Draft Disabled People’s Rights Plan: summary of responses
Summary of consultation responses to the Welsh Government draft Disabled People’s Rights Plan.
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Introduction
The Welsh Government is committed to upholding the rights of disabled people and ensuring their full inclusion and participation in communities throughout Wales. The draft Disabled People's Rights Plan, represents a 10 year commitment to advancing equality and positive outcomes for disabled people in Wales. This long-term ambition recognises that real and lasting change requires sustained effort and collaboration, from government but also from across the public sector.
Consultation on the draft Disabled People’s Rights Plan began on the 15 of May 2025 and concluded on the 7 of August 2025. This document provides a summary of the responses received during that consultation.
Methodology
All responses submitted were reviewed and considered in drafting this report. Every consultation response was given a unique code. Thematic analysis was applied to the qualitative data, first examining responses to each question individually to identify recurring themes and related points. Analysis then looked across all questions to highlight overarching areas of consensus, concern, and priority. This structured approach allowed complex feedback to be distilled into clear themes and provide a deeper understanding of the issues raised.
Overview of quantitative data
The consultation received 157 responses in total, made up of:
- 86 submitted online via the consultation survey
- 58 submitted by email
- 7 commissioned responses submitted by focus groups
- 5 submitted in Easy Read format
Partially completed responses that were not formally submitted could not be taken into account.
Consultation workshops
During the consultation period, we held several workshops. Our engagement included commissioned focus groups led by:
- All Wales People First
- The Royal National Institute for Deaf People and Wales Council for Deaf People
- Vision Forum Wales: Guide Dogs Cymru and Wales Council of the Blind
- My Life, My Voice: Disability Arts Cymru and Autistic UK
- Children in Wales
- Fair Treatment for Women in Wales
- Disability Wales
Late responses
There were 4 responses submitted after the consultation closed. These were reviewed and considered in the preparation of this report.
Respondent profile
Of the 157 responses:
- 40 responses came from individuals
- 113 from organisations or other bodies
- 4 were blank
A full list of respondents, excluding those who asked to remain anonymous, is provided in Annex A. In total, 37 respondent requested anonymity, while 40 did not complete the anonymity question.
The table below provides a breakdown of responses by type of organisation:
| Type of respondent | Number |
|---|---|
| Commissioner's Office | 3 |
| Health board | 5 |
| Individual | 40 |
| Local authority | 14 |
| Organisation | 78 |
| Welsh public bodies | 8 |
| Regulator | 1 |
| University | 4 |
| Unknown | 4 |
Language of responses
Most responses (155) were submitted in English, with 2 received in Welsh.
Response themes
There was broad support for the plan, including its overall ambitions.
Strong themes repeated across many responses included:
- Collaboration, co-production, and the importance of lived experience
- The need for measurable outcomes, accountability, and transparency
- Digital Inclusion, transport, and rural inequality
- Children and young people
- Parents, carers and unpaid carers
- Workforce training and public awareness, especially around embedding the Social Model of Disability
Consistent themes appearing in several responses included:
- Health and well-being
- Education
- Employment
- Welsh Language and British Sign Language (BSL)
Themes appearing in some responses included:
- Intersectionality and the experiences of disabled people from minoritised groups
- Funding and resources
- Advocacy and support
Themes appearing in a few responses included:
- Political and legal issues
- Systemic and structural barriers
- Climate Change and Emergency Planning
- Leisure, sport and culture
- Concerns about the consultation process
- Housing and independent living
Summary of overarching response themes
The strong themes have been summarised below.
Collaboration, co-production, and the importance of lived experience
Respondents emphasised strong support for the principle of “Nothing About Us Without Us” but argued it is not being fully applied in practice. Respondents told us that disabled people should not only be consulted but should be visible in leadership roles, setting priorities and driving delivery. Some described the inclusion as ‘tokenistic’, with experiences of being invited to consultations but seeing little or no evidence that their contributions shaped decisions. There was a strong emphasis on ensuring that less-heard voices, such as those with learning disabilities, or intersecting impairments, are deliberately included.
There were calls for direct representation of disabled people within government structures (for example, a Cabinet-level post held by a disabled person) to ensure their voices carry authority. Respondents emphasised the need to see tangible change resulting from co-production, rather than being repeatedly asked for input without follow-through. Some highlighted the need to invest in user-led advocacy, with sustained funding and structural support for grassroots organisations to lead engagement and delivery.
The call for meaningful co-production with disabled people in the design and delivery of accessible experiences was highlighted across all sectors. Respondents advocated for the involvement of disabled artists, athletes, and audiences, stressing that additional funding and resources are necessary to make this a reality. There was also a strong emphasis on consulting those with lived experience to inform commissioning, especially regarding transport, housing, health, and specialist services.
Respondents called for ongoing co-production with disabled people at every stage of the Plan, include Disabled People’s Organisations, strengthen engagement standards. Additionally, respondents called for the inclusion of smaller grassroots community organisations, third sector groups, disabled children and young people’s voices and intersectionality in the new External Advisory Board overseeing the Plan, and decision-making processes and urged co-production of services with disabled people and their representatives, including trade unions.
Measurable outcomes, accountability, and transparency
Respondents emphasised that monitoring, feedback, and accountability mechanisms are essential for ensuring real progress for disabled people in Wales. They told us that it is crucial to have clear ways for disabled people to offer their views on accessibility and inclusion, and for government and organisations to be held responsible for meeting their obligations. Regular reviews, consistent outcomes monitoring, and including questions about disability in assessments were all emphasised as ways to drive continuous improvement.
The need for stronger accountability mechanisms was repeatedly stated, with respondents insisting on clear responsibilities for Welsh Government, local authorities, and public bodies. They stressed that the Plan requires concrete deliverables, defined timescales, and milestones not just aspirational goals. Many respondents told us that a live, regularly updated implementation plan would help track progress and hold decision-makers to account.
Respondents said the plan must have a rights-based approach. They underlined the importance of using the United Nations Convention on the Rights of Disabled People as a framework and said more needed to be done to improve accountability under the Public Sector Equality Duties. Respondents also emphasised that public services should be designed and delivered in ways that uphold the rights, dignity and autonomy of disabled people.
Several respondents pointed to gaps on the Plan, particularly the absence of detailed implementation strategies, timelines, funding, and measurable outcomes. They believe the Plan would be far more effective if it included a long-term implementation plan, associated funding, and a firmer commitment to upholding the rights of disabled people, potentially by placing those rights on a statutory footing in Wales.
Respondents said we must ensure data collection and transparent annual reporting across sectors, and aligning all implementation with a rights-based approach as set out in the UNCRPD. Efforts should be made to improve accessibility in transport, justice, and social care, with clear targets, measurable outcomes, and legal duties to ensure progress is both enforceable and accountable.
The plan should set specific objectives to close the disability employment gap, enhance inclusive education pathways, and invest in accessible infrastructure. Accountability should be ensured through Equality Impact Assessments, regular public reporting, and guidance for public authorities on applying human rights principles in decision-making. Collaboration with disabled people and their organisations must be central to developing, monitoring, and delivering these commitments.
Finally, respondents highlighted the necessity of consistent data to ensure genuine accountability. While some proposed short-term actions are welcome, many are seen as too broad or lacking measurable targets, making it difficult to evaluate success. Respondents also emphasised the importance of consulting with people with learning disabilities and ensuring their voices are heard throughout the process.
Digital inclusion
Respondents emphasised the urgent need for the Disabled People’s Rights Plan (the Plan) to commit to accessible digital skills training for disabled people, especially in education and employment arenas. They called for community-based programmes tailored to disabled learners, ensuring that digital services and platforms support all disabled people. They stressed that removing the digital skills gap is essential for independent living and lifelong learning. Respondents also advised that Artificial Intelligence and Data Protection should include protections against algorithmic bias in employment, benefits, and health services was referenced.
Accessibility was consistently mentioned as fundamental in public-facing digital services. Respondents urged clear accessibility standards across all online and telephone reporting systems, ensuring compatibility with assistive technologies and provision in British Sign Language (BSL), and accessible formats such as Easy Read, and voice-to-text. Additionally, there was a call for digital platforms and services to comply with Welsh Language Standards, ensuring equal access for Welsh speakers, including disabled Welsh speakers, and preventing additional barriers to participation.
Respondents pointed out that employment opportunities were closely linked to digital inclusion, advocating for public campaigns to raise awareness of assistive technologies that remove barriers to work, travel, leisure, and essential services, particularly for blind and partially sighted people. They also emphasised the importance of grants and upskilling initiatives that encourage organisations to make technology more accessible, alongside strategic planning for NHS-issued devices and robust reporting systems on accessibility. They expressed concern that without targeted digital actions in the Plan that technology risks becoming a barrier rather than a solution, especially for older disabled people and disabled people in rural communities. The need for a long-term route map for digital and assistive technology in Wales, to improve outcomes for disabled people was highlighted.
Children and young people
Some respondents felt that the sections in the Plan that focused on children and young people were written from an adult perspective and needed to better reflect the challenges faced by children and young people. Respondents advocated for establishing a dedicated theme within the Plan focused on Children and young people, separate from the Education theme, to reflect that early support is crucial for long-term independence. They emphasised the need for explicit mention of early years support, including pregnancy, childcare, nursery, and playgroups as well as inclusive play and out-of-school opportunities tailored for disabled children and young people.
There was a call for the promotion of rights advocacy for disabled children and young people of all ages. Respondents stressed the importance of teaching disabled children about their rights, the Social Model of Disability and the United Nations Convention on the Rights of Disabled People (UNCRDP). They also recommended expanding this education to parents, carers and targeted professionals and service providers who work with children and young people. Additionally, feedback highlighted the need for health and social care services to be specifically tailored to the needs of disabled children and young people.
Insights from a commissioned focus group of young people concentrated on the challenges of transitioning from child to adult services. Participants expressed concern over the lack of safe spaces and support in Wales for disabled young people once they reach age 25, which can lead to increased isolation and loneliness. Emphasising the need for improved access to support and advice services, they also raised concerns regarding post-16 education and the development of lifelong skills, calling for more skills workshops on managing money and home safety for young people living independently for the first time. Other respondents supported the inclusion of explicit reference to post-16 education, training and pathways to college or employment, highlighting the pivotal role of Further Education (FE) institutions in this transition.
Feedback from this focus group stressed that disabled children and young people want to be heard and included in making decisions that will affect them. The plan should create opportunities to amplify young voices in shaping meaningful change and enable them to plan for their own futures.
Parents and carers (including unpaid carers)
Respondents said the Plan should better embrace the Social Model of Disability by clearly recognising carers and unpaid carers as essential in the lives of many disabled people. Critical areas noted for improvement in the Plan include implementing stronger financial support for families facing healthcare and care-related costs (particularly during the cost-of-living crisis), providing clearer employment support and reasonable adjustments for working carers and establishing better respite services and financial recognition for paid and unpaid carers, aiming to reduce carer burnout and support well-being.
Contributors emphasised the need for more support for parents of disabled children in the early years and the need for more support for parents and carers to their children with play and recreation opportunities. There was also a need to ensure steering groups and coproduction include parents and carers of disabled children from the beginning.
Respondents also said the plan should address gaps in supporting families with disabled children, including ensuring parents understand their children's rights to inclusive education and recreation. Including more about family life and relationships would help capture the full picture of ‘Independent Living’.
Some families spoke of the challenges they face as their children experience exclusion within educational settings, which often reinforces wider divisions and fosters feelings of apprehension and mistrust within communities. They suggested that there is greater potential for progress in the Plan envisioning streets, shops, cafés, places of worship, and homes that are welcoming to all. In particular, they stressed that healthcare and other services should consistently embrace the social model of disability, ensuring that disabled children are recognised as valued members of society from the outset.
Some respondents said that unpaid carers are often missing from plans and discussions relating to people with learning disabilities, causing an instant barrier to access to society for the person with disabilities. They wanted to see recognition and involvement of carers at all levels of planning, delivery, and monitoring of services, to ensure that the voices and needs of both individuals with learning disabilities and their carers are valued.
Workforce training and the Social Model of Disability
There was consensus that comprehensive, mandatory workforce training with a focus on practical skills and disability, is essential across all public services, essential care providers, the justice system, and cultural and leisure services to effectively implement the plan. Respondents emphasised that training must go far beyond basic awareness-raising of disability but should embed practical skills and the Social Model of Disability into day-to-day practice. Training should be Rights-based and avoid deficit-based medical framings and instead be co-designed, co-delivered by disabled people to ensure authenticity and impact. Inclusive employment training was also highlighted; when delivering disability awareness and customer service training, include content on the importance of providing services bilingually and promoting the Welsh language as a right for service users.
Respondents highlighted that PGCE programmes and educational settings need robust training on the Equality Act 2010, reasonable adjustments, and use of assistive technology, with particular focus on addressing shortages in autism-specialist educators and ensuring BSL qualifications for staff teaching Deaf learners. Some suggested a need for BSL and deaf awareness training for frontline staff in public services to ensure BSL users can access services in their preferred language without delay or compromise and to promote cultural understanding and reduce stigma.
In Health and social care, including domiciliary care, mandatory face-to-face training with disability champions, high-quality dementia training, and trained vision rehabilitation services, were noted as essential by respondents. Respondents wanted outcomes relating to ensuring staff receive the training necessary to ensure blind and partially sighted people’s dignity and to communicate with them in a way that meets their needs to be included. Respondents stressed that training across services must be legally mandated rather than temporary initiatives, and co-designed and co-delivered by disabled people. There was significant frustration that current training often fails to equip staff to act differently, leading to continued exclusion and poor service delivery.
New issue raised
Climate change, environmental resilience and emergency planning
Respondents highlighted the disproportionate impact of climate change on disabled people, noting flooding and heatwaves pose particular risks and that climate change is absent from the Plan. They emphasised the need for accessible emergency services and crisis response. Improved training for emergency responders and clear care pathways during urgent situations were recommended. Respondents also called for more emphasis on topics such as Climate change and Accessible travel.
Several respondents highlighted the need for Strengthened emergency planning and crisis response in community settings, leisure venues, and public services. Respondents said it is vital to ensure disabled people are protected from severe weather event and power cuts. Additionally, there must also be learning from COVID-19 and the impact that had on disabled people in Wales.
In addition, respondents highlighted that adaptive equipment and single-use plastics are often necessary for disabled people, yet these needs are frequently overlooked in environmental strategies. Disabled people are sometimes unfairly blamed for relying on single-use plastic products, without recognition that suitable alternatives are often unavailable. Climate change planning must explicitly support disabled people and address their needs, especially as extreme weather conditions become more common.
Detailed qualitative data
Format of the summary for each consultation question:
- Quotes: key points are emphasised with quotations to highlight significant insights or comments made.
- Thematic headings: sections are divided by relevant headings, based on feedback, to make navigation straightforward.
- Recommendations: bullet points list the main recommendations for the plan, drawn directly from responses to ensure clarity and quick reference.
- Summary: at the end, a concise summary capturing the core responses to this question.
Question 1: the ambition
The Disabled People’s Rights Plan has this overarching ambition:
The Welsh Government is committed to promoting the rights of disabled people, and to ensure disabled people are included and able to participate in all communities in Wales. We want to make Wales an inclusive and accessible place for disabled people; a society where disabled people can participate without limits or restrictions and are empowered to lead fulfilling lives, where their individual and collective rights are recognised and upheld and where their contribution is recognised.
We asked you
Please tell us what you think about our proposed ambition. Is this the right ambition to improve equality for disabled people in Wales? What, if anything, could be added to or removed from this ambition?
You told us
Yes, we believe this is the right ambition to improve equality for disabled people in Wales. There also needs to be a commitment that Welsh Government will work together with disabled people to ensure communities are inclusive and accessible and ensure close monitoring throughout the duration of this plan to ensure these are being upheld.
All Wales Forum of Parents and Carers of People with Learning Disabilities.
Social Care Wales would like the ambition to clearly articulate that the aims are ambitious, will take the whole public sector to collaborate to achieve long term systemic change, which goes beyond a plan. We also feel that the ambition could go further to be clearer on broader anti-discrimination and it’s tackling of ableism, which unfortunately is the lived experience of many disabled people in Wales.
Social Care Wales.
Accountability and oversight
- The ultimate measure of success will be that each individual feels valued and that they belong to their community and nation.
- Needs to be measurable and backed with funding.
- [Needs] concrete language about practical steps, co-production with disabled people, and measurable outcomes.
- If they [Welsh Government] signed up to the UNCRPD and did it right, we wouldn’t need this plan.
- Include a specific reference to the UN Charter for the Rights of Disabled People as a benchmark, noting that the Rights Plan is already structured around the charter.
- Feel particularly strongly that education especially the training of teachers through PGCE programmes and within schools, colleges, and universities; should include both awareness of this plan and a strong understanding of the Equality Act 2010, including reasonable adjustments, as well as the social model of disability.
Discrimination, prejudice and ableism
- Could go further to be clearer on broader anti-discrimination and it’s tackling of ableism, which unfortunately is the lived experience of many disabled people in Wales.
- There is no reference to ableism, discrimination or systemic inequality. While the ambition is positive in its aim, not acknowledging and naming these core issues means there is no way to address these key barriers, measure progress or create actions focussing on these systemic issues.
- Include a clearer commitment to enforceable rights, trade union engagement, and the elimination of poverty and structural discrimination, which remain significant barriers.
- A commitment to challenging prejudice, discrimination, and hostility towards disabled and chronically ill people wherever it occurs.
Inclusion and rights
- Despite being framed through the lens of the UNCRDP the absence of any firm commitment to deliver on the Welsh Governments commitment to incorporating the UNCRDP into Welsh Law signals a weakening, not a strengthening of existing commitments to protect Rights.
- Should be clear what we mean by rights and explicit in what the Government will do.
- Acknowledge that disabled people face layered inequalities due to factors like race, gender, age, or socio-economic status.
- Uphold and recognise the rights of disabled people, should be the minimum standard, not the overarching ambition.
- Explicit mention of transport, digital, and economic inclusion.
- Make clear who the plan is referring to as everyone has their own definition of who is disabled.
- Be aware of other work already underway across Welsh Government and to ensure alignment where appropriate… the Ministerial Advisory Group for Neurodiversity.
- Disabled people must have structural power, advocacy support, and accessible enforcement mechanisms in place to assert those rights effectively. Without these, even the most well-intentioned ambitions will fall short in practice.
- Address the reduction of health inequalities, which is a critical component of disability justice.
Children and young people and education
- Commit to inclusive education, something that is currently lacking in Wales.
- Segregating families leads to perpetuation of segregation in society, fear and distrust.
- Add something along the lines of "societal attitudes are shaped in childhood”.
- Requires coordinated and sustained efforts within schools and across education systems.
- Barriers to the presence, participation and achievement of learners should be identified and addressed.
Homes and transport
- Mention housing as a key part of the overarching ambition of the disabled rights plan.
- Embed digital inclusion into this ambition in the context of making Wales an inclusive and accessible place.
- Refer to transport without losing the conciseness of the statement.
- Include digital accessibility, more ambitious housing targets, increased service availability, and more meaningful co-production with people with complex conditions such as motor neurone disease, would help improve the plan.
- Mention of transport, digital, and economic inclusion. Access to employment, digital services, and especially accessible, affordable transport is essential to full participation.
- This is the right ambition, add commitments around accountability, intersectionality, and access to transport and other essential enablers of participation.
- Barriers to disabled people cycling should be removed.
Summary
A wide range of respondents generally welcome the ambition for disabled people in Wales, and appreciate the Welsh Government’s commitment to rights, participation, and equality. Many organisations and individuals recognise the ambition as a meaningful step forward, aligning closely with values and co-production.
There was recognition for the Welsh Government’s approach, particularly the ambition to foster inclusive communities and a more realistic timescale for achieving systemic change. Respondents valued the ambition’s commitment to embedding the Social Model of Disability, moving away from medical model perspectives and placing emphasis on society to remove barriers many disabled people continue to face.
Respondents commented on the ambition’s potential to push to long-term, systemic change, provided it is supported by the whole public sector. They supported the emphasis on inclusion, accessibility, and participation and appreciated the recognition of the right of disabled people to be involved in shaping services which impact them. Some respondents highlighted the ambition could significantly improve community participation, especially with commitments to co-production and accountability.
Respondents also identified challenges and areas requiring improvement. Many noted that the ambition, while commendable, will lack impact without more measurable commitments and outcomes, and sufficient funding. Respondents called for clearer language around action, accountability, and the practical steps the government will take. Additionally, some respondents highlighted the need for a clear reference to a discrimination free society, as well as stronger commitments to tackling ableism and other forms of prejudice that many disabled people continue to experience in Wales.
Further feedback emphasised the importance of broadening the ambition to acknowledge intersectionality, recognising that disabled people may face overlapping inequalities due to factors such as race, gender, age, and socio-economic status. Respondents urged that digital, education, transport, and economic inclusion be clearly articulated as essential for full participation in society. The ambition was also described needing to recognise the specific needs of Deaf British Sign Language signing communities, carers (paid and unpaid), and families, as well as the changes required in infrastructure, housing, and education.
Respondents also emphasise that reaching the ambition will require a significant cultural shift within Welsh society, challenging existing stereotypes and negative perceptions of disabled people. Some commented that language and attitudes, both in policy and in the media, continue to marginalise disabled people, and that real progress will only be possible through widespread education and the promotion of positive language.
Additionally securing the rights of disabled people in Wales on a statutory footing in Wales was a recurring policy suggestion.
Question 2: the Plan’s 4 themes
The Disabled People’s Rights Plan is split into 4 themes:
- Neighbourhoods and Places
- Employment, Income, and Education
- Independent Living
- Justice and Supporting Environments
We asked you
Please tell us whether you think these themes are suitable for the plan. Do these themes cover the main issues or barriers that disabled people experience? Are there any missing areas that should be added to these themes? If yes, what are they?
You told us
“Although health is mentioned in certain sections of the plan (notably under independent living) we would like to have seen health given greater prominence, with a theme of its own.”
Down’s Syndrome Association.
“These themes touch on important parts of life where people live, how they work and learn, how they live independently, and how they’re treated in society. It’s good to see a focus on fairness and independence.”
Hywel Dda University Health Board.
- Address Climate Change and Environmental Resilience, highlighting its disproportionate impact on disabled people and aligning with the Well-being of Future Generations Act’s well-being goal ‘A Resilient Wales’.
- Prioritise Travel by adding it to the “Neighbourhoods and Places” theme, addressing its role in reducing social isolation, especially in rural Wales.
- Education is a foundational right to people of all ages, deserving of its own focus.
- Broaden the Employment theme to include Financial Support, reflecting the impact of benefits, extra costs, and Access to Work delays on disability poverty.
- Use plain language, replacing ‘income’ with ‘money’ for clarity.
- Digital Inclusion and Accessible Communication should be added as a standalone theme or clearly integrated across all existing ones, with firm commitments to removing digital barriers.
- Must welcome and support disabled students and also work with employers within Wales who will support disabled graduates through targeted work experience and recruitment schemes.
- Harness the network of Welsh Universities and Medr in Wales to develop a forum for disabled staff and students. Such a Forum could help build a Disabled People's Chartermark for Higher Education in Wales.
Health and well-being
- Separate Health and Well-being (including mental health and recreation) from Independent Living theme to ensure this has its own focus and is demonstrated as a priority over the next decade.
- These themes cover the main issues and barriers for people living with Crohn’s and Colitis outside medical support for their condition, keeping symptoms under control.
- Access to medical help seems to be missing, and that is the biggest barrier we face, whether it is buildings and facilities designed with wheelchair access thrown in as an afterthought, or insisting that people with Alzheimer's disease (or other memory problems), have to accept medical consultations by telephone.
- Reference emotional wellbeing and access to mental health services in the plan.
- Include family life and relationships within the Independent Living theme to reflect disabled people's support networks and promote genuine inclusion.
- Culture should be made more prominent in the plan with specific targets and funding for sport and culture. Participation in the arts, sport and heritage is a right under the UNCRDP and is an essential part of a fulfilling life.
Justice and supporting environments
- Pleased to see Justice and Supporting Environment theme but are unclear what is meant by ‘Supporting Environments’.
- Does the section include Policing and Criminal/Family/Civil Justice?
- Perhaps it would be better to rename the theme to Access to Family, Criminal and Civil Justice.
- Consumer advice should be added as important social welfare advice.
- Need to correctly assess councils play sufficiency assessment when it comes to diverse needs.
- Challenge the segregation that continues in supported living and services, and uphold the right to an ordinary, self-directed life.
- Focus on leisure, learning, and community participation: Access to leisure facilities, fitness, learning activities, and inclusion in community life.
Summary
Respondents felt that the overarching themes within the Plan are broadly suitable and reflect many of the barriers disabled people face. However, more focus on community was proposed and respondents suggested that in grouping themes together, some themes might ‘get lost’ and lack targeted focus or attention. Access to digital technology is important for so many aspects of life and will certainly be a prevalent issue for disabled people over the lifespan of this 10 year plan.
Additionally, many respondents suggest that Health and Well-being (including mental health and recreation) is separated from Independent Living and is prioritised as a standalone theme within the plan to demonstrate the Welsh Government’s commitment. Nature and green spaces were deemed vital for physical and mental health, especially for disabled people, and specific mention of this was encouraged for the plan.
Additionally, recommendations call for prioritising independent living, inclusive education, and economic inclusion for disabled people by incorporating equality and human rights standards into policy and practice.
Respondents emphasised that education deserves its own focus, separate from Employment and Income. Respondents feel that education is a basic right and key to future independence.
Respondents said that the Employment and Income theme should be clearer and more inclusive. Many disabled people face poverty not just because of low wages, but due to benefit issues and extra costs. The word “income” should be replaced with “money” to make it easier to understand. The theme should include financial support, budgeting skills, and access to benefits, especially for those who can’t work due to health reasons or are living independently for the first time.
Some respondents said the plan would benefit from clarifying what each theme covers. For example, some respondents felt that vague terms like “Justice and Supporting Environments” and ‘Independent Living’ were confusing. They called for clarification or renaming of these sections because of the degree to which they are misunderstood and open to varying interpretations.
Some respondents said disabled graduates can be overlooked so it is important that they are supported within higher education and in that critical transition when leaving university and entering the labour market. Many Government services aimed at supporting disabled people do not cater directly for disabled graduates and low aspiration assumptions about the types of jobs suitable for disabled people, mean they are not supported into professional careers.
Respondents expressed that education should be prioritised as a distinct theme within the Plan, rather than grouped under ‘Employment, Income and Education’, recognising education as a fundamental right for people of all ages. They voiced disappointment at the absence of explicit references to accessible pathways to employment, transitions from education to the workplace, supported employment, and support mechanisms to help disabled people remain in work. Additionally, respondents highlighted the crucial role played by staff in fostering inclusive organisational cultures across Further and Higher Education settings.
Respondents also called for more emphasis on topics such as Climate change and Accessible travel, particularly in rural areas where poor transport links can lead to social isolation. Some respondents suggest adding Travel to the Neighbourhoods and Places theme title. A focus group of learning-disabled adults called for Travel to be a standalone theme, separate from Neighbourhoods and Places to recognise its role as a foundational enabler for independence, employment, healthcare, access and social participation justifying the need for greater emphasis.
Other recommended themes to embed throughout the plan include Intersectionality, and Economic Dignity, and for people with learning disabilities. There was a call for the plan to reflect a commitment to economic dignity and intergenerational fairness, particularly to address the long-term impacts of austerity, welfare reform, and poverty on disabled people’s lives. These respondents advocated for a rights-based approach that centres dignity, security, and autonomy.
Finally, many of the younger participants felt positive about the plan but felt confused by the amount of information and the language used. The children’s version of the plan should be made simpler and easier to understand, with clear goals and timelines to help young people see how the plan will benefit them.
Question 3: main topics
The Plan sets out the following main topics. These topics are split into 10 themes:
- embedding and understanding of the Social Model of Disability
- access to services
- independent living: social care
- independent living: health
- travel
- employment and income
- affordable and accessible housing
- children and young people
- access to justice
- well-being
We asked you
Do these topics cover the main issues or barriers that disabled people experience? Are there any missing areas that should be added to these themes? If yes, what are they?
You told us
The topics in the plan cover many important areas, and it’s reassuring to know they were identified with the involvement of disabled people, they’re best placed to say what matters most.
Hywel Dda University Health Board.
The topics in the plan are well-chosen, but their effectiveness depends on recognising the interconnected nature of these barriers and the impact of privilege and economic inequality. A truly inclusive Wales requires not only addressing each area in isolation but also understanding how they interact to shape disabled people’s lives.
Focus Group commissioned by Welsh Government.
Health, well-being and social care
- Well-being to encompass respite care, healthy relationships, social inclusion (to prevent feelings of isolation), participation in cultural life, reference to green and blue spaces, access to leisure, art, culture, and sport as per UNCRDP rights.
- Social Care as its own distinct topic, to ensure focused policy development. This should address safeguarding.
- Focus on access to welfare benefits and expanding benefit advice services across healthcare and third-sector settings.
- Disability advocates in police stations and hospitals.
- Absence of Older People as a distinct topic and recommends its explicit inclusion as a standalone topic to address the unique barriers that older disabled adults face.
- Ensure decision-making across the life cycle is supported.
- Gender bias in health responses.
- Prioritise protective data collection on disabled people, especially those with learning disabilities.
Transition (children to adult services)
- A focus group of adults with learning disabilities also called for a topic dedicated to ‘Transitions and Life Stages’, stating that the challenges of disabled people often shift over time.
- More attention should be given to key transition points, such as moving from education to employment, or from child services to adult services, which are often where support systems break down.
Children and young people
- Tackle restrictive practices in education (use of restraints, seclusion, segregation).
- Explicitly ensure that disabled children and young people can exercise their right to education, feel safe and be included in their educational and childcare settings, where their educational needs are identified and met, as well as through learning that reflects the needs, experiences and rights of disabled people.
Accessibility and environment
- Rename ‘Travel’ to ‘Travel and Transport Systems’ for clarity. This theme should go beyond mainstream public transport to include community-led transport services and accessible transport options for healthcare, employment, education and social activities.
- Add ‘Streets and Communities’ as a main topic to reflect environmental barriers to independence.
- Calls for built environment improvements, including the enhanced accessibility of streets and pavements, drop kerbs, active travel routes, public buildings and personal care provision in community settings. It could also address general attitudes leading to blocked pavements and misuse of disabled parking.
- Calls for joined-up housing strategy, stronger recognition of housing as a vital part of independent living.
- Improve legal aid for housing disputes which is limited or unavailable in Wales.
- There should be stronger links between this topic and Travel, both essential for independent living.
- Disabled people face legal and practical barriers in accessing suitable housing.
- More focus in the plan on Climate Change, Environmental Resilience and Emergency Planning.
Communication and language access
- Improve communication accessibility for individuals with additional speech and language needs.
- Clarify and reinforce the plan’s commitment to the Social Model of Disability and consider the Linguistic Model for Deaf signers to better reflect experiences.
- Ensure communication is accessible across BSL, Welsh and English, and in formats such as Easy Read, recognising that not all disabled people have the same linguistic or cognitive needs.
- Makaton and other pictorial systems are currently absent from the plan and must be included to reflect the full spectrum of communication needs.
- Strengthen commitments to expanding and promoting BSL use across public services.
- Incorporate specific recommendations about developing and investing in the BSL interpreter workforce in Wales.
Community participation and representation
- Beyond access to services, disabled people want to shape their communities. Include civic engagement, leadership opportunities, and co-production in decision-making.
- Empower disabled people as leaders, voters, trustees and decision makers in shaping policies that affect their lives.
- Call for ‘Democracy and Civic Participation’ as a core topic within the plan.
- Include ‘Access to Communities’ as a key topic, including care and mobility support.
- Address access to general services such as banking, especially in the context of cashless societies and bank closures in Wales.
Legal system
- Expand ‘Access to Justice’ topic to include bullying and harassment, accessibility of court buildings, inclusive legal processes and adequate legal representation.
- Stronger protections needed against hate crime.
- More information and support for victims fearful of reporting abuse or discrimination.
- Calls for trauma-informed, accessible legal services (including advice and information) which have been co-designed with disabled people.
Summary
Respondents expressed support for how the Social Model of Disability has been embedded throughout the plan, recognising this as a foundation for meaningful change in Wales. One respondent stated that this is imperative towards a movement of shifting attitudes, removing systematic barriers and tackling unconscious /conscious biases in society. This respondent proposed changing the ‘Embedding and Understanding the Social Model of Disability’ topic to ‘Social Model of Disability and Human Rights’ so be clearer on the rights of disabled people in Wales and how the plan will seek to address them.
A focus group of women with non-visible impairments expressed limited knowledge about their rights and the Social Model, urging Welsh Government to consider how its messaging might strengthen the Social Model’s applicability to those living with long-term, fluctuating, recurrent, non-visible health conditions so that this population group and other disabled groups are more confident in referring to this model, including in the context of medical intervention and management.
Respondents appreciated the engagement of disabled people in identifying the topics set out in the plan, through the work of the Disability Rights Taskforce. Feedback was that the topics were broadly representative of the issues that many disabled people identify as barriers.
While the plan is comprehensive in many respects, some respondents felt there are important considerations that should either be explicitly included or strengthened within the existing topics.
Feedback recommended that the plan needs to have a clearer long-term strategic ambition and demonstrate how it will adapt to future trends, such as an ageing population, emerging technologies, and changing health and care needs; all of which were strongly recommended to add to the existing topics. Adding these crucial topics would ensure the plan is viewed through a long-term and preventative lens which is core to the Well-being of Future Generations Act.
Question 4: our actions
The short-term actions published alongside the plan, sets out the steps we want to take now. There will be more actions by future governments to support us to achieve the long-term outcomes.
We asked you
Please tell us whether you think these short-term actions will help deliver the long-term outcomes? Will these actions help reduce the problems and barriers that disabled people face? Please give reasons for your answer if possible.
You told us
Measurable outcomes, accountability and transparency
“We’re glad to see a focus on early action. It’s important that short-term plans are made together with disabled people, especially those facing many barriers. Llais is concerned that without inclusive ways to track progress and get feedback from people, good ideas might not lead to real change. There must be clearer timelines and monitoring structures put in place to make sure these actions are tracked and adjusted based on people’s feedback of their experiences.”
Llais.
“The short-term actions outlined are a positive start, but their impact will depend on implementation. We recommend clearer timelines and accountability measures.”
Newport City Council.
- [The actions] are not all directed towards meeting the outcomes.
- They [the actions] must be more ambitious, more focused on delivery, and better aligned with the urgency of the issues disabled people face.
- Too much emphasis on scoping, reviewing, and piloting, and not enough on immediate, tangible improvements.
- Would welcome continued emphasis in the short and longer-term on implementing the Wales Trauma-informed Framework, recognising that the barriers.
- The actions don't really address funding issues.
- Need adequate funding and resources to ensure actions are not just symbolic but lead to real change.
- Welcome the action on health economic measures including Quality Adjusted Life Years and Disability Adjusted Life Years impacting on NHS.
- Prioritise actions that tackle the disability employment gap, such as requiring public sector employers to report and reduce pay gaps.
- Include specific short-term measures to strengthen disability rights at work, including trade union consultation.
Information and inclusion
- BSL signers need to be considered in implementing short term actions. For example, introducing fast track learning for BSL learners to progress to registered interpreters is a short-term action which should lead to increased capacity in future.
- Like to see a target including the Short-term Action Plan relating to wider availability of Easy Read materials.
- The short-term actions do not go far enough to address digital exclusion.
- There is a lack of strategic planning to ensure that provision is in place to accept disabled children in Welsh language settings. Actions should urgently address this inequity.
- Homes Not Hospitals campaign, this requires an urgent response from the Welsh Government and should be included in as a short-term action.
- As well as supporting the wonderful employment champions there needs to be somewhere for people to go when they experience barriers to employment.
- Prioritise actions that tackle the disability employment gap.
- Coproduction should be embedded as a core approach.
Access to communities
- Address the unique challenges faced in rural Wales, including isolation, limited public infrastructure, and transport poverty.
- Accessible community transport is vital in rural areas.
- On venues there should be no music venues that is out of bounds for wheelchair users.
- For young wheelchair users getting the right equipment from NHS Wheelchair Services is the key driver to maximise independence, confidence and wellbeing.
- More travel passes for all hidden disability.
- Consider an additional action focused on deaf people requiring mental health services.
- Include working with housing associations as a major contributor to providing accessible, adapted homes.
- Should compel public bodies to work together to ensure appropriate transport for disabled people.
- Existing development requirements for disabled people feel disjointed. For example, where the provision for a wet room is required, but the space standards in a hallway may not always support a wheelchair user to access it, therefore making the wet room provision feel tokenistic.
Children and young people
- The financial support available for childcare should be based on the needs of the child and the setting and not on the eligibility of parents.
- Childcare Offer, urgent action is needed to ensure that the output to the review of the Additional Support Grant addresses this gap.
- Education needs to be at the forefront of this project with children being taught that being different is normal and that no two people are the same.
- Children and young people deserve opportunities in play, sport and socialising.
Raise awareness in schools and colleges to learn more about hidden disability.
Summary
Respondents broadly welcomed the introduction of a short-term actions document, viewing it as a good start toward improving outcomes for disabled people. Many emphasised the need for clear measurements and accountability to ensure that progress is both tangible and maintained. Concerns were raised that the plan relies too heavily on ‘reviewing’ and ‘signposting’ rather than delivering immediate, concrete improvements. In addition, respondents highlighted the importance of strengthened accountability, clarity around funding, and regular transparent reporting to track progress and uphold the plan’s effectiveness.
Greater integration of the social model of disability was strongly recommended, particularly in health and care settings, with calls for upskilling professionals and organisations, and for embedding this model across all aspects of policy and service development.
While the employment section was welcomed, respondents urged greater ambition, including targets for closing the disability employment gap, improved recruitment and retention policies, and awareness campaigns. There was emphasis on supporting unpaid carers in employment and ensuring reasonable adjustments are clearly understood and accessible. They advocated for the co-production of strategies, involving disabled people and their families in the planning, implementation, and review of all actions. Calls were made to increase the availability of Easy Read materials, particularly to support those with learning disabilities.
A lack of accessible housing was highlighted as a persistent barrier, with calls for cross-sector planning, more accessible accommodation (especially for those fleeing violence), and inclusion of people with learning disabilities in housing strategies. Respondents also called for integration of inclusive design standards and support for independent living, including specialist rehabilitation. While some actions are welcomed, respondents caution that ambitions for housing reform may be unrealistic in the short term without significant investment and cross-sector partnerships. There are also calls for improved data collection, better information for unpaid carers, and a more consistent delivery of housing adaptations and equipment.
A lack of accessible transport, particularly in rural Wales, remains a significant barrier. Feedback called for more explicit actions to address accessible public transport, support for personal assistants, and joined-up approaches across education, transport, and social care. Respondents stressed the importance of involving disabled people in designing and reviewing transport solutions, including regular consultations and accessible information in multiple formats.
Respondents welcome the focus on mapping accessible parking and inclusive transport panels but point out omissions such as a lack of detail on bus reform and rural transport challenges. Feedback emphasises the need for accessible information, regular and genuinely inclusive consultations, and ongoing staff training that involves people with lived experience of disability.
Education and awareness across all sectors are viewed as pivotal to achieving long-term outcomes. Respondents call for cultural change in schools, workplaces, and communities, with better disability awareness, anti-discrimination initiatives, and inclusive education.
Respondents advocated for greater emphasis on prevention, early intervention, and collecting reliable data, especially regarding people with learning disabilities. The intersectional approach was highlighted as showing promise, especially in its commitment to consulting disabled people from Gypsy, Roma, and Traveller communities, to better understand and address their unique barriers.
Additional gaps were identified in areas such as inclusive education, employment support, and access to venues and public spaces. Respondents highlighted that societal attitudes are shaped from childhood, making inclusive education essential for lasting change. Overall, while the short-term plan provides a good foundation, it must evolve to focus on delivery, accountability, and the specific needs of disabled people in Wales, especially those in under-resourced communities.
Question 5: neighbourhoods and places
‘Neighbourhoods and places’ is made up of the following themes: travel, housing and the Social Model of Disability.
We asked you
Will the proposed outcomes set out in ‘Neighbourhoods and Places’ help reduce the problems and barriers that disabled people face? What, if anything, should be added or removed from these outcomes? Please give reasons for your answer if possible.
You told us
Outcomes
“This outcome rightly recognises that accessible information is a cornerstone of independent travel.”
Royal National Institute of Blind People.
“Accessibility is not just about buildings or pavements, it begins and ends with the ability to travel. Without fully accessible, affordable, and reliable transport, including community transport services, disabled people are effectively excluded from participating in society.”
Dolen Teifi Community transport organisation.
Housing and accommodation
- There is a need to increase the supply of accessible and affordable housing, particularly social housing.
- Disabled people should have stronger rights to adapt their homes, including in flats and rented properties.
- The language of Outcome 2 should be strengthened. Respondents suggested changing “availability” to “supply and availability of accessible housing”.
- Accessible housing registers would be a significant improvement and their inclusion in the Homelessness and Social Housing Allocations Bill is welcomed.
- Barriers in the private rental sector need to be addressed, with concerns that “no-fault” evictions can deter or prevent adaptions. Welsh Government should commission research to fully understand unmet demand for accessible housing and current provision.
- With just a focus on housing, transport and the social model, the complexity of how communities interact and thrive will be missed, along with significant opportunities to address the loneliness and isolation that faces disabled people and people with learning disabilities across Wales.
Transport and travel
- Introduce national accessibility standards for transport, covering audio-visual announcements, accessible bus stops, tactile paving, wayfinding, and consistent signage.
- More detail is needed on the Multi-Modal Disabled People’s Inclusive Travel Panel, including timelines, and representation of disabled people.
- Align plan with existing policy, such as the "Travel for All" documents.
- Community travel should be prioritised as a core part of an inclusive transport system, especially in rural areas where reliance on volunteers leaves many stranded.
- Accessible information on Blue Badge parking spaces and increased provision of spaces was called for. One respondent suggested different categories of badges for people with mobility impairments and those with invisible disabilities.
- Operators should have clear protocols for medical emergencies to support passengers with long-term conditions.
- Prioritise community transport as a core enabler of access.
- To prevent social exclusion for people with Crohn’s and Ulcerative Colitis it is essential that public transport offers good access, adequate facilities and reliable information.
- Include the availability and cost of toilets, unexpected closures, and the accessibility of replacement bus or coach services.
Access and infrastructure
- There is a lack of focus on access to private sector spaces such as shops, hospitality venues, gyms, places of worship and cultural events.
- Commitment to basic amenities such as public toilets, public seating, safe paths, clear signage, and sensory-friendly spaces.
- Develop an App that has accessible places to visit in Wales, for wheelchair friendly day trips and disabled accessible activities and recommendations.
- Consider design and access standards for publicly funded places, including features to support people with hearing loss and neurodiverse people.
- Training on the social model of disability, alongside deaf awareness training and use of assistive technology.
- Improve perception of Deaf and Disabled people was keen as key to tackling hostility and hate crime.
- The outcomes would be significantly strengthened by explicitly recognising the role of digital inclusion in enabling full participation in local life.
Summary
The majority of responses agreed that the proposed outcomes under ‘Neighbourhoods and Places’ could help reduce the barriers for disabled people, provided they are implemented with clear timescales, measurable targets, and meaningful co-production. Community-led solutions and engagement with disabled people, including children and young people, were highlighted as vital to ensure services reflect lived experience. One third sector organisation advised coproduction should be embedded in decision-making processes.
Awareness training and community engagement were widely seen as ways to reduce stigma and “everyday ableism”, improve public attitudes, and create safer, more supportive neighbourhoods. One respondent emphasised that such activity should co-designed and delivered by disabled people.
Views on the social model of disability were mixed. Most welcomed its inclusion, while others argued it could set unrealistic expectations if used in isolation. Some respondents, particularly those representing people with chronic and / or fluctuating illness, felt greater balance was needed between the social and medical models, recognising that medical treatment is a priority for some disabled people. Transport attracted significant attention. respondents called for community transport to be recognised as a key part of an inclusive system, especially in rural areas. Barriers raised included affordability and inconsistent fares, reliance on cashless systems, and ticket office closures. Accessible information was highlighted as important during service disruptions, and many notes negative attitudes and limited awareness of invisible impairments among staff. Beyond services, respondents stressed the need for safe street and accessible public spaces, including pavements, toilets, and seating.
Digital inclusion was also raised, particularly in relation to transport. Several responses highlighted the importance of digital accessibility for transport service, particularly for people with sensory impairments, cognitive disabilities, or conditions affected by stress and unpredictability. One respondent outlined anecdotal evidence that technology (such as visual display screens, or inaudible announcements) is often broken and the problem not resolved quickly. Another respondent suggested all travel apps should be voice operated. More generally, it was noted that the plan needs to align with the Digital Strategy for Wales and the Digital and Data Strategy for Health and Social Care in Wales.
Parking and mobility were raised through discussion of the blue badge scheme. Respondents called for more spaces and better information. Suggestions included separate categories of badges for server mobility impairments and invisible conditions, and greater flexibility to reflect fluctuating needs.
On housing, respondents highlighted the lack of accessible and adaptable homes across Wales, as well as the importance of housing designed with accessibility in mind, improved protection for tenants in the private rented sector, and better alignment with existing policies, including use of the Accessible Housing Register
Finally, accountability was a strong theme. Respondents wanted clearer measures of progress, regular public reporting, and stronger enforcement of accessibility standards. One respondent felt Welsh Government must take a bolder approach to regulation through procurement, licensing, planning and inspections to ensure commitments are delivered in practice.
Question 6: employment, income and education
We asked you
Will the proposed outcomes set out in ‘Employment, Income and Education’ help reduce the problems and barriers that disabled people face? What, if anything, should be added or removed from these outcomes? Please give reasons for your answer if possible.
You told us
“We need stronger accountability, income resilience, meaningful employer compliance, and intersectional support to ensure disabled people can not only access jobs and education but sustain and progress in fulfilling careers.”
Office of the Future Generations Commissioner for Wales.
“These outcomes are positive in theory, promoting inclusivity and a commitment to reduce the barriers people with a learning disability face. However, there is still a lack of measurable outcomes and deadlines.”
Learning Disability Wales.
Achievability and measurability
- The short-term actions will go far enough in moving us forward and there are no detailed medium/long-term actions that set out how these ambitious outcomes will be achieved.
- It is important that interventions are not advocated without clear evidence that they will achieve the intended outcomes, based on actual changes to employment rates and outcomes.
- We firmly believe that [support] must be [for] long term employment that provides adequate financial stability and satisfaction for disabled people. Research indicates that as much as 50% of the employment undertaken by disabled people is low in pay, part-time or even short-term.
Inclusive pathways and co-produced support
- Important for both employment and education policies to be co-produced with people with a learning disability and their families, to ensure they reflect the real-world barriers faced within the workplace and in school.
- Changes must include inclusive spaces, with disabled and non-disabled learners learning together, just as the UNCRPD envisions.
- Provision of lifts, ramps and physical access needs to be obligated such that wheelchair users can access businesses as users, visitors and employees.
- Outcomes should include measures to ensure that mainstream and further education settings support learners with learning disabilities, including through appropriate teaching, accessible information, and staff training.
- The outcomes should include commitments to wraparound, co-produced pathways that span employment, social care, education, and benefits.
- Although mental health is mentioned, the plan could do more to address the specific needs of neurodivergent people, including access to diagnosis, support in education and employment, and tailored mental health services.
- A major theme was the lack of reasonable adjustments in the workplace.
Children and young people
- Like to see this part of the plan be joined directly to the work that is ongoing around the delivery of the RSE curriculum. Differentiated resources, content and delivery styles will be vital to the success of this work and the connectivity of the two pieces of guidance will ensure that they are not developed or delivered in isolation.
- Urgently develop and publish national guidance for local services to embed auditory verbal therapy within existing support structures, ensuring equality of access for families of deaf children across Wales.
- Invest £80,000 annually for 10 years to train a small proportion of the current sector workforce; speech and language therapists, teachers of the Deaf, and Audiologists as certified Auditor Verbal therapists to help close the gap in education and social outcomes for children.
- Plan should have better links to the Disabled Children's Lives in Wales: Our work and impact this year (1 April 2024 to 31 March 2025).
- Extend the Children’s Commissioner’s remit to cover disabled children and young people up to at least 21 years of age, to make sure they are properly supported during this difficult stage of life.
- Inconsistencies found between areas for SENCO support.
- There needs to be something about access from very early including childcare settings and nursery.
Rurality and transport
- Accessible transport must be integrated, not siloed. Employment and education are simply not possible without accessible, affordable transport. This must include community-led transport provision, not just conventional public transport.
- The plan must ensure that transport is not treated as a standalone issue, but embedded across all themes, including here.
- Transport and accessibility are major barriers. For many, especially in rural areas, the challenge of simply getting to and from work made employment unfeasible.
- Given the rurality of much of Wales, one of the most significant barriers to paid employment for many people who have Down’s syndrome or other learning disabilities is the lack of an integrated public transport system, with suitable transport running at times when people need to travel to and from work.
- Acknowledge staff as playing a vital role in transforming inclusive organisational cultures in Further and Higher education.
- Collect data about disabled people and disabled older workers (in particular) in this sector through recent voluntary redundancy losses.
- For people with sight loss there are challenges with Independent Travel.
Summary
Respondents broadly welcomed the Welsh Government's commitment to inclusive employment and education systems. Outcomes were described as evidence-led and focused on key areas where disabled people continue to face entrenched and structural inequality, with the potential to drive meaningful change. The emphasis on ensuring that employers and educators are aware of their legal responsibilities and the rights of disabled people was particularly supported, as was the Plan’s recognition of the importance of embedding the Social Model of Disability into societal structures and co-production. Respondents raised concerns about the lack of enforceability and accountability mechanisms within the Plan.
Additionally, respondents called for the Plan to embed social partnership principles, ensuring disabled people a direct role in designing accessible workplaces and training systems, and proposed the creation of an Equalities Sub-Group to represent disabled people and other groups with protected characteristics. This group would co-produce guidance to promote and embed positive employment practices in public procurement contracts, including requirements around reasonable adjustments and disability employment data, which they felt should be incorporated into the Plan’s short-term actions.
While inclusive recruitment was referenced in the plan, some respondents wanted to see mandatory adoption across sectors, reinforced through public procurement strategies that leverage government expenditure to enforce accessibility and equity standards. Additionally, the consultation emphasised the need for stronger enforcement of employment rights including reasonable adjustments and protection from discrimination, ensuring that legal duties are actively upheld.
The Disability Confident Scheme was criticised for focusing on self-reported practices rather than measurable outcomes, and there were calls to reform its certification criteria. Respondents reported positive experiences of the Access to Work scheme, saying that the support provided through it resolved some of the challenges experienced; however, concerns were expressed about proposed cuts to the scheme and how it may be under threat, in addition to the significant backlogs currently faced.
There were calls to expand supported employment and job coaching programmes, and map existing employment support schemes to assess their accessibility and effectiveness. Additionally, there was a call for greater support for entrepreneurship and self-employment pathways, recognising the importance of flexible and autonomous work options for disabled people.
There was also a call to acknowledge that some individuals as well as the families and carers who support them are not, and may never be, in a position to work. For this community, whose needs are often more complex, support must be understood as fundamentally different from pathways into education or employment.
In education, respondents welcomed the Plan’s inclusive ambitions but emphasised the need to strengthen the recognition of inclusive education as a legal right. They recommended clearly distinguishing between inclusive education, a whole-system approach where schools are designed to accommodate all learners and inclusion in education, which often places disabled children in mainstream settings without the necessary support, values, or structures to ensure meaningful participation.
There were calls to reverse segregation trends and ensure disabled learners are educated alongside their peers, with courses designed for a range of abilities and flexible accreditations. Respondents also recommended aligning the Plan with existing guidance and initiatives, such as Disabled Children’s Lives in Wales and the delivery of the RSE curriculum, ensuring development of each are connected and not carried out in isolation.
Respondents also called for specific outcomes on early education, including childcare settings and nursery, to ensure that disabled children are supported in understanding their autonomy, rights, and needs from a young age. Broader recommendations included strengthening transitional support from school to employment, improving teacher training on the social model of disability and addressing the need for BSL and autism specialist educators.
The importance of access to inclusive digital learning platforms was highlighted, alongside the need for tailored support for neurodivergent learners, those with non-visible differences or impairments, and individuals with fluctuating conditions.
Additional calls included embedding therapies such as Auditory Verbal within local services to improve access for deaf children, extending the Children’s Commissioner’s remit to cover disabled young people up to at least age 21, and addressing inconsistencies in SENCO support across regions.
Income-related feedback focused on clearer communication around welfare benefits, greater recognition of the additional costs of being disabled, and improved access to financial advice and support. Respondents urged the Welsh government to advocate for disabled people in UK-wide welfare reforms and to ensure that benefits and support schemes are accessible, well-publicised, and user-friendly.
Finally, cross-cutting recommendations include improving transport accessibility in rural areas, digital inclusion, and ensuring disability awareness training across sectors. Also highlighted were concerns around the use of certain terminology, such as ALN, which some felt reflects a deficit-based, medical model language and inconsistent with the Equality Act. Overall, the consultation responses highlighted a need for a joined-up, enforceable, and co-produced approach to delivering meaningful change for disabled people in Wales.
Question 7: independent living
Independent living is made up of the following themes: well-being and health, care and support.
We asked you
Will the proposed outcomes set out in ‘Independent Living’ help reduce the problems and barriers that disabled people face? What, if anything, should be added or removed from these outcomes? Please give reasons for your answer if possible.
You told us
“Independent living means more than remaining at home with a care package. It requires the right to choose where and how to live, who provides your support, and how your daily life is structured. The outcomes should emphasise the importance of co-produced support plans, flexible budgets, and a genuine shift of power toward disabled people.”
Anonymous.
“…there is a long way to go in ensuring that support service providers are properly equipped to meeting varied and intersectional needs. This includes sufficient funding so that services can continue to operate, and frontline workers can be paid fairly for the life-changing work they do.”
Community Housing Cymru.
Health and social care
- The onset of sight loss can cause mental health issues for a person acquiring a vision impairment, so it is important that access to mental health support is available.
- Add something about early years and again mention of supporting parents and carers to support their children with play and recreation.
- Reflect the need for responsive, adaptable systems that don’t force people to reapply repeatedly for the same support or face ‘cliff-edge’ funding losses during transitions (e.g. from child to adult services).
- Relating to Outcome 3 ‘a rights-centred and person-centred care policy’, lacks a target for social care. The outcome only commits to this work within Health Boards and Welsh NHS Bodies but with the overall outcome of ‘promoting the rights of disabled people in health, social care, and independent living’.
- Acknowledge the urgent need to address workforce recruitment and retention, especially in rural and Welsh-speaking communities.
- For people with dementia, well-trained social care staff means improvements in their day-to-day quality of life, and in many cases a reduction in the use of antipsychotic medication and physical restraints, with staff instead being able to provider healthier and more ethical means of supporting agitation.
- For people with dementia, receiving an early diagnosis is crucial.
- Commit to improve emergency planning and crisis response arrangements for disabled people, including those with conditions such as epilepsy, in community settings, leisure venues, and public services.
Housing and accommodation
- Increase availability of supported living spaces for people who have a learning disability, including people who have Down’s syndrome.
- Respond to those inappropriately accommodated in hospital settings with appropriate community-based supported living arrangements.
- Need appropriate community-based services, decrease reliance on institutional detention.
- Continued provision of safe spaces and support opportunities for young people with additional needs and disabilities, including after the age of twenty-five.
- Need access to suitable housing remains a major barrier for autistic people.
- Direct Payments are important but need a lot of work to be done to ensure they do what they are designed to do.
- Act to review and improve accessible housing provision, including adapted properties and supported living options would fill a current gap in this theme.
Communication and inclusion
- The equal communication outcome doesn’t mention other forms of communication than Welsh or BSL.
- Digital inclusion is fundamental to modern independent living.
- Increased awareness and promotion of available opportunities and activities for disabled and additional needs young people.
- Learning braille should be promoted, and it should be provided as a form of communication.
- Improve communication from Health and utility companies for example for people with sight loss.
- Not enough people to give advice and support for individuals; technology a challenge to use and learn; and not enough support or training for people with sight loss.
- Hospital letters needed in large print.
- Inclusive of Digital and Online Services for Cultural and Social Participation.
- Reference the need for services to meet accessibility standards and to support participation by disabled people in online spaces.
- In outcome 3 we would urge a clearer commitment to co-production as an already widely used concept in parts of the public sector to add greater definition to this outcome.
- Outcome 5 would be strengthened with a clear reference to the concept and behaviours of co-production.
- Establishing an external advisory board offers an important mechanism for maintaining oversight, accountability, and lived experience leadership in the delivery of the wider plan.
Staff training and skills
- Provide training for domiciliary care providers and social care workers.
- Need concerted advocacy and systemic change to address the avoidable suffering and discrimination faced by autistic people.
- Improve access to training and support for independent living skills, such as using technology and ensuring personal safety at home.
- Expand education and courses on financial management and budgeting for young people, especially for those transitioning to living independently.
- [Need] greater awareness and training of staff to advise and assess people with sight loss is essential.
- Need to progress in the pay and progression framework. Continued efforts to promote the social care sector as an attractive career path here in Wales.
Funding and resources
- Financial support for national parks to adapt to being accessible by all. Access outdoor spaces are not reliant on groups and carers.
- None of the outcomes will be deliverable unless there is a sustainable, fairly paid, and well-trained social care workforce.
- Guarantee a right to independent living, backed by adequate funding for social care.
- A Welsh minimum income for independent living would help tackle socio-economic inequality, which is particularly stark between disabled and able-bodied groups.
- Recognise that independent living also depends on affordable, accessible transport and housing options, especially in rural areas.
- Embedding the Social Model of Disability in grant and project evaluation processes is an important way of ensuring that funded initiatives actively address social and environmental barriers, rather than focusing solely on individuals' impairments.
- Prioritise the transformation of stroke services in the next Programme for Government, with dedicated funding, updated service standards, and cross-sector support for life after stroke.
- Fund specialist mental health support tailored to stroke survivors and their families, reflecting the distinct psychological impact of stroke.
Leisure, sport, and culture
- Work with cultural, heritage, sport and leisure organisations to improve physical access and inclusive programming for disabled people engage in community and cultural life.
- Part of independent living is having access to arts and culture (a human right). This should be included.
- Promotion of hidden disabilities awareness in leisure and cultural settings.
- Incorporate awareness-raising initiatives for leisure, sport, and cultural providers on hidden disabilities including conditions like epilepsy, sensory sensitivities, and neurodivergence would support more inclusive, person-centred services.
Summary
Respondents emphasised that independent living for disabled people requires more than just access to health and social care services. They highlighted the critical importance of affordable, accessible transport and housing, especially in rural areas, pointing out that without the right social care support disabled people cannot participate in community life. The lack of supported living spaces, particularly for people with learning disabilities and those transitioning to adulthood, was identified as a significant barrier, with many people experiencing long waits or inappropriate hospital placements.
Additionally, respondents called for greater recognition and training for social care providers, noting their crucial role in supporting disabled people across Wales. They emphasised the need for a sustainable, well-trained, and fairly paid social care workforce, with particular attention to recruitment and retention challenges in rural and Welsh-speaking communities. They also advocated for the inclusion of a commitment to a Welsh minimum income for independent living, seeing this as essential for tackling socio-economic inequalities faced by disabled people.
There was a strong call for responsive and adaptable support systems that recognise fluctuating health conditions, so that disabled people do not face repeated reassessments or sudden funding losses during transitions. Respondents urged that care policy outcomes must include clear targets for social care and stronger links to workforce development and career progression, ensuring the rights and dignity of disabled people remain central.
Respondents noted that these areas are central to wellbeing, identity, and community life for disabled people. Accessible communication was another central theme, with calls for mandatory accessible formats for promotional materials, booking systems, and public information. Respondents emphasised that effective communication using British Sign Language, communication methods like Easy Read, and digital accessibility is needed but not as an ‘add on’.
Intersectional commissioning and a broader understanding of accessibility emerged as priorities, with many stressing that accessibility should account for dical eneurodivergence and invisible differences or impairments. There were calls for commissioners to include those with lived experience in decision-making, and to address the specific risks faced by vulnerable adults, such as exploitation and insecure housing.
Question 8: justice and supporting environments
Justice and supporting environments are made up of the following themes: access to justice and accessible and supporting environments.
We asked
Will the proposed outcomes set out in ‘Justice and Supporting Environments’ help reduce the problems and barriers that disabled people face? What, if anything, should be added or removed from these outcomes? Please give reasons for your answer if possible.
You told us
“TUC Cymru supports the inclusion of justice and supporting environments… Participants in our discussion raised serious concerns about the lack of accountability and enforcement mechanisms across all sectors. Without these, rights exist only in theory not in practice.”
TUC Cymru.
Accountability and enforcement
- Delivery must be led by Disabled People’s Organisations to ensure lived experience is central.
- Outcomes in the plan are aspirational but lack enforceability. Without clear duties and consequences, change will not happen.
- Access to legal aid is inadequate. Court closures and the need for long-distance travel create significant barriers to justice.
- Strengthen the role of the Equality and Human Rights Commission (EHRC) in Wales. Introduce transparent reporting systems, inspections, and redress mechanisms for public bodies and service providers.
Advocacy
- Advocacy is essential to ensuring disabled people can meaningfully access justice. It must be seen as a right rather than an optional service.
- There must be accessible, well-resourced advocacy across employment disputes, housing, social care appeals, and legal procedures.
- Without advocacy, disabled people and their families are left to “fight a system which isn’t designed to support them.”
- Communication and advocacy support must be guaranteed to ensure disabled people can access legal procedures meaningfully.
Data, measurement and evaluation
- Current data is fragmented, inconsistent, or missing altogether, particularly on disabled people’s experiences in prisons and across the justice system.
- A justice data dashboard is needed, with disaggregated data on court outcomes, hate crime prosecutions, and prison populations, broken down by disability type and other characteristics.
- There were also calls for better use of the Welsh Government’s Equality, Race, and Disability Evidence Units.
Safeguarding
- Safeguarding within the outcomes is underdeveloped and must be made more visible and explicit.
- Disabled people are often unable to access safeguarding processes, either because systems are not publicised, not accessible, or not trusted.
- There must be accessible, well-publicised safeguarding processes that disabled people can rely on.
- Safeguarding should also expand in scope to cover areas such as cuckooing, modern slavery, and domestic abuse.
Systemic and structural barriers
- Entrenched discrimination and systemic barriers remain a major problem, with many feeling that the system is built to exclude rather than support them.
- Outcomes are seen as too limited and rights existing “in theory, not in practice.”
- There is a lack of trust in justice processes, with delays in decisions, inaccessible complaints systems and dismissive responses to serious crimes.
- More ambitious reform is needed to tackle institutions and culture, not just individual services.
- Low public awareness of systemic abuse of disabled people, emphasising the need for more education to help people recognise and challenge it.
Intersectionality
- Services must actively account for intersectional experiences.
- This plan must align with other Welsh Government plans such as Anti-Racist Wales, LGBTQ+ and HIV Action Plans.
- Disabled people who are LGBTQ+, from ethnic minority backgrounds, or living in poverty face multiple barriers that must be recognised and addressed.
Summary
Respondents broadly welcomed the inclusion of justice and supporting environments within the draft plan, recognising its potential to address some of the most pressing barriers faced by disabled people. However, they stressed the need for stronger accountability to ensure systems deliver in practice. Recommendations included clear performance measures, transparent reporting, robust enforcement mechanisms, and enhanced leadership roles such as a Disability Commissioner. Regular publication of disaggregated justice data was also called for to inform policy and track progress, with some suggesting better use of Welsh Government’s specialist evidence units to generate high-quality, Wales-specific data.
There was consistent support for the expansion and protection of advocacy services, with calls for ring-fenced funding for independent legal advocacy and peer-led organisations. Respondents noted the significant impact of the loss of local and informal advocacy networks and stressed the importance of embedding advocacy provision into all stages of justice processes.
Co-production, particularly with individuals who have lived experience of disability and the justice system, was identified as a critical element in the design, delivery, and evaluation of effective policy interventions. Respondents noted that disabled people should be involved not only as consultees but as decision-makers and partners, ensuring their perspectives shape the systems intended to serve them.
Responses highlighted the intersectional and systemic nature of barriers, calling for stronger cross-sector and cross-government collaboration, alignment with wider equality strategies and human rights obligations, and the creation of inclusive, rights-based services that meet the diverse needs of disabled people in Wales.
Question 9: United Nations Convention on the Rights of Disabled People
We asked you
We have outlined in the Disabled People’s Rights Plan how the actions and outcomes support the principles set out in the UNCRDP. Do you think that the plan promotes the main principles of access to rights and inclusion within the UNCRDP? Please give reasons for your answer if possible.
You told us
“Yes, the Disabled People’s Rights Plan makes a sincere attempt to align with the core principles of the UN Convention on the Rights of Persons with Disabilities (UNCRDP) particularly around inclusion, equality, and the right to live independently. However, in our opinion, the plan still falls short of fully embedding the UNCRDP principles into practical, enforceable action, especially when it comes to accessible transport, which is a foundational enabler of many rights under the Convention.”
Dolen Teifi Community Transport.
“Overall, the plan is a strong step toward realising the rights enshrined in the UNCRDP. It reflects the values of inclusion, autonomy, and equality, and it has the potential to transform the lives of disabled people in Wales. To fully meet the Convention’s standards, the plan must now be matched by bold implementation, robust accountability, and inclusive leadership with disabled people at the centre of every decision.”
Focus group commissioned by Welsh Government.
Legal commitments and incorporation
- Include a clear commitment to incorporation of the UNCRDP into Welsh law.
- Ensure that the rights of disabled people are respected, protected and fulfilled in Wales, there must be a clear and specific action within the plan to fully incorporate the UNCRPD into Welsh law.
- The Draft Plan makes no reference to the Welsh Government’s own commitment to incorporate the UNCRDP into Welsh domestic legislation.
- The Convention requires state parties to take active steps and report on progress. The plan currently lacks clear monitoring and enforcement mechanisms. Rights cannot depend on good intentions, they require accountability and recourse when they are not met.
- Address exploitation of disabled people.
Health care and support
- Respond to delays in mental health service provision and the lack of autism-trained professionals. These barriers breach Article 25 of the UNCRPD, which establishes the right to the highest attainable standard of health without discrimination.
- Stronger commitments needed around: Access to healthcare (Article 25), Employment and workplace protections (Article 27), and social protection and welfare support (Article 28).
- Ensure the social model of disability is applied consistently, particularly in healthcare and service design, moving away from medicalised assumptions.
- Since a DNACPR (Do Not Attempt Cardiopulmonary Resuscitation) is not an order that must be followed in all circumstances, it may be helpful to provide this as a significant training example.
- Include ‘psychosocial’ disability as per the WHO and UN joint Mental Health legislative and practice guidance.
- Greater emphasis to the rights and needs of people with hidden, fluctuating, and less visible disabilities such as epilepsy, autism, or mental health conditions, ensuring their experiences are equally embedded in all actions.
- [The Plan] needs to be strengthened with regard to protecting the rights of those with communication disability.
- Invest in independent advocacy, peer support and representation, especially in relation to education, employment, social care, and justice.
Transport and mobility
- Treat accessible transport as a human rights issue, essential to the exercise of all other rights
- The current plan refers to travel in isolation, but the UNCRDP makes clear in Article 9 (Accessibility) and Article 20 (Personal mobility) that transport is central to exercising virtually all other rights, whether that’s accessing education, work, justice, healthcare, or political participation.
Participation, co-production, and inclusive governance
- Lack of access to professional BSL interpreters is denying human rights.
- The plan mentions engagement, but to meet the standard set by the UNCRDP, there must be a commitment to co-production and shared decision-making with disabled people at every level from national policy to local delivery.
- Ensure rights are delivered equitably across all areas, including rural communities.
- Start by educating our future generation of decision makers now, this will need a workforce which completely understands it also.
- Disabled women are only mentioned once in the short-term actions, and the draft plan itself makes little mention of disabled women.
- Stronger integration of disabled people’s organisations, trade unions, and community groups in delivery and governance, in line with the principle of nothing about us without us.
- Disabled people, particularly individuals with learning disabilities, may not be aware of the UNCRDP which may affect understanding of how this plan could impact on them and their rights.
- Article 28 (Adequate standard of living and social protection): This right is being undermined by the financial costs and distinct challenges facing Children and young people with cancer and their families.
- Under Article 21, the UNCRDP states that parties should accept and facilitate the use of sign languages and recognise and promote the use of sign language, but this article is not directly considered.
Employment, workplace and social protection
- Address the disability pay gap and the disproportionate levels of in-work poverty faced by disabled individuals.
- Promote inclusive workplace cultures that value disabled employees as equal contributors.
- Support internships should be seen as integral parts of a sustainable strategy to secure paid employment for young disabled people.
Summary
Respondents emphasised that the United Nations Convention on the Rights of Disabled People (UNCRDP) should be incorporated into law in Wales to ensure genuine protection of disabled people’s rights. Some respondents felt that current policy efforts fail to reflect the integrated nature of these rights, such as access to arts and culture, and argued that such areas cannot be addressed in isolation from broader plans. The exploitation of disabled people was identified as a central concern under the Convention, and that current government plans do not adequately address this issue.
Changes in language and terminology related to disability were also debated, with some respondents feeling these shifts lacked authentic engagement and failed to communicate true respect for disabled people’s rights. There was widespread doubt about the Welsh Government’s intentions to improve outcomes, particularly relating to the provision and retention of benefits. Many perceived a mismatch between policy statements and tangible support or action, leading to a broader mistrust of official commitments. Some felt that, despite assurances of support, authorities are “trying to take away all our benefits,” reflecting fears that changes to welfare or support systems could undermine rights in practice even though no specific welfare reforms were named.
Some respondents expressed frustration over the absence of measurable and enforceable government actions. Concerns over the issuing of DNACPR (Do Not Attempt Cardiopulmonary Resuscitation) recommendations further highlighted anxieties around the right to life and the adequacy of decision-making systems. Respondents called for these recommendations to be used in training, emphasising the need for compassionate, transparent, and accessible processes.
To uphold UNCRDP principles, respondents said the Welsh Government must implement clearer monitoring, accountability, and evaluation mechanisms. Disparities in access, often determined by geography, remained a major issue, with calls to ensure and monitor equal access to services, transport, housing, and justice for all communities, not just those better resourced. Finally, respondents urged the plan to recognise and address barriers related to poverty, rurality, language, ethnicity, and gender, and to design actions that thoughtfully consider these intersecting factors.
Question 10: governance, monitoring, and evaluation
The final section of the Disabled People’s Rights Plan sets out the arrangements for the governance, monitoring, and evaluation of the plan. This means checking how the plan is working, making sure it is going well, and measuring how well the plan is improving the lives of disabled people.
We asked you
Do you think any other governance, monitoring or evaluation mechanisms should be considered?
You told us
“More information is also needed as to how disabled children and young people will be included in evaluation processes and impact measurements.”
WhizzKidz.
“We would encourage the Welsh Government to set short-term and longer-term measurable milestones and outcomes to evidence the Plan’s ambition, progress and success. We recognise that changing cultures and reducing barriers is a long-term agenda and we welcome the Welsh Government’s commitment to doing this. Measurable outcomes will be key to reporting and celebrating progress.”
Medr.
Co-production and meaningful engagement
- Co-produced evaluation mechanisms are needed, using accessible formats and providing resources for participation (e.g. payments for lived experience expertise, accessible venues, digital tools).
- Further the VAWDASV-specific aspirations of the plan.
- Mandatory engagement with trade unions, especially for employment and services.
- Annual public progress reports, publish clear, accessible reports with achievements, areas for improvement, feedback, and case studies.
- Feedback loops must allow disabled people to comment on implementation, ensuring less-heard voices and those with complex needs are included.
- Include longitudinal evaluations, co-designed with disabled people, to measure quality of life and inclusion.
- Track lived experience through a panel or a national survey like the National Survey for Wales.
- Engage with disabled families from ethnic minority backgrounds; more work is needed for communities where English isn’t the first language.
- Ongoing feedback from disabled people through accessible surveys, forums, and focus groups.
- More consideration on how to inform and support all DPOs in Wales to engage in decision-making and evaluation.
- Engage with people who have severe, profound, or multiple learning disabilities and complex communication needs.
- Clarify how the plan relates to existing strategies (e.g., Autism strategy, Learning Disability programme).
- Set up an evaluation taskforce with stakeholders, including disabled people, DPOs, and prisoners’ advocacy orgs.
- Nursing leaders (Chief Nursing Officers, Consultant Nurses, Advanced Nurse Practitioners) must have a central role, working closely with disabled nurses and those in disability services.
- Governance structures should include condition-specific third sector organisations/charities.
- Ensure External Advisory Board representation from healthcare, psychosocial care, and welfare rights sectors.
- Strategies that would include seeking views from disabled people who have profound and multiple disabilities or are non-verbal would be welcome as these individual’s perspectives are often underrepresented compared to more able or verbal individuals.
Children, young people
- Steering groups and coproduction include disabled people and also young people, children and/or representatives for them such as parents from the beginning.
- How would children be included in a steering group like the one that helped form this plan? Use special needs school councils to do this and to share some excellent practice in this area.
- Involve organisations with expertise in disabled children and young people: The External Advisory Board should require for a minimum level of representation from third-sector organisations focused on disabled children and young people.
- Improve data collection for younger people: There is a significant data gap regarding the data that is available on disabled CYP in Wales.
Data, measurement and performance indicators
- Collect and disaggregate data (by impairment, age, gender, ethnicity, geography, socio-economic status) and act when delivery falls short.
- Independent, with lived experience at the centre; Co-produced, not top-down; Data-informed, with a focus on equity across all communities.
- Include measurements e.g., schools moving from red or amber on accessibility towards green; numbers of stations with accessible platforms; numbers of people logging complaints about inaccessible streets, shops, or pubs.
- Define Key Performance Indicators linked to each outcome, with regular public reporting on progress.
- Need a mechanism for tracking how local authorities, health boards, and transport providers are implementing the plan and consequences if they do not.
- Require bodies included to produce a plan with specific targets and timescales, and an inspection regime which can review actions and require changes.
- Need SMART goals, plan and actions lack clear timelines, accountability, enforceability, and legal weight (it doesn't seem it will lead to legislative change).
- Strengthen data collection and monitoring by ensuring disaggregated data is gathered and analysed across characteristics, including impairment type, age, gender, ethnicity, sexuality, and socio-economic status.
- Data gathering and reporting must include Deaf BSL signers by ensuring they can provide feedback and information.
- Publish a data dashboard that tracks headline indicators and publish current baseline statistics, and annual updates to show improvements.
Governance, oversight and accountability
- Evaluation and governance must be fully and properly resourced to ensure the impact of proposals can be effectively judged and assessed.
- Establish ongoing, structured involvement of disabled people and Disabled People’s Organisations (DPOs) in governance, through advisory groups or forums that regularly review progress, raise concerns, and suggest improvements.
- Governance should clearly name an individual job/position/role responsible for delivery and outcomes.
- Governance, monitoring, and evaluation should be provided by disabled people or disability-led organisations.
- Welcome the plan to establish an External Advisory Board to monitor and hold policy makers to account for delivery of the plan.
- Digital inclusion must be embedded into governance and monitoring, with mechanisms involving disabled people with lived experience of digital exclusion and co-designed with relevant organisations.
- Consistent, cross-government commitment is required, with clear accountability for co-production and how it is handled, monitored, and resourced.
- Establish a Disabled People’s Rights Commission or independent advisory board, primarily composed of disabled people and DPOs, to oversee and scrutinise progress, publish findings, and advise Ministers.
- An independent Disability Commissioner for Wales is needed to provide oversight and scrutiny.
- Audits of public bodies should be conducted and a data dashboard tracking headline indicators published regularly to ensure transparency and accountability.
- Clarity is needed about who will be on the External Advisory Board, its representation, and independence.
- There must be a clear process and place for disabled people to log their day-to-day barriers in their communities.
Summary
Respondents empathised that meaningful involvement of disabled people, particularly those with learning disabilities, disabled children, and young people, must be at the heart of governance and monitoring. They stressed the need for accessible formats, co-produced evaluation, and direct participation, cautioning against tokenistic consultation. Genuine influence, not just presence, is required for the plan’s success.
Respondents said coproduction must be embedded throughout design, delivery, and assessment. Respondents generally agreed with the establishment of an advisory boards although some called for a commission led by disabled people and organisations, alongside ongoing feedback mechanisms, to ensure lived experience is central.
Respondents said data collection and performance tracking are crucial. They recommended regular audits, the publication of baseline statistics, and a data dashboard to monitor headline indicators. Importantly, data should be disaggregated across impairment, geography, ethnicity, age, and gender. Gaps, especially regarding young disabled people, must be addressed to properly measure impact and success.
Respondents underlined the importance of consistent, cross-government commitment is essential. They highlighted the importance of clear lines of accountability and roles, funding that earmarks resources for disability and additional learning needs and avoiding administrative overload. Too many committees and unclear responsibilities can create confusion and dilute impact; consolidation is needed.
Main risks highlighted included superficial accountability and box-ticking if governance and monitoring are not fully resourced and independent. Respondents warned that without continuous feedback, meaningful engagement, and transparency, the plan could fail to deliver genuine improvements for disabled people in Wales. Clear processes for reporting barriers and regular, accessible communications are vital to maintain trust and momentum.
Question 11: British Sign Language
We asked you
What do you think the likely effects of the Disabled People’s Rights Plan will be on deaf British Sign Language (BSL) signers? We are particularly interested in its potential impact on opportunities to use BSL in Wales.
- How will the plan help to promote and strengthen the use of BSL in Wales?
- How will the Plan help to break down barriers for BSL signers in accessing information and services?
You told us
“Embedding BSL benefits everyone by promoting inclusion, understanding, and communication for all. It should be a core part of an education system that values every child’s right to be heard and included.”
Individual response.
“Once the British Sign Language Bill is implemented, this will have an impact on LA’s to ensure that this is incorporated into our practices. There will be cost implications alongside this. I think the plan could be reviewed following enactment to ensure it covers what is required.”
Merthyr Tydfil CBC.
- The Plan needs to go further if it is to truly promote and strengthen the use of BSL across Wales and break down the persistent barriers that Deaf BSL users face in accessing information, services, and equal participation.
- Some BSL users do not consider themselves disabled so including them in this plan may be alienating for some in the community.
- increase the capacity of BSL teaching resources urgently and to increase BSL Interpreter capacity.
- Aim to fund new interpretation or translation services with KPIs to measure success.
- Require that key public information be routinely made available in BSL, including emergency updates, government communications, and online portals.
- Make stronger commitments to legal recognition of BSL in Wales, in line with other UK nations.
- Implementation of the BSL (Wales) Bill should be added to the action plan.
- Encourage collaboration with deaf led organisations to co-design accessible resources that reflect the needs of the BSL community.
- Public sector bodies need clear guidance and resources to understand and meet the needs of BSL users effectively.
- Strengthen the Plan’s impact on BSL users, by the inclusion of the following outcomes:
- BSL-accessible content across all public service websites and digital platforms, including health, care, education, and justice
- Expansion of video relay services to support BSL users in accessing appointments, advice, and support services
- Funding for BSL content creators and interpreters, particularly within digital inclusion hubs and online learning platforms
- More opportunities are needed for deaf and hearing people to learn BSL
Summary
Those that agreed that there would be positive impact on opportunities to use BSL in Wales cited positive factors within the plan, such as increased visibility and access, better service experience and inclusive participation.
Where respondents felt the plan could be strengthened to maximise impact, these respondents called for BSL to be normalised into the design of service delivery and recognising BSL as a language with equal status. This included ensuring public information is made routinely made available in BSL, including emergency updates and government communications. The importance of different forms of communication was referenced, including Makaton, Picture Exchange Communication System (PECS) and communication boards. One response included the definition of “communication]” and “language” from the UN Convention and recommends these are included in the plan.
Education was a key theme through responses, with responses calling for BSL to be taught widely across schools, as part of the curriculum, alongside learning about deaf culture, to encourage fluency and inclusion. A commissioned response from a series of creative workshops and discussions held with Deaf, disabled and neurodivergent people across Wales noted, the only way to create genuine inclusion for deaf BSL users is to increase the number of people who can use BSL throughout Wales, including making learning BSL accessible for deaf and hard of hearing people. Another commissioned response from 2 workshops with people with hearing loss and deaf BSL users raised concerns about the lack of teachers of the Deaf and communication support workers with the right level of qualifications to support deaf children. Several responded said there is limited availability of family BSL classes across Wales for families of deaf children, particularly beyond level 1, meaning that achieving better proficiency of the language becomes a costly and often unaffordable choice.
The availability and accuracy of interpretation services across Wales was highlighted a significant challenge and as vital to ensure deaf people can participate fully in Welsh life. Many responses commented on BSL accessibility and were clear there needs to be an increase, through recruitment and training, in the routine availability of qualified BSL interpreters across all public services, events, and consultations. Respondents noted the limited provision available in healthcare settings and in rural and Welsh-speaking areas. Commissioned responses from workshops with deaf BSL users called for a BSL interpreter workforce plan and highlighted examples of needing to depend on family members to translate for them in healthcare settings. The commissioned responses highlighted that deaf people miss out on privacy when they must rely on family members or interpreters when they need to access services or information.
Some suggested a need for BSL and deaf awareness training for frontline staff in public services to ensure BSL users can access services in their preferred language without delay or compromise and to promote cultural understanding and reduce stigma. This was recommended particularly for healthcare and local authority staff, to ensure they are familiar with and able to book communication support and BSL interpreters whenever needed, including in emergency situations.
Digital inclusion was highlighted across responses. For BSL users, it was noted that the availability of accessible digital content is essential to exercising rights and participating fully in society. One respondent felt there may be some scope for AI innovations to help with simple messaging in BSL. Another recognised digital platform is a primary means of accessing public services, health information, education, and civic participation. Commissioned responses from a series of workshops and discussions held with Deaf, heard of hearing, disabled and neurodivergent people across Wales, noted that the use of assistive tech or remote support for BSL users cannot replace the need to communicate face to face directly through their language of choice, without the need for an interpreter. They also noted the importance of ensuring that public services and places are equipped with the right tech, and the right knowledge of how it works, to support deaf people and people with hearing loss.
Several responses highlighted the BSL (Wales) Bill and the need to review the actions contained within the Plan, following the outcome of the passage of the Bill through the Senedd’s scrutiny process. It was recommended that the Welsh Government’s BSL Stakeholder Task and Finish Group recommendations should inform the Plan and there needs to be greater alignment with the priority actions in the Welsh Government’s forthcoming BSL Route Map.
"Communication" includes languages, display of text, Braille, tactile communication, large print, accessible multimedia as well as written, audio, plain-language, human-reader and augmentative and alternative modes, means and formats of communication, including accessible information and communication technology.
"Language" includes spoken and signed languages and other forms of non-spoken languages.
Question 12: Welsh language
We asked you
What, in your view, would be the likely effects of the Disabled People’s Rights Plan on the Welsh language? We are particularly interested in likely effects on opportunities to use the Welsh language and on not treating the Welsh language less favourably than English.
Do you think there are opportunities to reduce unhelpful effects on the Welsh language in the plan?
You told us
“Welsh language has been stolen from disabled people. We’ve not been taught it. We need ways of learning Welsh too”
Focus group commissioned by Welsh Government.
“In areas like west Wales, where many disabled people are Welsh first-language speakers, it’s not just about preference, it’s about dignity and comfort. If someone’s support worker, advocate, or transport provider can’t speak Welsh, it can make people feel like outsiders in their own communities.”
Dolen Teifi Community Transport.
Promoting Welsh language use and avoiding linguistic marginalisation
- The use of Braille, Easy Read and BSL (a recognised language with Welsh accents, variants) is just as important as the need for Welsh. Without being able to access the right language and communication tools, communication becomes a breakdown and risk factor.
- Recognise the intersectionality of language and disability e.g. ensuring that Welsh-speaking D/deaf and hard of hearing individuals have access to Welsh BSL interpreters and captioning.
- Favouring Welsh and prioritising Welsh speakers for posts and roles can act as a barrier to equality with additional language needs or disabilities, such as dyslexia and neurodivergent people, being negatively impacted.
- Employ Welsh speaking staff to reduce negative impacts on the Welsh language.
- Ensure that specialist or disability-focused services do not default to English-only provision, and that services designed to improve accessibility are equally available in Welsh.
- Promote Welsh-Medium provision for disabled learners and service users to avoid any perception that accessibility comes at the expense of Welsh language rights.
Equal access and language rights
- Welsh Government should work closely with both the Welsh Language Commissioner and disabled people’s organisations to monitor delivery and prevent a two-tier system of rights and access.
- Establish a clear commitment to making sure accessibility doesn’t come at the expense of Welsh language rights or vice versa. If something is being published in BSL or Easy Read, it should also be in Welsh.
- Ensure that Welsh-medium schools and colleges are accessible for disabled learners and that disabled Welsh speakers can access advocacy and support in their language of choice.
We asked you
Do you think that there are opportunities to promote positive effects in regard to Welsh language in the Plan?
You told us
Welsh language and British Sign Language
- Explore and support the use of Welsh-language BSL interpretation, where appropriate, to reflect the bilingual nature of Wales and support deaf Welsh speakers.
- Ensure that all public services, health, social care, and justice provisions addressed by the plan are available in both Welsh and English, including BSL, Easy Read Welsh, and Welsh-language interpretation.
Culture
- Embed inclusive Welsh-language access into public spaces, services, and cultural life, for example, by ensuring that Eisteddfodau, schools, and community events are fully accessible to disabled people.
- Ensure the plan aligns with the Cymraeg 2050 strategy and reinforces the Active Offer to ensure Welsh is treated no less favourably than English.
- Arts and culture are excellent opportunities to promote positive effects in regard to Welsh language.
Disabled people’s organisations
- Welsh-language operating Disabled People’s Organisations should be central to co-production, governance, and evaluation of the plan.
- Ensure the intersection between disability and Welsh language identity is fully recognised to promote equality, inclusion, and cultural respect.
- Support Welsh-speaking DPOs and community groups to shape delivery.
- Embed “More than Just Words” into the plan’s independent living commitments.
Rights and language
- Promote bilingualism as a right and ensure that both languages are treated with parity. Insufficient planning may disadvantage disabled Welsh speakers, this must be actively mitigated.
- Actively involve Welsh-speaking disabled people in the development and monitoring of the plan.
- Co-produce materials with disabled Welsh speakers to actively promote the use of Welsh language in support services and networks.
Additional comments
- People with learning disabilities are still being discouraged from pursuing the Welsh Language in education as it is seen as ‘complicating’ for their education, rather than putting into place reasonable adjustments.
- Lack of suitable Welsh language courses for Deaf / Deafblind people.
- Welcome consideration of people who have additional communication needs who are first-language Welsh speakers and encourage government to consult with those who have direct lived experience.
- Interpreters are an integral part of the BSL community. We would welcome similar approaches to those outlined in Cymraeg 2050.
- Early intervention is key to supporting individual needs at a young age; welcome early assessment and support for deaf babies and children to ensure their cognitive and linguistic development.
Summary
Respondents highlighted that accessible formats such as Easy Read and audio are often produced only in English, excluding disabled Welsh speakers from full participation. Services for disabled people frequently default to English-only provision and digital-only services which can inadvertently disadvantage some Welsh speakers. Respondents stressed that Welsh language rights and accessibility must be integrated into all services, not treated as competing priorities.
It was recommended that all accessible formats, including Easy Read, be made available in both Welsh and English. Respondents emphasised expanding Welsh-medium provision for disabled learners and service users and strongly called for recruiting and training Welsh-speaking staff in healthcare, education, and social care, with a focus on disability awareness. There were suggestions to include Welsh language use in training and respondents supported efforts to enable frontline staff to deliver the Active Offer of Welsh.
Involving Welsh-speaking disabled people in consultations, co-production, governance, and monitoring was seen as essential to ensuring services reflect their needs. Respondents recommended developing Welsh-language digital platforms and content to align with the Digital Strategy for Wales, alongside ongoing monitoring of the plan’s impact on linguistic equality and accessibility.
Embedding inclusive Welsh-language access into public spaces, cultural events, and community life was also encouraged, as well as increased support for Welsh-speaking Disabled People’s Organisations and community groups.
Respondents highlighted that attitudes towards people with learning disabilities can pose barriers to Welsh language education and employment, often due to perceived complexity or language requirements. Advocates called for BSL to be recognised as a third national language in Wales, with plans for accessible Welsh language BSL interpretation and training. Deaf and deafblind people face particular challenges in accessing Welsh courses and services, while those with non-visible differences require inclusive government support and involvement.
Feedback supports alignment with Welsh Language Standards and suggests the plan should reinforce the Active Offer and Cymraeg 2050 strategy to widen opportunities for disabled people who choose Welsh first. Respondents noted that Welsh language actions in the plan are currently limited and must be strengthened.
Question 13: Anything else about the Plan
We asked you
We have asked you specific questions about the Disabled People’s Rights Plan. If you have anything else about any part of the plan you would like to tell us, please use this space to let us know.
You told us
“…there is limited intersectional analysis in the plan, i.e. specifically addressing the needs of disabled women, disabled LGBTQ+ people and global majority disabled people.”
Royal College of Nursing Wales.
Intersectionality, invisible differences or impairments, and communication equity
- The Plan does not reflect intersectional experiences. Barriers faced by disabled women, LGBTQ+ disabled people, and disabled people from Black and minoritised communities \are not addressed in detail.
- Invisible disabilities, fluctuating conditions, and neurodivergence (such as autism, ADHD, and mental health conditions) are being overlooked. These groups face distinct barriers that must be recognised.
- Access needs are often interwoven. Services must be designed to support people with multiple, intersecting needs, for example, a deaf person who is also autistic.
- Public services and professionals lack the knowledge or training to recognise and support hidden disabilities, leading to exclusion and delays in diagnosis. Better cross-professional communication is needed to close the gaps and deliver joined-up care.
- The Plan must link with other Welsh Government strategies (e.g., anti-racist action plan, LGBTQ+ action plan) to create a more joined-up approach that reflects the multiple identities many disabled people hold.
- The Mental Capacity Act is missing from the plan. Its absence is a missed opportunity to strengthen protections.
- Language and communication equity should be prioritised. Welsh speakers and BSL users are underrepresented in the Plan. Standardised Welsh-language disability terminology is needed, alongside embedding Welsh and BSL across all actions, and ensuring BSL-accessible consultation events.
- The Children and Young People’s version of the plan is overwhelming. It needs to be simplified, with clear timeline to show how changes will benefit them before adulthood. Disabled people should not just be consulted, they should lead. They must be in decision-making roles, setting priorities and driving delivery.
Funding and resources
- Short-term actions are not fully funded and therefore risk failing before any long-term outcomes can be achieved.
- The scale of ambition in the Plan is not matched by the financial or staffing commitments needed to deliver it. Without extra investment, the Plan will remain aspirational rather than actionable.
- Clear delivery details are needed: dates, milestones, costings, and accountability structures to track progress across government departments.
Concerns with consultation process
- The consultation process was inaccessible and confusing, with documents spread across multiple files, a difficult website layout, and some groups (e.g., Easy Read respondents) were excluded from responding electronically.
- Communication and publicity were seen as weak. People said they often did not know the consultation was happening, and suggested using more everyday channels (e.g., school newsletters, community noticeboards, posters in public places, GP surgeries, and Welsh Government social media).
- Consultation must be more inclusive. Workshops, creative and informal sessions, accessible BSL-events, accessible apps, Welsh language access, and targeted information sessions are needed. Engagement should happen regularly and locally, not just at a national level.
- Consultation fatigue is an issue. Repetitive, tick-box surveys and overlapping consultations (particularly with UK Government processes) leave people exhausted and disengaged.
- Digital poverty is a barrier. Non-digital alternatives must be available to ensure everyone can participate.
- Clearer timelines, regular updates, and earlier notice of events are needed so people can plan and stay engaged.
Devolution and reserved matters
- UK Government welfare reforms (such as changes to PIP or Access to Work) are undermining progress in Wales. One respondent noted that trust is being eroded by UK-level welfare reforms and called for Welsh MPs to advocate more strongly in Parliament on behalf of disabled people in Wales.
- The Plan should meaningfully reference to the role of the benefits system and the ongoing impacts of UK Government welfare reform on disabled people’s financial security and well-being.
- Disability-related benefits and employment support should be devolved so that Welsh Government can ensure more equitable delivery.
- There is confusion about which responsibilities sit with Welsh Government, and which remain reserved to Westminster. This makes it hard to understand what the Plan can realistically achieve.
- Launching the Plan so close to the next Senedd election creates anxiety about political continuity. There is concern that priorities could shifter a new administration.
Building a future Wales for disabled people
- The Plan should consider future demographic shifts, including ageing populations, rising disability rates, and evolving care needs.
- Wales has a global role in advancing disability rights. The plan should align with international human rights frameworks.
Other comments
- Would like to see [the accessible employers] action broken down into different sectors devolved in Welsh Government.
- Participants urged policymakers to:
- Oppose fit note reforms that compromise medical autonomy.
- Map the intersectional impacts of UK policy on Welsh claimants.
- Ensure DPOs lead engagement with UK consultations.
- Expand inclusive, person-centred employability programmes.
- Publicly reaffirm and enforce CRPD Article 4.
- Urge the Welsh Government to include starting development of an Employer’s Disability Information Hub in its short-term action plan.
- We also feel that the focus on ‘leveraging the public purse to foster behaviours that support an inclusive workplace’ is not addressed in any of the short-term actions.
- Embed trade union recognition and collective bargaining rights in employment standards for disabled workers.
- Create spaces for employers, unions, and DPOs to collaborate fosters shared learning and accountability.
- Further clarity on how this accessible employment support will be provided. Will the approach be to train existing providers on accessibility, deaf and disability awareness? Or fund new employment support programmes targeted specifically at disabled people and perhaps delivered by DPOs? There is not an action in the short-term action plan that aligns with this objective.
- Commit to developing accessible, high quality, responsive and citizen-centred services which meet the needs of all deafblind people in Wales is welcomed…we have concerns as to how this will work operationally and whether this may become a postcode lottery depending on where individuals reside.
Summary
The responses to Question 13 of the consultation reflect a consistent call for the Disabled People’s Rights Plan to be backed by adequate resources, clear timelines, and robust accountability mechanisms. While many respondents welcomed the ambition of the Plan, they stressed that without defined costings, milestones, and delivery structures, the commitments risk remaining aspirational. Concerns were also raised about the short-term nature of the actions, and whether progress would survive future political changes, particularly in light of the planned UK welfare reforms that could undermine progress in Wales. Several respondents called for the devolution of disability-related benefits to give Welsh Government greater control.
A central theme was the need for authentic co-production. Respondents urged that disabled people should not only be consulted but also take leadership roles in shaping and delivering policy. Many felt current approaches remain tokenistic, with limited evidence that contributions from disabled people influence final decisions. This frustration was heightened by criticisms of the consultation process itself, which some participants found inaccessible, confusing, or poorly publicised. Respondents also called for more transparent communication, including regular progress updates and advance notice of engagement opportunities such as BSL-accessible events.
Intersectionality and the inclusion of invisible differences or impairments were identified as major gaps in the Plan. Respondents highlighted that disabled women, neurodivergent people, those with mental health conditions, and people from Black and minoritised backgrounds face distinct barriers that were not sufficiently addressed. Concerns were also raised about the lack of explicit reference to the Mental Capacity Act in Wales, and the underrepresentation of Welsh speakers and BSL users. Across all sectors, respondents emphasised that professionals often lack the training to support these groups effectively.
Accessibility was another recurring issue. Participants described barriers in the built environment, such as cluttered pavements, bins, and signage, alongside digital exclusion caused by inaccessible systems. Respondents called for digital inclusion to be embedded across all services, fair access to equipment and adaptations, and long-term planning for assistive technology.
Finally, participants emphasised the importance of accountability. They called for stronger monitoring and evaluation frameworks, with measurable targets, deliverable asks, and defined timescales. Proposals included mandating local authority membership of Disability Wales and creating reporting systems for discrimination and accessibility barriers. A live, regularly updated implementation plan was recommended to allow disabled people and the public to track delivery and hold governments to account. Without these measures, respondents feared the Plan could repeat past shortcomings and fail to deliver meaningful change.
Next steps
Following the evaluation of consultation responses, the draft Disabled People’s Rights Plan will be reviewed and updated.
In the interim, we will continue to progress the actions that are already underway, maintaining momentum on main priorities, such as working with a Task and Finish Group of stakeholders, advising on the establishment an External Advisory Board. We will also regularly assess whether further steps are necessary to strengthen our approach.
We will review the Integrated Impact Assessments in line with the changes made to the Disabled People’s Rights Plan.
Annex A: organisations
Aneurin Bevan University Health Board - Child and Family Psychology Dept
All Wales Forum of Parents and Carers of People with Learning Disabilities
All Wales People First
Alzheimer’s Society
Auditory Verbal UK
Betsi Cadwaladr University Health Board
Blaenau Gwent County Borough Council
Caerphilly County Borough Council
Careers Wales
Carers Wales
Cereba
Children in Wales
Children's Commissioner for Wales
Children's Legal Centre Wales
CIH Cymru
Citizens Advice Conwy-Gwynedd
Colegau Cymru
Community Housing Cymru
Conwy County Borough Council
Centre Of Sign
Crohn's and Colitis UK
Cwmpas
Cycling UK
Cyngor Sir CEREDIGION County Council
Digital Health and Care Wales
Disability Arts Cymru
Disability Wales
Dolen Teifi Community Transport
Down’s Syndrome Association
Epilepsy Action Cymru
Equality and Human Rights Commission
Fair Treatment for the Women in Wales
Family Fund
Guide Dogs
Learning Disability Wales
Merthyr Tydfil County Borough Council
Mirus Wales
Motor Neurone Disease Association
Mudiad Meithrin
National Advice Network
Newport City Council
Office of the Older Peoples Commissioner for Wales
Office of the Future Generations Commissioner for Wales
Parkinson’s UK Cymru
Powys Teaching Health Board
Public Health Wales NHS Trust
Royal National Institute for Blind People
Royal National Institute for Deaf People
Royal College of Nursing Wales
Wales Council for Deaf People
Social Care Wales
Tenovus Cancer Care
Tros Gynnal Plant (TGP Cymru)
The Thalidomide Trust
Unite The Union Cymru
Wales Vision Forum
Welsh Women's Aid
Whizz Kidz
