEU). The EU’s limited competence in culture stems primarily from Article 167 of the TFEU, which prescribes a supplementary and facilitating role for the EU in the field of culture. The legal basis for the EHL is Article 167(5) TFEU, as the EHL is an incentive measure in the sphere of culture, implemented in accordance with the principles of subsidiarity and proportionality stipulated in Article 5 of the Treaty on European Union. Despite its limited competence in the field of culture, the EU adopts a multifaceted approach that reflects its three main roles in the cultural sphere: funding actions with European added value; funding and organising actions that enhance the sense of European belonging, such as the EHL; and making cultural policy choices in the internal market (De Witte, 2024). The EHL is the embodiment of one of the three major roles of the EU outlined by De Witte.
The Decision establishing the EHL is emphatic about ‘increasing and/or improving access for all’ as one of the crucial elements of sites involved in this action (Art. 3 of the Decision). Even though the Decision does not mention persons with disabilities specifically, the EHL sites should make every effort to ensure the accessibility for persons with disabilities in light with the EU general commitments to promote disability rights stemming from the Charter of Fundamental Rights (CFR) and the UN Convention on the Rights on the Rights of Persons with Disabilities (CRPD), concluded by the EU in 2010. In that regard, the EU is obliged to foster the social integration of persons with disabilities and ensure accessibility in the implementation of EU law. Accessibility of cultural goods and services, including cultural heritage, is tightly linked to social inclusion and participation in the community, as well as to the right to cultural participation. The former is mandated in Article 26 (integration of persons with disabilities) CFR, and the latter in Article 30 (participation in cultural life) CRPD. Additionally, Article 9 CRPD obliges parties to ensure accessibility to a wide array of facilities and services available to the public, such as heritage sites. Currently several pieces of EU legislation, including the European Accessibility Act, mandate accessibility of some cultural goods and services. In fact, accessibility provisions are scattered around different pieces of EU legislation creating a ‘jigsaw’ (Ferri, 2023), and is mainstreamed in other initiatives such as the EHL.
The latest EHL report examined whether heritage sites continue to meet the criteria for their EHL status. The review focused on two aspects of site functioning – action plans developed by the sites’ administration and their organisational capacities. Notably, for the purpose of this post, under the organisational capacity section, the reviewers also noted the sites’ accessibility for persons with disabilities. However, the methodology outlined in the EHL Report does not clearly indicate whether or how accessibility for persons with disabilities is weighted. Furthermore, most of the sites reviewed include an indication of their accessibility to persons with disabilities, although not all of them do. In several instances, however, reviewers only mention accessibility in general terms, such as public transport connections or availability of information in various languages of EU Member States (e.g. Archaeological Area of Ostia Antica), without specifically addressing accessibility for persons with disabilities. The absence of information on accessibility for persons with disabilities for some of the sites likely reflects insufficient prioritisation in the review process.
Looking more closely to the assessment included in the report, some of the sites were reported to be accessible to persons with physical impairments but not to persons with sensory or mental impairments (e.g. Aleksandrovo Tomb). Other sites are located in difficult terrain or even underwater (e.g. Azores’ Underwater Cultural Heritage), which significantly reduces the possibility for interventions to ensure access for persons with various disabilities. Furthermore, the report captures instances of tension between the preservation of sites and accessibility for persons with disabilities (e.g. Olomouc Premyslid Castle). Other reviews emphasise that accessibility has been improved through bespoke staff training on how to accommodate visitors with disabilities (e.g. Archive of the Crown of Aragon). Many of the sites improved their accessibility by leveraging digital accessibility and incorporating bespoke features into their websites, especially during the COVID-19 pandemic. The review also noted the use of advanced technology to ensure library access for persons with disabilities (General Library of the University of Coimbra).
Turning now to the 21 newly pre-selected sites, information on accessibility is limited. A review of their websites reveals that, currently, most of them provide little to no detailed information on the accessibility of the site. Positive exceptions include the Styrian Armoury in Austria, which clearly describes accessibility features, and Krzysztof Penderecki – European Centre for Music in Poland. Similarly commendable from a disability rights perspective is the St Paul’s Catacombs site in Malta, which offers detailed accessibility information and digital 3D reconstructions for otherwise inaccessible areas.
While many European heritage sites have improved accessibility significantly, others still have much to do. To comply with obligations under Article 30 CRPD and better fulfil Article 26 CFR, the EHL review process should place greater emphasis on accessibility for persons with disabilities. This can be achieved by requiring a prioritization of accessibility for persons with disabilities a mandatory criterion for EHL sites. When carrying out the periodic external and independent evaluation of the EHL, provided for in Article 18 of the Decision, clear recommendations should be issued in relation to increasing access to EHL sites for persons with disabilities. Further, the European Heritage Label Bureau – which has been operating EHL sites’ umbrella organisation to support the development of a “community of practice” – should release practical recommendations on a regular basis, and ensure systematic follow-up on how sites meet accessibility criteria. This focus would also encourage broader EU-wide compliance, ultimately ensuring that heritage sites are genuinely inclusive for all visito
