Recommendations of the Disability Rights Taskforce

The Disability Rights Taskforce, co-chaired by the Cabinet Secretary for Social Justice, Trefnydd and Chief Whip, Jane Hutt MS, and Professor Debbie Foster, Cardiff University, brought together people with lived experience, Welsh Government policy leads, and representative organisations to remove barriers and improve outcomes for disabled people in Wales.

The taskforce worked with more than 350 external stakeholders (listed in Annex A) to develop recommendations aimed at improving outcomes for disabled people. People with lived experience were active partners in the Taskforce’s process, sharing insights and lived experiences, which have shaped actions to tackle disabled people’s rights and remove existing hurdles.

Thematic working groups considered embedding and understanding of the social model of disability (across Wales), access to services (including communications and technology), independent living: social care, independent living: health, travel, employment and income, affordable and accessible housing, children and young people, access to justice, and wellbeing (as a workshop).

The Taskforce’s recommendations have been used to inform the actions and outcomes of the Disabled People’s Rights Plan, and these recommendations will continue to be an important resource that Welsh Government can return to in the future, to set out its medium to long-term requirements to deliver the ambition and outcomes for disabled people set out in the Disabled People’s Rights Plan.

The Terraforming Wales campaigns

• All campaigns should be co-produced and evaluated with disabled people.
• Informing and empowering disabled people campaign about our rights, building self-worth and self-advocacy skills and knowing where to go for information and to make a complaint.
• General public campaign to reframe disability, educate about ableism and the collective responsibility for inclusion.
• Public body campaign to focus on access as a right and embed the social model and coproduction into all activities, including disabled employees and people using services.
• Influencing political parties by educating about the social model, disabled people’s civil and human rights and encourage disabled candidates to run for the Senedd.
• Private and third sector campaign with disability inclusion resources about their equality duties and the value of having disabled employees as well as disabled customers.
• Media industry and legal profession campaign to educate about accessible content, the social model, disabled people’s civil and human rights and the influence of words and images.

Monitoring, enforcement and data collection

• Bodies such as the Wales Audit Office and EHRC to embed coproduction and the social model into their data collection, monitoring, scrutiny, and communications and share good practice.
• Build an understanding of the different types of knowledge and the value that lived experience brings to this.

Tasks for Welsh Government

• Produce guidance on communication, standardise complaint procedures, develop an accessible system for reporting complaints and monitor the outcomes.
• Educate Welsh Government press, legal, ministers and staff, so that they are competent in their understanding and implementation of the Social Model.
• Translate Welsh Government legislation, guidance, and codes of practice into disability rights/Social Model language.
• Support the funding of new and existing Disabled People’s Organisations across Wales.
• Highlight the importance of accessible volunteering opportunities and an understanding that not all disabled people can work.
• Develop a kitemark system, encourage organisations to appoint “champions” and identify and share good practice.

Access standards

• Develop a kitemark system, encourage organisations to appoint “champions” and identify and share good practice.

Welsh Government to:

• Renew commitment to the concept of Independent Living as defined in the Action on Disability Framework 2019 (subject to amendments) and actively promote it across policy areas and in delivery of relevant services, including in the training and education of the social care workforce.

What does Welsh Government mean by “Independent Living”? 

Original:

Independent living means all disabled people having the same freedom, dignity, choice, and control as other citizens at home, work, in education and in the community. It does not mean having to live by yourself or do everything for yourself. It means rights to practical assistance and support to participate fully in society on the same basis as others, as well as to voice and control over how this is provided. It is about ensuring people of all ages and from all communities are able to maintain independent living, enjoy well-being and access appropriate support when and how they need it.’ 

Framework for Action on Disability: the Right to Independent Living (2019)

With amendments proposed by the Working Group:

Independent living means all disabled people having the same freedom, dignity, choice, and control as other citizens whether in their home environment, at work, in education and in the community. It does not mean having to live by yourself or do everything for yourself. It means rights to practical assistance and support to participate fully in society on the same basis as others, as well as to voice, choice, and control over how this is provided. It is about ensuring people of all ages and from all communities can enjoy well-being and access appropriate support when and how they need it.’

• To develop and disseminate guidance, in coproduction with disabled people related to the requirement that those exercising functions under the Social Services and Wellbeing Wales Act pay due regard to the UNCRDP (United Nations Convention on the Rights of Disabled People) in carrying out these duties.
• To commission the development of a suite of resources and implement a programme for delivery of training and education to support the objective of embedding the Social Model of Disability and right to Independent Living in Social Care practice including assessment processes across all local authorities in Wales.
• To develop and deliver a national campaign on citizens' rights to independent living and social care.
• To enhance accountability by requiring local authorities to report on delivery of citizen wellbeing and independent living outcomes agreed during assessments through reporting processes.
• To establish a National Centre for Independent Living, run and controlled by disabled people, aimed at:
• Strengthening knowledge and understanding about the right to Independent Living.
• Increasing knowledge and skills regarding good practice in supporting and achieving Independent Living
• Devising strategies to broadening access and take-up of Direct Payments including developing the market for Personal Assistants.
• Maximising the role of local Centres for Independent Living through provision of support and access to resources.
• To urgently re-examine current funding arrangements for Disabled People’s Organisations and voluntary and community organisations and develop new funding streams, to compensate for the loss in fund-raising capacity during the Pandemic and general lack of access to Welsh Government and other grant schemes e.g., longer funding cycles, accessibility of application processes and support with developing proposals.
• To develop a National Advocacy Service (linked to Locked Out recommendation 14: Welsh Government to increase funding for advocacy services to disabled people in Wales to support them in navigating and advocating their interests when dealing with health and public service providers).
• Where a move to remote public service delivery is being considered and/or a return to in-person services, there must be a requirement to Equality Impact Assess (EIA) proposed changes.
• To require all local authorities to develop a work force plan to address the increasing shortage of rehabilitation services and specialists.

• Develop a national disability equality campaign within all sectors of the health and care system: In health care, there must be a strong senior leadership approach to understand and embed the Social Model of Disability to ensure it is brought into the approach to care.
• Create a national training framework for health and social care staff: Co-produce, with disabled people, a national training framework for health and social care staff
• Create/develop best practice guidance: Welsh Government to audit all its guidance to local authorities and Health Boards that impact upon the lives of disabled people. This must include staff guidance. Welsh Government should also develop co-production guidance for local authorities and Health Boards.
• Realign healthcare values and principles with anti-oppressive practices. We recommend:
  • The continuation/development of the Covid Moral and Ethical Advisory group (CMEAG) to include equality issues around Health Economic Measures (such as Quality Adjusted Life Year, or QALY and Adjusted Life Years (DALY), and use of Artificial Intelligence in health.
  • Welsh Government to commence discussions with the National Institute for Clinical Excellence regarding what arrangements they have in place for mitigating inequality when applying Health economic measures.
  • Develop an action plan with a clear timescale for reporting to develop a programme of policy and academic work to identify some key issues to take forward relating to explore the use of HEA and AI in disability.
• Make all health care information accessible to all people: Public sector IT systems must capture disabled people’s preferred formats of communication, and this must be acted upon.
• Retaining the best of the COVID driven changes to service delivery: Where a move to remote public service delivery (or back again) is being considered, indeed any major change in service delivery, there is a requirement for an Equality Impact Assessment (EIA) to take place before the changes are undertaken.
• Supporting disabled people’s organisations; Additional support and funding are required so that they can continue to support patients’ access to health care.
• Improve the physical access to healthcare settings: We must ensure that all healthcare settings are accessible for disabled people. The access issues that pertain, include parking, toilets, signage, support to access appointments and communication. An audit of all healthcare settings is required to identify what improvements are needed and where.
• Develop the All-Wales Standards on communication: The All-Wales Standards on communication must include provision for people with impairments.
• Develop healthcare scrutiny systems: The Ministerial Taskforce must ensure that a new body is created to safeguard the continued co-production of policies in Welsh Government, governance, scrutiny, and challenge arrangements relating to delivery/development of the disability rights action plan.
• Senedd of disabled people: Regional forums will provide a formal structure ensuring disabled people are able to participate fully and influence matters that impact their health and wellbeing as well as other areas of life.

The Working Group identified the urgent need to bring about a change in attitudes, values and culture in Welsh Government, public services and among the public in Wales: 

• Through education from an early age and additions to the curriculum and a better public understanding of the social model of disability.
• Through the widespread and mandatory social model training of public servants and organisations that are in recipient of public funds from Welsh Government.
• Through changes in policies, practices, and procedures throughout Welsh public services.
• Through greater research and an extension of the evidence base of the need for change, as well as monitoring of initiatives aimed at bringing that change about.
• Through legislation to strengthen disabled people’s rights and access to justice
• Through improved routes of advocacy.
• Through the better enforcement of existing mechanisms aimed at improving inclusion and through new mechanisms, where gaps have been identified.

The following actions/recommendations were proposed by the ESMD working group:

Education

Schools

Educating school age pupils about the social model of disability and the history of the disability rights movement was identified as potentially powerful (this was a recommendation of the ‘Locked Out’ report). 

Disability Wales are currently working with Welsh Government and schools in Swansea, Powys, and Conwy to develop and pilot a teacher training pack to address this recommendation. (Short term action).

A public campaign

A wider public campaign to raise awareness about the social model of disability in Welsh society is recommended and could be linked to an initiative to educate and train personnel in the media. Changing the way disabled people are portrayed and the language used by journalists is essential if stereotypes are to be challenged and the social model is to be better understood. (Short to medium term action).

Training

While it was acknowledged that social model training is not a ‘silver bullet’ and changes in personnel can be problematic, on-going mandatory social model training for Welsh Government officials and representatives was recommended. Embedding the social model of disability requires personnel at all levels of the organisation to understand and enact it, but it is also important that the representation of disabled people among decision-makers, continues to improve. It was noted that there have been missed opportunities to incorporate the social model into legislation (e.g., the SSW(W)A 2014) and policymaking in the past because it was insufficiently understood and embedded in Welsh Government’s work. (Short/ medium-term action).

Further discussions need to take place about how training could be extended to personnel delivering all public services across Wales. 

• Could this be done through the development and funding of an on-line module?
• Could Welsh Government make social model training a requirement of future funding and procurement?
• How will disabled people be involved in the content and delivery of training?

Disability advocates/Access Officer roles in public services

It was recommended that trained and properly remunerated disability advocates be established in key public services. Advocates would provide a reference point for disabled service users, many of whom are exhausted by having to constantly explain their different requirements. These post holders would also provide education and representation as well as ongoing scrutiny to public service organisations. Consideration in the short term needs to be given to:

• What these job roles would look like?
• How would appointees be trained?
• How would these posts be funded?
• Who would these appointees be accountable to?

In the past, Access Officers have been employed directly by local authorities, but the group is only aware of one remaining, in Pembrokeshire. Their role was to advise and critically appraise built environment proposals, internal and external, and local delivery of transport planning, including connectivity of transport modes. They were a conduit between local disabled people, and their organisations, enabling a constructive dialogue between officers, external consultants, and residents.

They required a good working knowledge of building regulations particularly in relation to accessibility, but also a capacity to build networks gathering the views of disabled people and feeding them into consultations and proposals. They also supported local Access Groups, (some of which still exist), and in England belonged to the national Access Association, bringing together professionals working in this field for professional development and networking. Since these roles have disappeared, the relationship between disabled people and local authorities has, in many areas, broken down. Access Groups are poorly supported, if they exist at all, and local authorities are not held to account for their failure to engage because challenging their decisions is simply too hard and required an understanding of technically complex plans.

This recommendation requires further discussion within Welsh Government and a report back to the group. (Short term action).

Strengthening the role and effectiveness of Equality Impact Assessments (EIAs)

The Audit Office of Welsh Government recently published a report entitled ‘Equality Impact Assessments: More than just a Tick-Box Exercise?’ 

As an existing lever for change and accountability EIAs could be utilised more effectively to embed both the social model of disability and the principle of coproduction. 

One suggestion is that there could be a requirement in EIAs that where potential impacts on disabled people are identified, DPOs with an appreciation of the social model must be consulted and be involved in the coproduction of potential solutions. This is particularly important in respect of changes to policy or legislation. 

It was, however, also recognised that it is important that disabled people are actively involved in the identification of ‘potential impacts’ as key decision-makers, not just consulted retrospectively. Furthermore, it was thought essential that agencies tasked with assessing the implementation of impact assessments undertake regular social model training so that public officials are fully cognisant of the implications of the social model, embed those principles into their own work, and are, therefore, able to lead by example.

Where legislative duties already exist that specify that ‘due regard’ must be paid to the views of groups with protected characteristics, in for example EIAs and Public Sector Equality Duties, this was thought to be too weak. The introduction of a stronger duty to consult and coproduce solutions (the latter being an active responsibility beyond mere consultation), would help ensure that representatives from organisations with a thorough understanding of the social model and coproduction are better integrated into the process. This has the potential to strengthen existing provisions and increase representation and participation. (short/medium term action).

The Working Group and Taskforce need to understand better how the equalities team in Welsh Government will respond to the Audit Office’s report on EIAs and how it plans to co-produce integrated EIAs (short term action).

Strengthening and Advancing Equality and Human Rights in Wales

The ESMD working group identified the report ‘Strengthening and Advancing Equality and Human Rights’ published in August 2021, and work currently being developed from this by Welsh Government, as relevant to the Disability Equality Taskforce. A central recommendation made by the report was the need for a stronger recognition of rights and accountability in the policy domain.

The commitment of Welsh Government to incorporating the UNCRPD into Welsh legislation potentially provides an opportunity, through Article 1, to embed international obligations and the social model of disability into human rights legislation and establish clearer links between equality, human rights, and well-being, in public policy. The group recommended that it was essential, therefore, that Welsh Government recognise this and establish a clear mechanism to incorporate the work of the Disability Equality Taskforce into its ongoing work on human rights. (Short and medium-term goal). 

The relevance of the concept of disability in Article 1 of the CRPD was explained in the meeting:

“The purpose of the present Convention is to promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity.

Persons with disabilities include those who have long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others”

The CRDP represents a move away from a medical model of disability towards a rights-based approach in law that acknowledges disabled people as capable and active members of society able to participate and consent in decision-making. 

The ESMD group, nonetheless, raised problems with the language used in the UNCRPD (henceforth referred to as the UNCRDP) and Article 1, specifically in relation to the term ‘persons with disabilities.’ This person first language implies that disability is primarily located in the individual, rather than society and is inconsistent with the terminology used by disability rights organisations in the UK. It would be imperative, therefore, that this language be amended to reflect this if Article 1 were to be incorporated into future Welsh Government legislation.

Missed opportunities and past social policy initiatives

The group identified missed opportunities in the past to embed the social model of disability into legislation. One example discussed was the Social Services and Well-Being (Wales) Act (SSW(W)A) 2014, which despite discussing the social model at the drafting stage, incorporated the medical definition of disability used in the Equality Act 2010 into legislation. Reasons why this may have happened are:

• A preference for consistency in legislation
• Dominant perceptions of social care as an end in itself, rather than a means of facilitating independent living/the social model.
• Complexity
• Austerity and fiscal constraints

The group noted that the UK Equality Act 2010 is a considerable source of confusion because of its reliance on a medical rather than a social model of disability. While recognising that consistency in law tends to be a good thing, if Article 1 of the UNCRDP were incorporated into Welsh law, legal inconsistencies might be created with existing legislation. One potential remedy to address this in the case of existing legislation would be to amend accompanying guidance. For example, the guidance that accompanies the SSW(W)A could be amended which would be easier to facilitate than changing legislation. Advice is sought from Welsh Government on how this recommendation might be advanced and how future inconsistencies in legislation might be addressed. (Short- and medium-term actions).

Additional recommendations include the development of a series of key questions/ requirements to ensure that the social model is embedded into policy-making considerations and during the legislative process. These might be incorporated into an EIA (see earlier discussion about consultation and coproduction as part of EIAs).

A Commissioner for Disabled People in Wales

The ‘Locked out’ report recommended creating this new role within Welsh Government and discussions undertaken by the ESMD working group reinforced the case for this recommendation. Embedding the social model of disability into the work of Welsh Government is a complex and multi-faceted objective, requiring oversight of variety of its core activities. To be achieved, significant cultural and organisational change would be necessary that can only be effective if scrutiny and accountability are conducted on an ongoing basis.

Evidence from this group suggests there is a poor understanding of the social model not only within Welsh Government but in public services and among the general population of Wales. It does not help that UK and Welsh legislation reinforces and legitimises the use of a medical model. The task of bringing about change and addressing current inconsistencies is a considerable one and disabled people remain under-represented in positions of decision-making (a situation that cannot be remedied quickly). The case for a dedicated Commissioner to represent the interests of Disabled people we believe is a strong one, and equally as strong as the basis on which Commissioners have been created in the past. We recommend discussions are initiated to address this suggestion as soon as possible (short term action, with medium term implications).

The potential role of regulation

The ESMD group are aware of the potential for using regulation as a tool to try to embed the social model of disability into the work of Welsh Government and wider public service providers. However, more discussion needs to take place about how this kind of regulation would be applied and operationalised. 

Examples of using the role of Welsh Government as regulator might be for inspectorates to introduce requirements that they demonstrate what steps they are taking to embed the social model of disability in their organisations. This might apply to the Care sector (Care Inspectorate Wales); local authorities; the health service; Inspectorate for Schools etc.

The group recommends that a scoping study is conducted by Welsh Government examining the role that might be played by regulation in embedding the social model of disability into policy making and delivery. This could also examine the role of Welsh Government as procurer of goods and services. (short-term action with medium term implications).

It is recommended that Welsh Government host an Employment Summit for Wales. This would engage with Welsh employers, Disabled People’s Organisations (DPOs) and the public, to raise awareness of disabled people’s employment rights, challenge limiting stereotypes, and build positive relationships with employers.

Simply having a law to protect disabled people when they seek or are in employment, is not enough. Too often those the law is intended to protect are unaware that they have rights or, are unable to access support to exercise them. Experiences also suggest too few employers properly understand their legal obligations and the range of adjustments (many straight-forward and inexpensive), that could make the employment or retention of disabled people possible. Wales needs a public conversation. Negative stereotypes need to be challenged and the social model of disability better understood. Many disabled people with long term chronic impairments exit the labour market because they do not realise they can access reasonable adjustments. This loss of talent, experience, and skills is a failure in the operation of law. It does not benefit organisations, workers, or the Welsh economy.

Disability is not a minority issue and the likelihood of acquiring an impairment increases with age. Wales needs a sustainable approach to work that takes account of changes throughout the life-course. Work can provide economic independence, reduce social isolation, and improve well-being, but only if accompanied by good working conditions. The United Nations (UN) investigation into breaches by the UK Government of the Convention on the Rights of Disabled People (CRDP), demonstrates the importance of access to good quality work for disabled people as a human right. Welsh Government has significant opportunities to make better use of existing regulations by strengthening education and accountability and improving the poor provision of legal advice in Wales to enable disabled people to access their rights (Articles 12 and 13 of the UNCRDP). The Programme for Government includes a commitment to “Establish an equalities legal service to provide support on unfair or discriminatory employment practices” and the Disability Action Plan needs to further this objective.

Disability Confident Wales+

The existing UK Disability Confident scheme lacks ambition and importantly, disabled people have little confidence in it. Building on the work of the Disability Rights Taskforce (DRT) it is recommended that a made in Wales addition to this scheme or kitemark is coproduced with DPOs, Welsh employers that have achieved leadership status in the existing scheme, Disabled People’s Employment Champions, and Trade Unions. Ideally a Disability Confident Wales + would build upon the existing DWP Disability Confident scheme, however if this is not possible, Welsh Government should explore the option to incorporate other frameworks such as the Disability Business Forums Disability Smart Framework. The scheme would incorporate and celebrate distinctive Welsh values of social partnership, fair and decent work (Article 27 CRDP), commitment to a real living wage, and well-being. A vehicle for providing education, training, and developing good employment practice, the scheme would also link to a central objective of Welsh Government: socially responsible public procurement. Currently, only 40 employers in Wales have achieved Disability Confident Leadership status, just 12 in the private sector. An employers kitemark was proposed under the previous Action on Independent Living but this was not realised despite DWP engagement in 2020 to 2021.

The need for better representation of disabled people’s interests in the Social Partnership and Public Procurement of Wales Act

It is recommended that at the first Social Partnership Council meeting to take place in early 2024, Welsh Government propose that an equalities sub-group is established to ensure that disabled people and others with protected characteristics are properly represented.

Use the power of public procurement to co-produce guidance to promote and embed positive employment practices for disabled people and others with protected characteristics in all Welsh Government contracts, including requirements that contractors:

• Demonstrate they have effective procedures to deal with reasonable adjustment requests and a clear understanding of all equality obligations.
• Gather and report disability employment data, to help incentivise contractors to employ disabled people; create an environment where disclosure is viewed positively; and to aid the retention of disabled employees.
• It is also important that contractors demonstrate they have adequate dispute resolution procedures in place to address disabled people’s grievances, particularly in relation to reasonable adjustment requests. Too many organisations fail to constructively learn from conflict in this area and instead use non-disclosure agreements conditional on disabled employees exiting organisations, to resolve disputes. It should never be the case that a settlement is conditional on a disabled person relinquishing their employment, unless there is sufficient evidence that all other options have been extensively explored.

Proactively Equality Impact Assess (EIA) procurement decisions co-productively. Audit Wales questioned whether EIAs had become ‘tick box’ exercises. EIAs and the Public Sector Equality Duty must be used not only for ‘eliminating discrimination’ but to address the broader aims of ‘promoting equality’ and ‘fostering good relations’ (see below). Mainstreaming equality outcomes in procurement needs to become an integral part of this process.

Ensure that disabled people are prioritised in relation to flexible working arrangements as fundamental reasonable adjustments.

While welcoming a UK Bill that could extend the rights of all employees to request flexible working, there is concern that disabled people could face competition when making similar requests for reasonable adjustments. It is poorly understood that disabled people occupy a different status in employment law. Disabled workers should always be treated differently and it is often lawful to treat a disabled person more favourably than a non-disabled person.

Welsh Government has important educational, strategic, and leadership roles to play by using fair work policies and programmes to promote a better understanding of disability law. Educational and training materials coproduced with disabled people could be utilised by Employment Champions, Business Wales (see below), and a new Disability Confident Wales + scheme to support employers. Imaginative job re-design is central, so that flexible working arrangements are viewed positively, rather than a means of accommodating non-standard workers in standardised job roles. The current widespread ‘deficit’ approach towards reasonable adjustments is shaped by ableist norms.

Opportunities to work from home post-pandemic potentially provide new employment opportunities for disabled people, although there are fears that these are under threat. It is essential that where appropriate, homeworking becomes an accepted reasonable adjustment. However, homeworking must be supported, safe, and suitable. It is important that workers have the choice not to work from home and it is of concern that revised DWP work capability assessments threaten this. Homeworking must never be used as a justification for failing to improve the accessibility of public workplaces, transport systems, or wider infrastructure.

It is recommended that Welsh Government, which is uniquely placed having embraced homeworking post-pandemic, works with DPOs and social partners to develop a good practice ‘Home and Hybrid Working Charter for Wales.’ Urgent data is needed to better understand the challenges of home and hybrid working for disabled people. Developing hybrid opportunities to participate in all Welsh Government funded events and activities beyond working arrangements, is also needed to foster inclusive citizenship in Wales.

Employment retention is a dimension of the disability employment gap that is often overlooked. More data is needed on what steps employers are taking to retain disabled people in their workforces. In addition, proactive measures such as flexible working arrangements; redeployment; retraining; mentoring; creative job re-design/ job carving and case studies of where these have been successful, require promotion. Too often disabled people do not receive appropriate reasonable adjustments and are forced to leave employment or take on part-time roles, which can leave them in poverty. It is recommended that Disabled People’s Employment Champions play a leadership role in developing this work stream.

When Access to Work services provide timely advice, disabled people consistently provide positive feedback. However, recent delays in evaluations, bureaucracy, increased demand, and pressures on funding post-pandemic, have caused serious problems. The DWP’s white paper “Transforming Support: The Health and Disability White paper” proposes improvements to the service, including developing a digital system and rolling out passports. Our discussions also identified a need for more advisors with lived experience, particularly from misunderstood impairment groups (e.g. deaf/blind people); a need to increase the promotion of services to disabled people who are, or may be, considering self-employment; and given the importance of volunteer roles in providing a gateway to paid employment, support for this group. As active participants in the Welsh Stakeholder Forum led by Access to Work, it is recommended that Welsh Government raise these issues for further discussion, alongside the possibility of an expanded feedback loop with DPOs, and disabled representatives in devolved services such as education and health.

It is recommended that Welsh Government demonstrate by example, a more explicit understanding and commitment to using positive action and positive discrimination where the law permits, in their employment practices and contractor relationships. Employment law is often ineffective because employers and public authorities are not proactive in circumstances that allow them to be.

Examples of positive action include proactively stating in job advertisements the availability of part-time, flexible, hybrid and remote working. The inclusion of statements encouraging disabled people to apply for jobs where they are under-represented: particularly important in relation to senior roles. Clear and positive signposting of policies and procedures. Supportive discussions around reasonable adjustments at interview, appointment, appraisal, and promotion.

“It is not possible for a non-disabled person to claim disability discrimination under the law. This means you can treat a disabled person more favourably compared to a non-disabled person. You can specifically advertise for and recruit a disabled person without the risk of disability discrimination” 

(ACAS). 

This poorly understood aspect of employment law prevents organisations from learning from the lived experiences of disabled people. To improve policy, services, and the experience of users, better representation of disabled people throughout the workforce is needed. Employers and public institutions must be more willing to utilise provisions in the Equality Act that allow the recruitment of disabled people as a genuine occupational requirement. Work needs to be done to help public bodies develop confidence in using positive action provisions and Welsh Government has a leadership role to play. Principles of positive action and positive discrimination where relevant to disability employment law, need to be embedded in Welsh Government practices and expectations of contractors and all organisations they fund.

Transitioning from education to employment

Welsh Government produced an innovative document: ‘Inclusive Apprenticeships: Disability Action Plan for Apprenticeships 2018 to 2021’. This recognised that too few disabled people are accessing apprenticeships and identified employers being insufficiently aware of the support available to them if they take on a disabled apprentice. A thorough evaluation of the objectives and impact of this Action Plan is needed, and a new group established to build on its achievements and coproduce a strategy with disabled people for the next 10 years.

Welsh Government have been involved in initiatives involving young people wanting to access work, such as ‘Engage to Change’, which supported learning-disabled people. Valuable knowledge and skills have been gained through participation in projects, but because funding is short-term there is a danger that accumulated expertise in Wales will be lost. It is recommended that greater longevity and certainty in funding is provided to support in-house expertise in this area within Welsh Government. This would ensure existing programmes are maintained and future initiatives such as a Mentors and Ambassadors programme and a National Job Coaching model, are developed.

The ‘Go Wales’ scheme has helped to facilitate positive work placements for disabled graduates and has received positive feedback from Disability Wales. Providing valuable work experience, it facilitates clear pathways into the labour market and could be used as a model for further development. It is, however, essential that current age restrictions are lifted in the scheme and a dedicated pathway for disabled people supported by Welsh Government, is recommended.

It is important that when the new Commission for Tertiary Education and Research (CTER), which will have oversight for post-16 education in Wales, becomes live from April 2024, it is made aware of the work of the Disability Rights Taskforce and its recommendations. Two key priorities of the CTER will be to promote equality and improve access to education. It is recommended that Welsh Government designate a named person to ensure that disabled people’s interests are sufficiently represented from the beginning of this important new body.

More tailored support is needed for disabled people wanting to return to education and training, many of whom may have fragmented education, training, and employment histories. A distinctive ‘disabled returners pathway’ needs to be developed to allow for confidence building, cv building and a supported reintroduction to education and work. We recommend Welsh Government work with Further and Higher education institutions in Wales and the CTER to establish appropriate pathways to re-skill and up-skill disabled people. A Welsh specific intervention is needed. This should not just be viewed as the responsibility of the UK Department of Health and Social Security.

It is proposed that an ‘Anti-Ableism Network’ is established across the Welsh further and higher education sectors. This needs to challenge stereotypes and monitor educational needs, provision, and achievements of disabled people and address their under-representation among staff in these sectors. The Network could also be a vehicle for sharing good practice, collecting data on the disability pay gap and be responsible for promoting an anti-ableist culture in the post-16 education sector. With a duty to report to Welsh Government and measure its progress annually, it is recommended that the Network also develop the first Disability Equality Chartermark in the UK further and higher education (these already exist in HE for gender and race and sexuality). Standards to be met in the Chartermark must be co-produced with DPOs and groups/ organisations representing staff and students.

Self-Employment, Entrepreneurship and Freelancers

Discrimination can force disabled people out of the labour market into self-employment, however, others make a positive choice to become self-employed or become freelance workers. Both situations can involve challenges.

Better awareness of the support available through Business Wales is needed among disabled people considering, or who are already, self-employed. Business Wales has developed services that aim to be inclusive and accessible to disabled people, but despite its considerable reach among businesses, engaging with disabled people remains difficult.

• It is recommended that Business Wales co-produce with Welsh DPOs a piece of research to establish the reasons why disabled people are not exploiting Business Wales services and what alternative approaches can be put in place.
• It is recommended that Business Wales consult with DPO’s to review workshops that are already offered by the service and may need adapting or, if identified as needed, co-produce a new workshop on self-employment and freelance work for disabled people.
• Business Wales and Welsh Government Relationship Managers have an important role to play in encouraging and promoting conversations between businesses and Disabled People’s Champions, on how to adopt and promote the Social Model of Disability in their organisations and employment practices. It is recommended that Business Wales encourage businesses to undertake the Social Model of Disability training that is available on the BOSS platform and engage with DPOs who can provide further tailored advice and training involving people with a range of lived experiences, in this area.
• It is recommended that Business Wales consider developing a Disability Employer Hub, providing a central portal of advice, guidance, resources, and examples to support employers to employ disabled people. The Hub should also signpost to other support programmes and funding schemes, and should reflect the full pathway of recruiting, retaining, and supporting disabled employees of all ages, including those who become disabled while in the workforce. The content of this hub should be co-produced with disabled people and regularly reviewed/updated.

Freelancers as a distinctive group are poorly understood and their specific needs are often overlooked. For example, disabled people in the creative industries who play an important role in challenging stereotypes, often report barriers including inaccessible venues, absence of procedures to reasonable adjustments and a benefits system that does not support short-term, unpredictable periods of work. Many public spaces like theatres and music venues, are insufficiently accessible and the status of disabled freelancers as self-employed, often mean their needs are overlooked and they find it difficult to access legal rights and work. It is recommended that:

• Freelancing as an employment status is better recognised and considered within co-produced (with unions, workers, and disabled people) ‘Fair Work’ principles.
• Data needs to be collected to gain a better understanding of freelancing as an employment status, not least to understand the number of disabled people in this group and how freelancing fits into debates about our understanding of disability pay and poverty gaps.
• Freelancing needs to be recognised as a positive choice by some and not always negatively as a form of casualisation. As such, freelancers should not be forced onto contracts or PAYE and it is recommended that Welsh Government lobby to reform the benefits system so that freelancers are better supported as a distinctive group.
• It is recommended that Creative Wales work with disabled people, Welsh Government and unions to improve awareness of Access Riders and the need for freelancers’ places of work to be made accessible; and encourage grant funding that includes ring fenced budget lines to allow for access costs to be met for workers, freelances and audiences.

Income

It is acknowledged that Welsh Government is limited to act in areas of social security. It has, however, introduced policies and discretionary payments to alleviate disadvantage, has an important role to play in collecting data and evaluating the socio-economic circumstances of Welsh citizens, and lobbying for change in the UK policy.

More and better data is needed to understand how gender pay gap reporting has affected employer behaviour in Wales, so that positive benefits can be extended to include pay gap reporting on disability and ethnicity.

Publicly available data is needed on the recruitment, retention, and progression of disabled people in Welsh organisations. It is recommended that Welsh Government consider introducing a positive duty that requires employing organisations to track and report such data as part of its review of specific duties for Wales. This would include a requirement for public authorities to publish their analysis of why gaps exist and be required to set in place action plans to reduce them. By providing formal oversight of this process Welsh Government would take on a leadership role, one that is compatible with its objective to place socio-economic disadvantage at the centre of strategic decision-making.

The introduction of a (Universal) Basic Income would have clear benefits for disabled people. It would improve access to education and training and support disabled people needing work or volunteering experiences as confidence building pathways to employment. By providing a safety-net during disruptions in employment caused by ill-health, treatment, rehabilitation, or the need to implement reasonable adjustments, a basic income could contribute to job retention and reduce the administrative costs associated with means-tested benefits. For the many disabled people in precarious forms of employment, a guaranteed basic income would free them from a frustrating and often punitive social security system that often penalises them when they work. Furthermore, disabled people unable to work at all would have a security of income to help them to live more independently and with dignity. Welsh Government is uniquely placed to apply learning from its current Basic Income Pilot to disabled people and it is, therefore, recommended that when reviewing evidence (evaluation is currently scheduled for 2026), it conducts a feasibility study and cost-benefit analysis of its application to this group.

In July 2023, Disability Wales launched its report 'Barely Surviving': The Impact of the Cost-of-Living Crisis on Disabled People in Wales. It is recommended that when introducing policies that provide financial support to address socio-economic disadvantages Welsh Government automatically applies a ‘disability premium’, which recognises the additional costs associated with being disabled, for example, the need for heating, power, equipment, or disability related expenses. It is also essential to acknowledge that some funded schemes to alleviate disadvantage have proved inaccessible to some disabled people.

The Office for Budget Responsibility forecasts 370,000 fewer disabled people or people with health problems will receive an additional payment in their Universal Credit or Employment and Support Allowance due to recent UK Government changes in eligibility criteria but estimates reforms will only raise employment by around 10,000 by 2028 to 2029. It is recommended Welsh Government express concerns about this and lobby for full powers over disabled people’s welfare benefits. A significant advantage of devolution in this area is that it would allow eligibility criteria and assessment of benefits to be based on a social model of disability and enable Welsh Government to better achieve its objectives under the Welsh Socio-Economic Duty.

The Employment and Income group heard from the Bevan Foundation about proposals for a Welsh Benefits Charter, which Welsh Government are now working towards. The commitment to use the Social Model of Disability in the design and delivery of Welsh Benefits is very much welcomed and it is understood an external steering group will be established to drive this work forward, develop an implementation plan and report back to the Partnership Council for Wales on progress. It is recommended that as well as inviting Disability Wales to join this Steering Group, consideration is given to the support required by specific impairment groups and intersectional issues, given some of the socio-economic findings detailed in the ‘Locked-out’ report.

Recommendations across all transport and travel modes

Commission a public media campaign on the public’s perception of disability, which must include non visual impairments, particularly around blue badge parking, and assistance that may be required on transport. Seeing the issues faced by disabled people each day will help the public understand the barriers that disabled people face. This could feed into an overarching public campaign, which speaks across all the working groups, making the public aware of the rights of disabled people to equity of access. It is essential that visuals are truly inclusive and feature a variety of people using a variety of mobility aids.

Journey planning websites should include the accessibility requirements of disabled people, end to end. This is required to ensure disabled people can plan their journeys ahead of time, considering problems such as drop kerbs, bus stop heights, and changing spaces.

Transport websites must be tested for accessibility and be developed with the involvement of disabled people. Transport websites should also include information on parking for Blue Badge holders.

Ensure tickets can be purchased in person at the station and on the train, as some individuals may be digitally excluded. Smart ticketing must be accessible to all disabled people and should not, in itself, create an additional barrier.

Establish an independent multi-modal Disabled Persons’ Transport Advisory Committee (DPTAC), which reports to the Minister responsible for Transport, and is represented by people with lived experience. Wales is currently the only nation without a Disabled Persons Transport Advisory Committee in the UK. This must change if we are truly committed to improving outcomes for disabled people and the daily barriers they experience when using transport.

We recommend Welsh Government put measures in place to ensure that reasonable adjustments required, such as a personal assistant or companion when using public transport, does not result in additional costs to the disabled person. It must be recognised that the impact of additional costs for disabled people when travelling provides a barrier to participation in Welsh society on all levels. Disabled people must not be penalised for their impairments and left behind. Further, cancellations of transport services have a far greater impact on disabled people, and so the eligibility criteria for concessionary travel, whether or not a companion is required, should be the same system across all public transport modes.

We recommend Welsh Government undertake research to assess the impact of cuts to transport following the COVID-19 pandemic and to assess to what extent those cuts have impacted on isolation and loneliness experienced by disabled people.

We ask the Cabinet of the Senedd to undertake ‘a day in the life of a disabled person’ using public transport. This recommendation has been made to raise awareness in leaders and decision makers of the barriers and challenges disabled people face every day of their lives when accessing public transport.

Taxis / private vehicle hire (PHV)

We recommend the development of a standardised programme of mandatory training covering the Social Model of Disability, equality legislation and good customer care for taxi drivers. This training should be co-produced with disabled people and delivered with their involvement.

Licensing Officers must act on refusals by taxi and PHV drivers to meet accessibility needs of disabled customers, as set out in equality legislation. For example, refusal of service animals or equipment.

We recommend as part of the reform of taxi and PHV services, Local authorities should be required to have an appropriate proportion of available wheelchair accessible vehicles. For example, ensuring wheelchairs can be clamped down for safety.

Bus

 Under the proposed DPTAC group, we recommend a multi-agency body that looks at serious complaints raised by disabled people, which can hold bus companies to account. In the short term, Bus Users Cymru must be resourced to organise and promote ‘bus surgeries’ in accessible venues. There is no national mechanism for engagement between bus companies and their disabled customer base, and it is difficult to make a complaint. More serious complaints require escalation and timely resolution.

We recommend that bus operators commit to a standardised programme of mandatory training, covering the Social Model of Disability, equality legislation and good customer care.

We recommend that as part of bus franchising, the overarching regulatory authority must have a department dedicated to overseeing accessibility and inclusion in all aspects of bus travel. This department would have the authority to issue guidance and act when standards are not met. This department must ensure that both the bus companies/operators that run services and the local authorities who have oversight of bus infrastructure report back in the implementation and maintenance of accessibility requirements. It must foster meaningful engagement to ensure that disabled groups have a role in co-producing accessibility guidance, standard practices and complaints procedures and ensuring that voices can be amplified to remove barriers to accessing bus travel for disabled people. Accessibility must be deliverable and enforceable under the proposed Franchising Bill and be developed as a program for improvement, which is coproduced with disabled people.

We recommend plans to ensure a consistent approach to the provision of digital information at bus stops, bus interchanges and bus stations. Any future Apps developed to support customer information must be fully WCAG 2.1 compliant and compatible with screen reader technology. 

Local authorities should use emerging technologies to make information accessible such as digital information at bus stops with audio functions / screen readers and ensure that their function is properly maintained.

We recommend mapping the Community Transport services across Wales and review funding, particularly where there is currently no provision. The impact of cuts to bus services is a problem for many disabled people in Wales. This creates a barrier to participation in Welsh society.

Rail

We recommend a standardised programme of mandatory training covering the Social Model of Disability, equality legislation and good customer care services for all customer facing rail staff.

The Wales Transport Strategy obligations must be fulfilled by ensuring that all railway stations are fully accessible.

Ensure that all trains have accessible toilet facilities. Having to get off the train to use station toilets, which may not be open or nearby is totally unacceptable and impossible for some disabled people.

Ensure all timetabling and journey planning information is fully accessible to all disabled passengers. Any future Apps developed to support customer information must be fully WCAG 2.1 compliant and compatible with screen reader technology.

We recommend Transport for Wales (TfW) invest in improved signage and staff awareness of the impact of putting prams, luggage etc. into the priority seating areas. 

Active travel

We recommend a review of the intention and definition of the term ‘Active Travel’ and any future reviews of the Active Travel policy should reflect the Social Model of Disability. The word ‘active’ suggests that this mode of travel is not for all disabled people, along with the statement ‘natural mode of travel’. We need more inclusive wording if ‘Active Travel’ is to resonate with and be used by disabled people.

Active travel routes must be inclusive of all users, for example ensuring availability of charging points for wheelchairs, provision of accessible equipment, resting points, information on gradients, and where space is shared with cyclists. For too long, disabled people have been designed out of access to communities. This must change.

Local authorities must have representation from disabled people when developing new Active Travel routes. Funding from within Active Travel budgets should be allocated to support that involvement, and for that to be evidenced when the scheme is submitted to TfW for approval.

All professionals who work with children and young people (particularly in education, health, sport, cultural activities, social care, childcare, youth service, play development, midwifery and health visiting) need to be educated on Social Model of Disability, disabled people’s socioeconomic status, and disability history.

This education should be incorporated into initial training and continuing professional development. Regulators should be asked to include it within Codes of Professional Conduct and should monitor that is has been undertaken.

The Locked Out: Liberating Disabled Peoples Lives and Rights (Wales) Beyond COVID-19 report highlighted the importance of the social model of disability but the lived experiences of those within the working group showed that those who work with disabled children and young people are not aware of it or how to use it in their work. 

Welsh Government should ensure that data is collected to monitor compliance with this recommendation when it is implemented.

Welsh Government must revisit and amend the integrated impact assessment to ensure that the children’s rights section can properly incorporate the rights and voices of disabled children as required by Article 12 of the UNCRC.

The Locked-Out report highlighted the need for human rights legislation. For children and young people, the Rights of Children and Young Persons (Wales) Measure 2011 should already mean that policy makers have due regard to the UN Convention on the Rights of the Child and the Equality Act 2010 (and the Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011) means that policy makers should have due regard to the needs of disabled people, and as part of that disabled children and young people. However, the lived experiences of those within the working group do not reflect that these two duties are being considered together and therefore they do not currently ensure that policy makers have due regard to the rights and needs of disabled children and young people.

Welsh Government should deliver a cross departmental action plan to identify and reduce the delays that impact the service provision received by disabled children.

This action plan should have at its core the needs and aspirations of disabled children, as expressed by disabled children themselves, and must seek to identify how these delays can be removed.

The lived experiences of those in the working group highlighted the devastating effect of delays in receiving services, which has significant negative impacts on disabled children and young people. Weeks or months within any child or young person’s life are hugely significant. Lack of access to services, such as not having the relevant support in school or waiting for a diagnosis or health service can be life changing for a child or young person and can stop them achieving their full potential.

Welsh Government must adopt an intersectional approach to decisions about disabled children and young people. The action plans that relate to other protected characteristics (such as the Race, NYTH/NEST and LGBTQ action plans) must be reviewed to ensure that they fully incorporate the needs, aspirations and voices of disabled children and young people.

All members of the working group agreed that support for disabled children and young people needs to have an intersectional approach, as many disabled children and young people have more than one protected characteristic and sometimes this can put them at a particular disadvantage.

Public education

Welsh Government should run a public campaign to ensure that all children and young people understand their rights under the UN Convention on the Rights of the Child (UNCRC), the United Nations Convention on the Rights of Disabled People and the Equality Act 2010.

Those in the working group often shared that they had only discovered these rights late or were not aware of how they could be used to ensure these rights were realised properly.

This is also important as parents and carers do not always know about these rights and find out much later or are not aware of them. This should be accompanied by making sure that parents and carers of disabled children and young people know where and how they are able to access support. There is a need to consider people and communities in Wales where there may be a need to provide additional support and awareness.

The children and young people that we spoke with shared accounts of ignorance/discrimination from people who have dubbed them “too young to be disabled” or through statements suggesting that they “don’t look disabled”. Such a campaign should specifically target society’s perceptions of disability and assumptions about children and young people with non-visible impairments. Children and young people stressed the wider understanding of the Social Model of Disability and the common belief that a person does not need to be “fixed” to fit in.

Education

Welsh Government must include in the What Matters Code a reference to the Social Model of Disability. Alongside this, Welsh Government should include the Social Model of Disability in the statutory guidance and should develop anti-ableist content to support schools in their delivery of the Curriculum for Wales delivered to all children in Wales (regardless of their education setting).

Amongst others, the curriculum must include the Social Model of Disability. We acknowledge that the What matters Code already includes Disability History, UN Convention on the Rights of the Child (UNCRC), United Nations Convention on the Rights of Disabled People and the Equality Act 2010. However, additional materials should be prepared to ensure that wherever children are educated (schools, pupil referral units, education otherwise than at school and for those who elect for home education), they are educated on these issues. This is important because one of the key barriers identified by the working group were attitudes in society. We note that there are already examples of best practice available, such as the UNCRPD Disability Wales resources on Hwb.

Children and young people within this session recommended that disability must be included in the curriculum as they wanted to be understood by friends and peers.

Welsh Government properly resource educational settings to ensure that the new Curriculum for Wales, and in particular the digital curriculum for Wales is accessible to all disabled children and young people. Should be accompanied with data and should seek to reduce the attainment gap for disabled children and young people. This should be accompanied by monitoring and where necessary enforcement and intervention to ensure educational settings comply.

We acknowledge that the new Curriculum for Wales has been designed in a way that does not prescribe particular activities, it is technology neutral with an emphasis on user needs. This enables educational settings to adapt their approach to ensure it is accessible. However, educational settings need support to ensure that when they implement, that they follow that approach. It is particularly important that this happens not only in schools, but in pupil referral units, education other than at school and is available for those who elect for home education as educational setting other than at school provide education for some of the most vulnerable learners.

It is important that disabled children and young people acquire good digital skills to access the curriculum, if this does not happen, they can feel excluded. Digital skills must be taught by a specialist teacher who understands how to engage with the technology and accessibility features e.g. a child with a VI may not be able to use a mouse while others will require screen magnifying software.

Welsh Government to work with relevant stakeholders and young people with visual impairments to explore the creation of an assistive technology passport for those with visual impairments so that assistive technology moves with a young person and remains in their ownership and therefore improves their ability to search for and access work, volunteer opportunities and work experience.

Children and young people told us that training was needed on accessibility devices, apparatus, or equipment to accommodate a range of impairments and ensure equal opportunities.

Welsh Government must develop an action plan and properly resource schools to ensure that the Education workforce is able to fully support disabled children and young people. This must include ensuring full training for teachers and support staff at all stages, recruiting and retaining specialist teachers where needed and providing additional specific training for staff when needed.

Many members of the working group highlighted that staff in education are the most crucial in ensuring that disabled children and young people are able to access inclusive education.

Children and young people recommended mandatory training for teachers and career advisors within schools to overcome bias and stigma. They shared stories of discouraging feedback on their ideas for a future beyond school, stating that they would not be able to enter the workplace or professions rather than encouraging students to follow their passion and suggesting which reasonable adjustments might be required to enable their success.

Welsh Government should reconsider how it can truly achieve inclusive education as set out Universal Design for Learning and in Article 24 of the United Nations Convention on the Rights of Disabled People, when the Additional Learning Needs and Educational Tribunal Act 2018 is implemented.

The lived experiences of people within the children and young people group do not currently reflect this change as there are still systems where disabled children and young people have to access special schools or be educated outside of school. We have heard cases of attitudes and facilities in mainstream schools not being inclusive. Inclusive education will only be achieved when disabled children and young people are able to access education within their communities at mainstream community schools, along with any additional support or adjustments. The group also reported difficulties with the ALN support, including having to wait for diagnosis before support was given and teachers not being trained in ALN.

Welsh Government should redesign guidance and codes of practice for qualifications, attendance, and behaviour management systems in schools, pupil referral units and groups that provide education otherwise than at school, so they focus on the needs of disabled children and young people. 

The evidence from the working group includes:

• In Wales, there is no reporting system in place to report any restraints on disabled children and young people in schools. An independent reporting system is recommended to ensure that reasonable adjustments to education are being universally met.
• Mainstream education is not fit for purpose for disabled children and young people.
• Examinations and the A* to C expectation are harmful as they overlook the lack of cohesion between disabled students and the education system.
• Target grades and ability to sit examinations should be determined on a case-by-case basis.
• Schools often take a punitive approach to behaviour (e.g. shaming and attendance/behaviour reward systems). There is a need to understand and communicate why these disabled children and young people are acting the way they are, instead of punishing them for not following the status quo.
• Attendance requirements and awards are usually out of reach for disabled children and young people and adjustments are not made.

Welsh Government should require schools to encourage learners to engage with learning that enables them to develop communication skills to overcome communication barriers. Alongside this, Welsh Government should monitor and where necessary enforce the legal requirements for the provision of communication aids for disabled children and young people who specifically need them.

The working group was encouraged to hear about the development of British Sign Language not only as a GCSE but at all levels of the curriculum. However, we note that resources mean that this is only provided where a school opts to provide it. We also heard many examples where communication provision was not in place. It is crucial to remove barriers for disabled children and young people enabling them to communicate as widely as possible. Part of this is encouraging others within society to increase their abilities.

Welsh Government must develop an anti-bullying strategy that specifically seeks to protect disabled children and young people.

Too many disabled children a forced to leave mainstream schools because of their schools’ lack of willingness to protect them against bullying. “Ambitions for Wales” is the children’s commissioner for Wales report on survey results and analysis of the experiences and hopes of children, young people, parents and carers and professionals in Wales, and their priorities. Professionals most frequently identified disabled young people as most at risk from bullying and highlighted online and local neighbourhoods as the most high-risk environments for bullying.

Children and young people were particularly concerned about discrimination and bullying – both in person and on social media platforms; which can have a negative impact on their mental health and positive view of themselves, their value and self-worth.

All disabled children must be able to attend schools that are local to them so they can be educated alongside their local friends and family. 

To achieve this level of accessibility, Welsh Government must ensure that Councils, schools, and colleges, fully comply with their duties under the Equality Act 2010, and the Public Sector Equality Duty. 

While physical accessibility to schools is crucial, to achieve full accessibility, a whole school approach is required. This approach must include the curriculum, training and professional development for all education staff, adherence to specific regulations, and a workforce strategy that takes into account the needs of disabled children when assessing the requirement for specialist teachers or additional training for teachers.

Welsh Government must immediately resource schools and Councils so that they can fully respond to the support needs of their pupils and comply with their legal requirements under the Equality Act. This must also be accompanied by enforcement or intervention by Welsh Government where they do not comply.

The evidence from the working group includes:

• There is a lack of an individual approach to a student’s reasonable adjustments, and often schools favour a catch-all solution for every disabled student.
• Councils are not aiming to achieve more physically accessible schools or a physically accessible environment in all areas accessed by disabled children and young people, such as parks, youth clubs, childcare provision.

Children and young people with sensory issues shared their frustrations with mandatory uniforms, stating that they are uncomfortable and distracting them from focusing in the classroom. Others shared that the learning environment itself can be a barrier i.e. harsh and bright lighting, large rooms which affect the acoustics and steps into the space.

Children and young people also shared frustration with teacher’s negative attitudes towards the use of ear defenders in school settings.

Welsh Government must immediately resource schools and Councils so that they can fully respond to the support needs of their pupils and comply with the ALN Code of Practice. 

The evidence from the working group includes:

• Teachers without training or not having specialist teachers when needed has a significant negative impact on disabled children and young people.
• Where parents or carers chose to home school their children, ALN support is varied or not provided at all. Proper training, resources and funding are vital for parents of children who cannot physically attend school.
• There is poor engagement and action from mainstream schools for disabled children and young people, which forces them out. There are also regional inequalities in ALN support systems, which need to be evened out.
• ALN is still seen as an educational need, rather than a health need, instead, this should be a ‘hand-in-hand’ approach.

Welsh Government must develop and action plan to ensure that Councils and Further Education providers comply with the Equality Act 2010, both when deciding on provision for learners post-16 and when that provision is in place. This must include that all staff involved, including academic staff are trained in the social model of disability.

As above, evidence from the working group showed that in this crucial transition stage, there can be a lack of aspirations for disabled young people. Lack of reasonable adjustments or local provision can be a barrier to disabled young people being able to access educational provision post-16 which can affect their employment prospects.

Welsh Government should consider more support for alternative non-academic pathways for disabled young people after the end of compulsory education.

Increased recognition of higher education opportunities is required for disabled young people, especially those receiving education other than school (EOTAS). Attending university is sometimes not feasible for disabled young people and imposes an able-bodied view of academic progress. A bespoke EOTAS curriculum for young adults should be considered to make higher education prospects more accessible to those unable to attend university.

Health and social care

Welsh Government should place specific statutory requirements upon Health Boards, and where appropriate centralised services, to ensure that health services for children and young people provide timely diagnosis and services for disabled children and young people.

This should include ensuring that they take disabled children and young people’s needs and aspirations into account in their workforce strategy, which may need to include specialist services or additional training for staff.

Evidence from the working group showed that there were often significant delays in services, including mental health services, Speech and Language Therapy (SALT) / Occupational Therapy (OT) / Physiotherapy which had a significant impact upon disabled children and young people’s lives.

Welsh Government should require regulators and professional bodies to include communication requirements within the Code of Practice for all health and social care professionals.

These requirements should include that all professionals adapt to disabled children and young people’s communication needs when they are providing any health services. This is so that professionals ensure that they make the appropriate specific adjustments so disabled children and young people understand any information or choices provided to them and what the implications are for their lives.

The lived experiences of people within the working group showed that informed consent from parents/carers is vital when changes are made to their child’s medical care but that there was a lack of understanding for some children and young people about their own impairment/condition or the concept of disability itself.

Welsh Government should develop an action plan to address the shortcomings in transition from children’s services to adult services for both health and social care.

This action plan should aim to ensure seamless transfer from services or alternatively to consider where it is appropriate to not transition to adult services automatically based on biological age and should consider a consistent approach across Wales.

This action plan should be carried out with the direct involvement of disabled adults and children and young people.

The evidence from the working group included:

• Although an 18-year-old is legally an adult, it should not be assumed that adult services can meet their needs.
• The transition process often begins later or is not thought out well. It should begin long before the disabled young person moves services to allow for preparation and understanding. This communication should be tailored.
• The transition process should involve both paediatric consultants and adult consultants to hand over the disabled young person’s medical history/requirements.

Welsh Government should develop an action plan to resolve the barriers for disabled children and young people in accessing mental health services, drug and alcohol services and associated social care services.

This action plan should consider how waiting times can be reduced and how disabled children and young people can be given better access to services, both via referral process and self-referral.

The action plan should also examine the intersection of race, LGBTQ+ status, gender, religion, ableism, segregation, and bullying, seeking to understand their impacts on the mental health of disabled children and young people. This action plan should be developed through the NYTH/NEST framework to ensure a whole system and holistic approach is taken to planning and delivery. 

The evidence from the working group includes:

• There are delays and a lack of referrals to address mental health concerns in ALN children – especially since the COVID-19 pandemic.
• There are significant social repercussions of the COVID-19 pandemic on ALN children (e.g. heightened anxiety, lack of social skills with children/adults respectively) but access to services has become harder.
• CAMHS have seen a rise in depression and anxiety in ALN children post-pandemic.
• A broader scope and understanding of how ALN children display poor mental health is required.
• There is a lack of reasonable adjustments (such as BSL interpretation) within therapy/mental health care, which can exclude children and families from receiving services. This needs to be reviewed to ensure equal access to mental health support.
• In addition, there is a lack of mental health literacy. Disabled young people may not be well positioned to know what support they need.

Post-18 education

Welsh Government should place statutory requirements on universities to ensure that access to disability services at university and higher education institutions is easier and that these services are fully equipped to support disabled students including in matters such as allowances and benefits.

The lived experience from the working group showed it is very difficult for disabled students to access support when they transition to university.

Welsh Government should ensure that Universities comply with their duties under the Equality Act 2010 and the Public Sector Equality Duty, both not to discriminate, and to make all the reasonable adjustments that are required, particularly when support may be needed when asking for extensions or in meeting academic standards.

The evidence from the working group showed that reasonable adjustments are not consistent and do not currently consider the nature of the individual’s impairment, instead they try to test their abilities in generic areas that their impairment may not affect. This is not limited to academic activities and staff committees or societies should also be required to comply with these duties and in particular to make reasonable adjustments.

Welsh Government should require all Academic staff to be educated on the Social Model of Disability and the Equality Act 2010.

Compliance with these legal obligations should be included in training and professional development requirements for all education staff and should be monitored. There should be a higher severity of consequences for staff members that do not allow for legal accessibility requirements and an independent reporting system for lack of accessibility requirements.

We recommend improved access to BSL to deaf babies/children from diagnosis as well as access to free BSL classes for parents and siblings of deaf children, with opportunities to progress through BSL levels.

Deaf children need to be able to communicate with their parents as soon and as fully as possible. Much of the parent child affective bonding takes place with language. Without access to BSL for both baby/young child and parent, there is a major negative consequence to the child’s cognitive and linguistic development. Deaf children are underperforming in education due to missing out on early years formative learning, along with missing out on incidental learning. It is also important to for deaf children and young people to have role models.

Early years

Welsh Government must develop an action plan to ensure that disabled children are supported properly before they start formal education. This must include a review of the available workforce and framework for accessing support.

Evidence presented to the working group shows that it can be difficult for parents and carers to access support and specialist staff are often not available. For example, there is a shortage of specialist habilitation officers and in some Welsh Local Authorities some children and young people with a vision impairment receive no habilitation support. The RNIB Freedom of Information Report (2023) (1) found that a total of 312 pupils are currently on active habilitation caseloads with a further 43 waiting to be assessed. Two local authorities did not supply this information. The percentage of children and young people on LA VI service active caseloads accessing, or on a waiting list to access, habilitation support varies from below 9% to 48%, while waiting times for habilitation support vary from 1 week to approximately 12 months.

The lack of specialist support not only affects a child’s early years but education and adulthood too. The impact on social inclusion can also be significant. 

Children and young people’s participation work 

Schools and Children in Wales event

We recommend that transport organisations consult disabled children and young people about how travel can be improved, and transport organisations must take action to implement recommendations put forward by disabled children and young people. 

Pupils also spent time talking about how to improve access for people who use wheelchairs. The main issues reported by disabled children and young people in schools were that there were not enough facilities with appropriate support and transport.

We recommend that Welsh Government work with local authorities to undertake a wider consultation with disabled children and young people, on how to improve facilities and activities in local communities for children in Wales.

Disabled children and young people would like more places to go, where there are people who know them and can support them. They would socialise with their friends in fun places, like the cinema, park and garden spaces for example.

We recommend that Welsh Government works with retailers to improve accessible spaces in shopping areas, such as ensuring shop doors are accessible with automatic doors, which are wide enough to accommodate a range of wheelchairs and equipment and consideration is given to the impact of harsh fluorescent lighting and loud music.

Children and young people believed that we are currently “building a world without disabled people in mind”. Disabled people are being designed out of services and feel excluded from community life as they cannot go where they choose or participate fully. This can impact a person’s sense of belonging.

Promotion of diversity and social inclusion is imperative to a world where disabled people have equal opportunities to participate in sport, get a haircut, eat at a restaurant, and go shopping without barriers in place.

Enabling people in this way would result in increased feelings of security, confidence and comfort and will certainly ensure a more “able life”. Solving barriers for neurodivergent children and young people and improving access for disabled children, i.e., reducing the amount of loud, unnecessary tannoy announcements and playing calming music within shops, where possible.

We recommend that Welsh Government ensures there is ongoing and considered engagement with disabled children and young people throughout the various stages of service design and policymaking.

As part of this event, children and young people suggested that desired outcomes for disabled people were unlikely as they suspected that policymakers within Government are not disabled themselves. Lack of representation amongst Officials could result in failure to understand the needs of stakeholders for whom the policy serves. A proposed solution would be to understand the benefits of co-production and the importance of listening to lived experiences which are sure to add depth to policies and processes.

We recommend that each school has a dedicated Disability/Young Carers Champion within its Youth Engagement and Participation Service.

Children and young people want to have a disability champion within the school setting – an authoritative figure they can trust to remove barriers for them and be the communication link between the student and the teacher. For example, the disability champion could make recommendations to teachers about which reasonable adjustments should be put in place for the student based on the feedback received in confidence. I.e., more breaks, early dismissal from class. This disability champion would also be the contact person to go to when the student needs advice/someone to confide in.

Children also wanted a champion who could provide support and advice for young carers who may not be disabled themselves, but care for a disabled parent/carer at home.

We recommend that additional support is given to children and young people who have missed out on their right to education as a result of poor health.

Children and young people felt strongly that students who have missed out on their education due to poor mental/physical health conditions should be given the opportunity to undertake this learning and complete the curriculum when they are deemed well enough to return. All too often, children miss out on large portions of their education due to being hospitalised or incapacitated and are then expected to go onto further education or secure jobs without completing their education and obtaining qualifications.

This may be already allowed for in the system and offered as part of further education settings, however, the young people felt more could be done to ensure that no young person enters adulthood without receiving their right to education.

We recommend that Welsh Government call for National Institute for Health and Care Excellence (NICE) committees to include disabled people in the decisions around allocation of resources and the direction in which those resources are spent in relation to adaptions and equipment.

Further research to be prioritised with the view to use pioneering modern technology to remove barriers for disabled people and understand how this can improve accessibility among disabled people.

We recommend more accessible places within venues for sport, music and theatre productions.

Children and young people shared that they enjoy going along to concerts and sport events but are disappointed that accessible seats tend to be limited and in undesirable sections of the venue with a limited view/further away.

It was also recommended that these tickets and any costs associated with disabled spectators and audience members are fairly priced and affordable for all.

Welsh Government to consider a detailed strategy to address the shortage of accessible homes.

Research from the Bevan Foundation has shown Wales is facing a housing shortage. According to the foundation:

There is a shortage of properties that people in Wales can purchase or rent at affordable prices…with some forced to move into a property that is unaffordable, risking financial hardship, some forced into poor quality accommodation, whilst others are forced to seek assistance from local authority homelessness services. These challenges are especially pronounced for low-income households living in the private rental sector.

(Bevan Foundation)

A report by the Equality and Human Rights Commission, Housing Disabled People: Wales Hidden Housing Crisis sets out, ‘there is a chronic shortage of accessible homes…there remains a severe shortage of accessible and wheelchair-accessible housing.’

As identified in the Welsh Government's White Paper, there is an undersupply of accessible homes across Wales. The group heard that this shortage of accessible homes is holding significant consequences, including reports of disabled people having extended hospital stays, sofa surfing with family members and even of a young person living in accommodation for elderly people.

As the Welsh Government moves forward with existing commitments to address gaps in the supply of social housing, it will be imperative that this work includes a clear strategy.

Undertake research around unmet demand of accessible housing

Research is required to fully understand the unmet demand for accessible housing, including the current amount of accessible housing. This research must result in granular data regarding the different types of accessible housing that is required compared to what is presently available on a county-by-county basis. It must also include information regarding the extent that disabled people are living in inappropriate housing, including care homes.

Disseminate results of research for unmet demand of accessible housing

All bodies working within the housing sector, both private and social/public, must be made aware of these research findings and the consequences for disabled people when they are not adequately housed.

Acknowledgment of unmet demand for accessible housing

There must be a clear acceptance of the need to improve in the housing sector both in terms of policy and delivery of accessible homes to disabled people. There must be a renewed focus to improve housing for disabled people, taking the lived experience of this group into account.

Improvement of government policy co-ordination

There are many ongoing pieces of work regarding accessible homes. A holistic, whole system approach is required and improved joint working practices. This means relevant policy leads working across Welsh Government to work co-productively with disabled people impacted by housing policy. 

All of the recommendations above lead us to:

Develop a disabled person focussed housing strategy

Welsh Government housing policy leads are the process of formalising arrangements to capture views from people with protected characteristics, and there is a commitment to preparing a housing strategy, which will reflect intersectionality. However, Welsh Government must continue with this commitment to work collaboratively with disabled people, including disabled people from Gyspy, Roma, Traveller communities and disabled people seeking asylum in all areas of the housing sector. This collaboration must result in a concrete detailed strategy, which will ensure that all the housing needs of all disabled people are met locally.

Strengthened governance and prioritisation for disabled housing initiatives

Despite previous policy initiatives that indicate good intentions, they struggle when faced by other competing pressures. Therefore, as well as being developed collaboratively, any new accessible housing strategy must be supported by firm targets and governance.

Ensure adherence to existing equality and building regulations

Adhering to the Equality Act

All bodies working within the housing sector are required to adhere to the Equality Act. Welsh Government must communicate with the EHRC the need to co-create materials that focus on housing and the sectors requirements to deliver reasonable adjustments. This must be properly resourced.

Private landlords’ compliance with the Equality Act

The Equality Act is very clear that private landlords cannot oppose reasonable adjustments. It is also illegal for them to discriminate against potential disabled renters because they may need adjustments. This information must be disseminated to all private landlords and consider including in the ‘Rent Smart Wales’ registration requirements and test.

Adherence to Welsh Government policy and to building standards

As the planning authority, Local Authorities are in a powerful position to drive accessibility across all areas of Welsh life, however, we have heard instances that Local Authorities do not always fully comply to the regulations that should guide their decisions. For the bare minimum all local authorities must adhere to ‘Approved Document M: access to and use of buildings’ of Building Regulations in Wales.

Cohesive approach to developing housing related equality plans

When developing equality plans, effective collaboration between local authorities, housing associations and Welsh Government is required when considering actions to do with housing. 

Conference to assist bodies adhere to equality legislation and accessible housing

Working with the EHRC, Welsh Government should hold a sector wide conference with the purpose of ensuring that the sector fully understands its legal duties in relation to the housing of disabled people, including disabled people from Gyspy, Roma, Traveller communities and disabled people seeking asylum.

Improve and strengthen Welsh Housing Standards 

Keep the practices and Housing policies of the Welsh Government under review and where appropriate, put forward proposals to strengthen guidance and standards. 

The Welsh Housing Quality Standard 2023

The Welsh Housing Quality Standard 2023 applies to older and social homes and sets out that all social housing must be maintained and kept in good condition. While a recent review has been undertaken, a further review of these standards is needed to ensure they are appropriate for disabled people. These Standards also need to be supported by an effective and vigorous sanction system for when rights are being infringed.

The Welsh Development Quality Requirements 2021

The Welsh Development Quality Requirements 2021 Creating Beautiful Homes and Places sets out the minimum functional quality standards for new and rehabilitated general needs affordable homes. The requirements do not meet the needs of disabled people and should be reviewed as a matter of priority to ensure the requirements are vocal on how homes must be suitable for people with diverse access requirements.

Ensure the voice of disabled people regarding their needs is reflected in the Welsh Government’s development of the White Paper on Adequate Housing and Fair Rents

Recognising the limited evidence, regarding the needs of disabled people in terms of housing adequacy, submitted to the Welsh Government Green Paper (A Call for Evidence on securing a path towards Adequate Housing, including Fair Rents and Affordability) there needs to be close engagement with representative organisations on the next steps. The development of the White Paper should reflect the needs of disabled people and should also reflect the much more progressive accessible housing Bill proposed by Tai Pawb. 

Improved accessibility standards for new builds

There is a clear need for better standards within building regulations to ensure every new build is accessible, or easily modified. This relates to private and public sector in Wales. The Welsh Government’s national planning policy, set out in Planning Policy Wales, requires local planning authorities to make provision through their development plans for the full range of house types to address the identified needs of their communities, including the needs of disabled people. This should include ‘barrier free’ housing, for example built to ‘Lifetime Homes’ standards, to enable people to live independently and safely in their homes for longer.

The need for alignment of housing registers for accessible housing

Create national principles for housing registers

We understand that local authority housing registers differ between their localities. We propose streamlining the creation of national housing principles in which all local registers must adhere to. This should include a property-by-property breakdown of the exact nature of the level/type of accessibility of council and housing association properties that have undergone adaption. When developing the national principles all data protection/safeguarding arrangements will need to be considered in terms of who can access the register.

Monitor the use of adapted properties

Monitor the usage of adapted properties including the number/location of properties that have adaptations removed

Reform the housing application process

Create transparency in housing application process

There needs to be greater transparency and a consistency of approach, across all providers regarding the housing application process. Ideally, all application processes should be the same across all relevant housing bodies in Wales.

Better advertising of housing accessible homes

There needs to be better consistency in how housing associations/local authorities advertise accessible homes and how these homes are described.

Create a person-centred assessment process for homelessness and social housing

Person centred holistic approach to assessments must be put in place as there is no need for a diagnosis before receiving support. People have told us they have had to wait for a diagnosis before being considered for housing/adaptations. 

Accessible information and communication

All housing related information must be provided in accessible formats and meet the audience’s needs

This includes all promotional, contractual, and general information, including what is provided on tenant notice boards. For this to be successful, housing providers must be fully aware of the access needs of all their tenants and act proactively. Where information is for the general public, there must be simple and transparent processes through which accessible formats can be obtained.

Each local authority to create a single point of contact for housing adaptions and the supply of equipment

All local authorities must have a clear and accessible single point of contact for housing adaptions and the supply of equipment. This includes when there are multiple agencies and contractors working on the same project. The quality of adaptions should also be monitored.

Providing information to those who are digitally excluded

Housing bodies must develop strategies regarding how they will disseminate information to those who are digitally excluded.

Information, communication, and intersectionality

When creating and disseminating information, it is obvious that all the necessary accessibility methods must be considered, but what is often ignored are the access requirements of people from different communities. An intersectional approach is required to help ensure access for all. 

Improve therapy service integration

There needs to be consistency across housing providers in how someone accesses occupational therapy services, including private occupational therapy. This requires systems in place to make this work as efficiently and effectively as possible. This information must proactively be provided to tenants using their preferred communication methods.

Housing related training

Embedding the Social Model of Disability in professional practice training

All staff across the housing sector should receive bespoke housing focused social model of disability training. This training should also include Disability History, including disabled people from Gyspy, Roma, Traveller communities and people seeking asylum. As well as for people working in the housing sector, this training should be offered to planners, architects, sector academics, and representatives of large building companies.

Accessibility standards and adaptive technology training

All appropriate staff across the housing sector should receive training regarding accessibility standards and adaptive technology.

Training for elected councillors involved in planning

We have heard councillors involved in the planning may not have received training, or have real-life experience in this landscape, and so mainly rely on the advice of their planning officers. This is problematic as there is in effect, only a very marginal check and balance regarding public interest and their council official’s adherence to the ‘Approved Document M: access to and use of buildings’ of Building Regulations in Wales. Local authority planning committees must include councillors who are suitably trained to recognise when their authority is in breach of the regulations and have the confidence to voice their concerns. Although training is provided it must ensure it includes building regs, social model and building standards. 

Training on disability rights and the impact of impairments

If someone presents as a wheelchair user or has difficulty in walking or using facilities such as baths, there is already much knowledge regarding the affects and how to mitigate when seeking suitable accommodation. However, there are some impairment groups where more staff training is required. This includes the access/accommodation requirements for those who are neurodivergent, deaf/blind people, those who have dementia and BSL users for example. 

All the training listed above must be co-designed with disabled people.

Developing academic curriculum

Higher education/postgraduate

Consider a partnership with the Welsh School of Architecture with the aim of embedding Social Model concepts into academic courses.

Further Education (FE) based building and construction courses

Working with the FE sector and the qualification bodies for apprenticeships, embed Social Model concepts into curriculum alongside accessibility standards and the practical use of adaptive technologies. This must be a requirement regardless of the age of the apprentice.

Accessible refuges

Create the required number of accessible refuges

Welsh Government must ensure that there is always adequate accessible accommodation for disabled people seeking refuge from violence, and that this provision is accessible for them, their carers, and their children. To achieve this there must be a need/provision gap analysis on a county-by-county basis with provision being created to match local needs. Attention must be given to disabled people from Gypsy, Roma, Traveller communities and disabled people seeking asylum who are subject to domestic abuse, and how women isolated on sites are able to know about and access safe refuge space.

Reform hospital discharge procedures

Disabled people of any age should not have to reside in hospital for prolonged periods of time without clinical need because of lack of accessible housing.

Disabled people should not be forced to give up their independence -being moved to a care home because of the lack of support to maintain independence, affordable and accessible housing.

Disabled people should not be forced to move out of county because of the lack of local, affordable, and accessible housing.

Disabled people: Gypsy Roma, Traveller

There is a duty on local authorities under Section 103 of the Housing Wales (2014) Act to identify the housing need of Gypsy Roma, Traveller communities and to report on that need in the form of Gypsy Traveller Accommodation Assessments (GTAAs). The GTAAs require improving and must consider the needs of disabled people who are from Gypsy Roma, Traveller communities. 

Whilst these are often around caravan and site bases, they can also apply to rented accommodation.

Disabled people: seeking asylum

We recommend that Welsh Government ensures contracted providers undertake training on the Social Model of Disability.

Organisations providing support to disabled people who are seeking asylum must be trained in the social model of disability and demonstrate how they are supporting disabled people to access rights and entitlements. Training should be provided by people with lived experience.

We recommend that Welsh Government makes representations to the UK Government to seek better data collection and reporting relating to disabled asylum seekers to ensure care and support needs are adequately addressed.

The UK Government is responsible for supporting asylum seekers accommodated in Wales. However, there must be improved data sharing to ensure any care and support needs can be met by either UK Government or local services, as required.

We recommend that Welsh Government makes representations to the UK Government to seek suitable housing and living support for disabled asylum seekers accommodated in Wales.

The UK Government is responsible for providing asylum accommodation in Wales. However, there should be assurances that housing is appropriate for the needs of any disabled people living in this accommodation in Wales.

Improve the support for young people and families

Young people and care

We believe that all disabled people of any age should be able to live in their own home. We have heard instances of placing young disabled people in care homes as a legitimate option when their accessibility needs are not being met. This must stop, it’s not a legitimate option, it’s an expedient one with often very negative outcomes for the disabled person.

Create working from home accommodation standard

When developing housing standards and implementing housing allocation, consideration must be given regarding the needs of people who work from home.

Access to justice for disabled people who are victims and offenders of crime

Issue: Statutory agencies need to understand about rights and duties to prevent disabled people from being discriminated against.

Recommendation(s):

• Welsh Government to incorporate of the UNCRDP into Welsh law. The Human Rights Advisory Group and Legislative Options Group has begun work to take this forward.

Issue: A lack of advice and information, in accessible formats such as BSL and easy read for disabled people.

Recommendations:

• Increase the funding and amount of legal aid services in Wales. Legal aid is ‘reserved’ therefore Welsh Government is asked to communicate this need to the UK Government.
• Invest in public legal education in Wales to ensure education includes information on access and inclusion.
• Increase the provision of adequate advocacy support for disabled people who are victims/ perpetrators of crime in Wales. Advocates must be qualified and experienced to provide the right level of advice and support. This may be legal advocacy, with trained Intralingual qualified interpreters and BSL/English/Welsh interpreters where required.
• Increase the provision of health and wellbeing support for disabled people in custody in Wales.
• Improve accessibility and availability of Citizens Advice Bureaus in Wales.

Issue: Disabled people not knowing how to complain and fearing the consequences of complaining about people they require support from.

Recommendations:

• Welsh Government to increase access to Advocacy support for disabled people in Wales.
• Welsh Government to ensure appropriate advice and information is made available for disabled people in Wales, and in accessible communication formats.

Issue: No Law Centre in Wales to advise disabled people.

Recommendation:

• Welsh Government to consider establishing a Law Centre for Wales, which supports disabled people in Wales.

Violence, Sexual Abuse and Domestic violence

Issue: Lack of voices of disabled people as part of the National Strategy (VAWDASV) who have been a victim of crime and abuse.

Recommendation:

• There has been a lack of representation of disabled people in the Survivor Voice Scrutiny and Involvement Panel. The panel has acknowledged this and are actively looking to recruit more disabled people with lived experience of Violence Against Women Domestic Abuse and Sexual Violence (VAWDASV).
• The Welsh Government to commit to ensuring an intersectional approach to policy development and delivery through the VAWDASV Blueprint. This means considering the needs of all with protected characteristics, including disabled people as victims and survivors of VAWDASV, and their communication requirements. 

Issue: Better availability of support services for disabled survivors of abuse.

Recommendations:

• Welsh Government to review provision of support services for disabled survivors of abuse in Wales through the VAWDASV whole-systems approach to sustainable workstream within the context of the National Training Framework. Welsh Government to ensure support services in Wales are trained in the Social Model of Disability.

Issue: Internalised Ableism/Dependence on partners, leaving victims feeling they have no choice but to tolerate abuse.

Recommendation:

• Welsh Government should ensure that proposed awareness raising campaigns on ableism are inclusive of the needs of disabled victims of VAWDASV, sharing information about the Social Model of Disability.

Issue: Data of disabled people who are a victim of crime lost in the tiers of intersectionality.

Recommendation:

• Welsh Government to undertake an analysis of the recording of the experiences of disabled people when crimes in Wales are reported. The report should be made available in accessible versions.

Issues:

• Inclusion of disabled male victims of abuse and a perceived lack of available support.
• Marked rise in reported cases of male victims as they get older.

Recommendation:

• Welsh Government to review current provision of support services for disabled men in Wales who are a victim of abuse. Extend or create support services where deficits are found. 

Issue: Domestic violence being treated as a safeguarding issue rather than a criminal one for disabled people. 

Recommendations: 

• Welsh Government to seek cooperation, where possible, with partner agencies such as police, tribunals, and the judicial system ensuring the provision of good quality training on the UNCRDP and the Social Model of Disability.
• Welsh Government to make representations to non-devolved agencies to consider gaps in knowledge through training and awareness raising.
• Welsh Government to coordinate activities with partner agencies in policing on educating the police in Wales to recognise that domestic violence against disabled people is a criminal offence, not a safeguarding issue.

Hate and mate crime

Issue: Hate crime wording and/or definitions used in Wales are not often clear and underplays what hate crime is.

Recommendation:

• Welsh Government to make representations to partner agencies to provide a new clear and simple definition of hate crime in Wales.

Issue: Disabled people not recognising when they are a victim of hate crime.

Recommendation:

• Welsh Government to raise awareness with disabled people of what constitutes hate crime, highlighting the importance of reporting it, and the support available.

Issue: Difficulties in reporting a hate crime.

Recommendation:

• The Wales Hate Support Centre to review its reporting systems in Wales to see if it can be made more accessible for disabled people in Wales.

Issue: Difficulties for people with learning disabilities recognising when they are a victim of mate crime.

Recommendations: 

• Welsh Government, as part of a national campaign on ableism to educate and empower people with learning disabilities about hate crime.
• Welsh Government to coordinate activities with partner agencies on educating the police in Wales about mate crime and the vulnerability of people with learning disabilities.

Issue: Public ignorance towards disability and ableist attitudes.

Recommendations:

• Welsh Government to provide education on the social model of disability and ableism for the general public.
• Welsh Government to work with Law Schools and universities providing courses in Law (in Wales) to ensure future legal professionals understand the Social Model of Disability.

The Criminal Justice System

Issue: Lack of awareness of specific needs of disabled people. Disabled people have other characteristics too such as age, race etc.

Recommendations:

• Welsh Government to make representations to partner agencies to provide disability awareness training for staff working in the criminal justice system, in Wales.
• Welsh Government to make representations to partner agencies to provide Social Model of Disability training for staff working in the criminal justice system, including tribunals in Wales.
• Welsh Government to make representations to partner agencies to provide diversity training for staff working in the criminal justice system, in Wales.

Issue: Lack of robust data on crime statistics on disabled people. 

Recommendation:

• Welsh Government to make representations to / improve methods of data collection so that the experiences of disabled people are appropriately recognised in crime statistics.

Issue: Lack of Data on prison population who are disabled, including those with acquired impairments due to ageing.

Recommendation:

• Welsh Government to make representations to the UK Government to consider improved data collection about the disabled population within Welsh prisons. This should include data relating to disabled women.

Issue: 60% of the prison population have problems with communication in some form.

Recommendation:

• Welsh Government to ensure prisoners are assessed appropriately and early in order to give them equal access to education in Wales. The assessment would be restricted to communication for the purposes of education.

Issue: Lack of disability equality training in the prison service.

Recommendation:

• Welsh Government to make representations to partner agencies to provide diversity and equality training for staff working in prisons in Wales as an ongoing essential part of continued professional development.

Issue: Lack of awareness of what education is available within the prison service.

Recommendation:

• Welsh Government to make representations to partner agencies to consider how prison staff in Wales are made aware of what education and training is on offer.

The Judicial System 

Issues: Lack of understanding/ application of the Equal Treatment Bench Book (ETBB).

The Equal Treatment Bench Book is a guidance document on equality and diversity for judges, magistrates, and other judicial office holders, published by the Judicial College. It is used by the judiciary of England and Wales. Courts should pay regard to the ETBB to ensure a fair trial (which is a requirement of the ECHR).

Many rights that protect disabled people are not understood and therefore not implemented by the judicial system.

Recommendations:

• Welsh Government to consider their powers in regard to making representations to partner agencies regarding the application of the ETBB by judges in court proceedings, including awareness and application of both article 13 ‘Access to Justice’ and article 43 ‘Consent to be bound’ which gives disabled people the right to be informed about any change within their community.
• Welsh Government to incorporate the United Nations Convention on the Rights of Disabled People into Welsh law.
• Welsh Government to be aware of the report of the International Committee of Rights of Disabled People and to align this with the recommendations of this sub-group.
• Welsh Government to make representations to partner agencies on the training of judges and solicitors working in Wales to understand the unequal benchmark that currently exists.

Issue: Lack of reasonable adjustments within court proceedings. 

Recommendation:

• Welsh Government to make representation to the Equality and Human Rights Commission to review how well reasonable adjustments are made in court proceedings in Wales, such as access to qualified and experienced BSL interpreters and to make recommendations for improvement.

Issue: UK statutes are interpreted in a different way to that of European and World statutes. This was affected by the removal of our World Rights as a result of Brexit. 

Recommendation:

• Welsh Government to address this partially in Wales through an act of the Senedd. This would allow disabled people to refer to the convention. This would allow disabled people to seek justice in the court that complies with the UN convention on the rights of disabled people.

Legislation and policy

Issue: No adequate representation of the needs of disabled people within the Welsh Government. 

Recommendations:

• Welsh Government to create a disability commissioner for Wales or relevant agency that can ensure policy is implemented.
• The Disability Commissioner/ relevant agency to drive the agenda of access to justice within Welsh Government.

Issue: Criminal justice not being lined up with Welsh Government policy for disabled people.

Recommendations:

• Welsh Government to create a disabled people’s commissioner for Wales or relevant agency that can ensure policy is implemented.
• The disabled people’s commissioner or relevant agency to drive the agenda of access to justice within Welsh Government.

Issue: Criminal justice not being lined up with Welsh Government policy for disabled people.

Recommendations:

• Welsh Government to review the Social Services and Wellbeing (Wales) Act and how well it links to criminal justice.
• Welsh Government to set up a working group to contribute to the above.
• Welsh Government to work with law influencers in Wales on the above.

Issue: Some disabled people may need additional support to access social care to which they are entitled to under the Social Services and Wellbeing (Wales) Act 2014. There is a lack of access to legal advice, there are few solicitors able to provide the type of advice needed in Wales and the lack of Legal Aid is also a problem. There is also a lack of access to specialist advocacy services/support to enable disabled people to access their rights.

Recommendation:

• Increase the provision of advocacy support and legal advice to disabled people to ensure they can access the social care to which they are entitled under the Social Services and Wellbeing (Wales) Act 2014. Support provided must be fully accessible.

Issue: Trained staff are needed to support people at court. Barristers are not trained in understanding disability and access needs. There is a set way of asking questions and doing things. Answers in court are expected to be neurotypical, which is problematic.

Recommendations:

• Welsh Government to ensure court / tribunal staff working in Wales have access to information on the Social Model of Disability.
• Welsh Government to support the ‘Welsh Bar’ with access to Social Model of Disability training. This should be provided and run by disabled people.

Issue: There is a lack of advocacy and legal support available to support disabled people in Wales. This problem is multifaceted. One way to mitigate the harms caused by the lack of access to rights for disabled people may be through the use of emerging technology such as artificial intelligence (AI). 

Recommendation:

• Welsh Government to explore how the use of accessible technology such as artificial intelligence (AI) may support disabled people with access to their legal and other rights in Wales.

Issue: Many households in Wales are losing out on additional financial income because they are not claiming entitlements and other support they are eligible for. Some disabled people are missing out because systems and current support is inaccessible to them. Promotion and awareness raising is only part of the solution in increasing take-up of benefits and some disabled people will require support in making the claim itself. 

Recommendation:

• Welsh Government to make representation to the UK Government to fund an impartial advice and support service, similar to the service that supports people to claim Universal Credit, in order for disabled people to access other benefits that are underclaimed, such as Pension Credit. The service must use accessible communication formats, provide face to face support where required, and meet any other accessibility requirements of disabled people, in Wales.

Issue: Previous advice not being acted upon/ potential future duplication of work already done. 

Recommendations:

• Welsh Government to review and update the 2013 ‘Access to Justice’ document.
• Welsh Government to review recommendations put forward by Disability Wales and Welsh Women’s Aid to remove barriers for women accessing support for justice.
• Welsh Government to review Barnardo’s 2011 report of abuse of girls with learning disabilities.
• Welsh Government to ensure recommendations made by the Independent Inquiry into Child Sexual Abuse (IICSA), such as those relating to historical abuse, are acted on.
• Welsh Government to consider any gaps in the IICSA report in regard to disabled people and to undertake analysis and lessons learned.

Issue: Gaps in implementation.

Recommendations:

• Welsh Government to hold further targeted meetings on key issues that cause a barrier to accessing justice with a view to closing systemic barriers to accessing justice in Wales.
• Welsh Government to set up working groups to interview major people in law, such as judges and directors of companies and make recommendations based on these discussions.
• Welsh Government to adopt the recommendations laid out in the ‘International Committee of Rights of People with Disabilities on access to justice’ report.

Issue: Lack of understanding/ implementation of the Equality Act.

Recommendation:

• Welsh Government to review the effectiveness of the Equality Act within civil justice in Wales.

Issue: A lack of cohesion between organisations who have worked on issues of discrimination for disabled people within the justice system.

Recommendation:

• Welsh Government to create a central organisation/ agency in Wales who can collate, monitor, and drive the agenda to remove the barriers for disabled people within the justice system in Wales.

We recommend Welsh Government hold a Disability Rights campaign to raise awareness of the importance of inclusion and access. This should also include recognition of where Welsh Language intersects with disability and the additional challenges of intersectionality of impairments.

Group members discussed the importance of understanding that there is not only intersectionality of protected characteristics, but intersectionality of impairments too e.g., DeafBlind. The range of access and inclusion needed among disabled adults and children must be better understood and accommodated. A Disability Rights campaign will support service providers of sport and recreation, tourism, and culture to ensure Wales is an inclusive and accessible nation for all.

We recommend sufficient numbers of specialist accessibility officers be situated in all local authorities in Wales.

Teams of specialist accessibility officers, with appropriate lived and professional experience, should be available in each local authority, in sufficient numbers, to reflect the views of the community and be a dedicated point of contact for disabled people in the locality. The role of the accessibility officers must focus on improving engagement between the local authority and disabled people, and not just used for technical advice such as housing accessibility and transport.

The group heard about instances where local authorities had been charging for assistance with completing Personal Independence Payments (PIP) application forms. Accessibility officers should provide support and advocacy for disabled people, including assistance with accessing financial entitlements and completing forms where support is required.

Accessibility officers could also support public bodies with Access Audits to understand how accessible their website or app is and what they need to fix to meet public sector accessibility regulations. Members of the group called for Access Audits to be updated to reflect the needs of service users with non-visible impairments.

Local authorities often lack expertise in access and bring in contracted consultants - this is costly and often disregards the vital element of continuous engagement with disabled people.

In tandem with Recommendation 2, we recommend that each local authority establishes a Lived Experience Advisory Group.

Welsh Government has Ministerial Advisory Groups on neurodiversity and learning disability, which have proven to be effective. Group members felt that a similar group focused on lived experience of disability would be beneficial at local authority level and should be led by the proposed specialist accessibility officers.

We recommend Welsh Government support organisations and public bodies to establish Accessibility Panels for disabled people to co-design and improve services and events across Wales.

Group members shared positive feedback for the Transport for Wales Accessibility Panel, which has been invaluable in helping to deliver accessible travel across Wales. 

The group discussed the importance of accessible services and events for those not from the area and travelling across or into Wales e.g., service stations or natural break areas.

Careful consideration will need to be paid when setting up these proposed Accessibility Panels and agreeing priorities. Organisations and public bodies should involve disabled people with lived experience during design and delivery of services.

The Welsh Government should convene a group of disabled people with lived experience of accessing Welsh medium services, and Welsh learning services to inform and advise the government on solutions moving forward.

We recommend Welsh Government promote accessible neighbourhoods throughout Wales. 

Accessible infrastructure is imperative to ensuring disabled people can participate in society on an equal basis to everyone else. 

Sustrans Cymru strives for cities or towns in Wales that “connect us to each other and what we need” in their Disabled Citizen’s Inquiry. The organisation believes the best way to do this is to ensure that it is easy for people to meet most of their everyday needs by a short, convenient, and pleasant journey. 

Accessible neighbourhoods would ensure that Welsh towns and cities are self-sufficient, reducing the need for cars and transport and enabling disabled people to live more independently in their local community.

We recommend that Welsh Government increase efforts to remove barriers in society that prevent disabled adults and children from participating in wellbeing enhancing activities and wellbeing support.

Group members expressed an interest in film and the arts but are often unclear on the accessibility of the venue (including changing places or toilets) or if the film/show itself is accessible. Group members campaigned for clearer communication regarding a venue’s accessibility and increased volume of accessible shows (BSL/captioner/audio description/autism friendly). There is currently a limited number of showings that disabled people can attend with friends/family, and these may not be appropriate times of day i.e. school or work hours. Group members recognised the positive impacts of Hynt; a National Access Scheme in with a network of theatres and arts centres across Wales who ensure that there is a consistent offer available for members and visitors with an impairment or specific access requirements, and their Carers or Personal Assistants.

Venues, buildings, and historical sites should consider accessibility and offer a range of communication methods for disabled adults and children to access. E.g. Museums to offer written information in Easy Read, audio and use plain language, where possible.

Wellbeing support such as counselling can often be inaccessible to people with different communication needs. It is important to offer interpreters or alternative methods of communication to aid people through difficult and challenging times.

Unfortunately, wellbeing support is often withdrawn due to lack of funding, resourcing, and capacity within the third sector. Group members urge Welsh Government to continue to fund charities who provide these vital services to promote enhanced wellbeing among Welsh communities and support disabled volunteers.

We recommend that Welsh Government works with Welsh accommodation businesses to improve the quality of information on their accessible provision (with the aim of making this information easier to find for disabled visitors).

Disabled members of the group shared the importance of accessible hotels and alternative accommodations in Wales. Stakeholders have shared their lived experience of trying to find an accessible hotel in Cardiff. One member noted that there is insufficient accommodation in our capital city and with accessible tracking hoists available.

Accessible infrastructure is imperative to ensuring disabled people can participate in society on an equal basis to everyone else.

Welsh Government should engage with accommodation providers to ensure that accessibility information is kept up to date and straightforward for members of the public to access. Monitoring this information might be possible at grading assessments.

We recommend Welsh Government work with public bodies and the third sector to improve the promotion, frequency and delivery of community-based activities which enhance wellbeing.

Engaging in activities which enhance wellbeing could help disabled people alleviate feelings of loneliness and isolation by making friendships and connecting with their community. Recognising that many disabled people may not have disposable income to spend on improving their wellbeing, group members suggested introducing subsidised memberships for gyms, libraries, clubs etc. 

Group members felt that accessible wellbeing activities are not well-advertised, many disabled people may not be aware of what is available to them. Members called for increased promotion of existing accessible activities, events, and services across Wales. Some examples include:

• Deaf people are often unaware if BSL interpreters will be at comedy shows until it is too late to book tickets.
• People are often unaware of accessible sport/activity and recreation in their local area or if organisers are willing to make adaptations to be inclusive.
• Insufficient information in healthcare settings on accessible social prescribing activities to aid mental wellbeing. i.e. nature paths.
• Suitable volunteering opportunities for a range of impairments and medical conditions.

We recommend the workforces in sport and recreation, culture, heritage, and tourism are offered further training on the Social Model of Disability and should embed the model into projects to ensure activities and attractions are accessible for disabled adults and children to enjoy.

The Welsh Government has an important role to ensure accessibility is considered across all projects. An understanding and appreciation for Welsh culture and history is incredibly important for the citizens of Wales and for visitors. 

Social Model of Disability training should be provided to the culture and tourism workforce, including those from external bodies and volunteers, to signify and improve the importance of inclusion for all. 

Where access to historical sites is not possible due to physical practicalities, colleagues working in the area should continue to consider alternative and creative ways in which to share our rich cultural heritage. 

Social Model of Disability training should also be offered to the sport and recreation workforce to ensure that colleagues provide support and opportunities for disabled people and athletes in a sustainable, independent way.

Application of the Social Model of Disability should also be considered in grant applications for sport, recreation, culture, and tourism projects across Wales. 

There is a need to address the skills gaps which exist within Welsh and English medium childcare and play providers. We recommend Welsh Government work with providers to ensure there are sufficient numbers of fully accessible breakfast clubs, after school clubs, holiday clubs available at schools, and other wrap-around type childcare services, which offer appropriately skilled staff to support disabled children. 

Stakeholders discussed the lack of accessible pre and post school services for children. Disabled children should have the same opportunities as their peers to attend good quality childcare provision, which is properly equipped, and supported with trained staff to ensure full participation of disabled children. 

Group members put forward the need for accessible play opportunities to ensure that children are not denied their right to play and learn in their locality.

Non maintained Welsh and English medium wrap-around childcare services should also be accessible to disabled children, with information available to parents, carers, and families at local authority level about inclusive and accessible childcare services.

We recommend the Welsh Government works to increase Welsh-medium education provision for disabled children, ensuring there is sufficient inclusive and accessible Welsh-medium education provision, supported by suitable skills and facilities which are available to families in their locality.

We welcome the Welsh Government’s expansionist and inclusive vision for the Welsh language. Welsh is a language that belongs to us all and can unite people from different backgrounds. We recognise the importance of engaging with disabled people to learn from their experiences and develop solutions that address the barriers they face in accessing the Welsh language, its culture, and spaces.

Technology should be made available in Welsh for people with specific accessibility needs. The Welsh Government should expand their investment into Welsh language assistive software and bilingual speech recognition in particular.

When referring to the Welsh language, we often refer to Welsh medium culture, events and spaces. With this in mind, the Welsh Government should work closely with funded partners and stakeholders working to deliver Cymraeg 2050: A million Welsh speakers to broaden access to Welsh medium events and spaces.

We recommend Welsh Government support schools to offer and implement accessible sports and recreation activities including those away from school sites and after school hours, to ensure all pupils can participate in enrichment activities.

Schools must become better resourced for all children to participate in their interests. Increased neurodivergence training is needed for Wellbeing Officers in schools to identify and support different needs.

Access and inclusion for children and young people was discussed during the workshop, with reference to access to school trips and residential trips. Group members felt that many young people and adults are rarely included in activities because they are viewed as a health and safety risk or because staff are not trained and, therefore, confident in addressing students’ diverse needs. All such activities need to be available to every child in mainstream education with sufficient resources for support.

Schools should provide accessible sports and recreation, such as wheelchair basketball as standard and as part of the curriculum to allow all pupils the opportunity to participate. Often, children are disabled by schools through being excluded from many things including transport and educational trips. The reason was usually the school citing funding for staff, but this needs to be rectified urgently to stop children feeling isolated and inferior to others. The children we spoke to as part of the Children and Young People’s working group also felt that disabled children should have exactly the same opportunities as their peers.

There is a need to address the skills gaps which exist within Welsh and English medium childcare and play providers. The Welsh Government should ensure there are sufficient numbers of fully accessible breakfast clubs, after school clubs, and holiday clubs available at schools, and which offer appropriately skilled staff to support disabled children.

Non maintained Welsh and English medium wrap-around childcare services should also be accessible to disabled children, with information available to parents and families at local authority level about inclusive and accessible childcare services. 

Organisations we have worked with:

• Abergavenny Town Council
• Aberystwyth University
• Acorn
• Action for Children Hawthone Project
• Advocate
• Alabare
• All Wales Advisory Forum
• All Wales continuing care group
• All Wales Deaf Mental Health and Wellbeing group
• All Wales Forum
• All Wales Forum of Parents and Carers
• All Wales People First
• Alzheimers Cymru
• Alzheimer's Society Cymru
• Aneurin Bevan University Health Board (UHB)
• Association of Transport Coordinating Officers (ATCO) Cymru
• Autism Hidden Voices
• Autism Parents Cymru (AP Cymru)
• Bevan Foundation
• Bristol University
• British Deaf Association (BDA)
• Bron Afon Housing Association
• Bus Users UK
• CaBAC
• Cardiff Airport
• Cardiff Business School
• Cardiff Community Housing Association (CCHA)
• Cardiff Cool Deaf Youth Club
• Cardiff Council
• Cardiff Law School
• Cardiff Pedal Power
• Cardiff University
• Care and Repair Cymru
• Carers and Parents North Wales
• Ceredigion Council
• Chartered Institute of Housing Wales
• Child and Adolescent Mental Health Services (CAMHS)
• Clinks
• Community Housing Cymru (CHC)
• Community Transport Association
• Confederation of Passenger Transport (CPT) Wales
• Co-production Network
• Cornerstone
• Crisis UK
• Crown Prosecution Service (CPS)
• Cymorth Cymru
• Cymru Additional Learning Needs (ALN)
• Dad's Group Gwent
• Department for Work and Pensions (DWP)
• Dewis Centre for Independent Living
• Disability Arts Cymru
• Disability Sport Wales
• Disability Wales
• Disabled Motoring UK (DMUK)
• Diverse Cymru
• Elite Supported Employment
• Ending Youth Homelessness Cymru
• Engage to Change
• Equality and Human Rights Commission (EHRC)
• Estyn
• Ethnic Youth Support Team (EYST)
• Federation of Museums and Art Galleries of Wales
• For The Women UK
• Glamorgan Archives
• Greenfield School
• Guide Dogs Cymru
• Guide Dogs UK
• Gwent Carers Hub
• Gwent Police
• Hate Crime Partnership Project
• Healthcare Inspectorate Wales (HIW)
• Hijinx Theatre
• His Majesty's Courts and Tribunals Service (HMCTS) Wales
• Law Society
• Learning Disability Wales
• Leonard Cheshire
• Living Streets
• Llamau Cymru
• MenCap Cymru
• Mirus
• Museum Wales
• National Health Service (NHS) Wales
• NHS Wales Confederation
• North Wales Betsi Cadwaladr University Health Board (BCUHB)
• North Wales Police National Police Autism Association (NPAA)
• Office of the Children's Commissioner for Wales
• Office of the Future Generations Commissioner for Wales
• Office of the Older People's Commissioner for Wales
• Ombudsman Wales
• Parents Federation
• Parents in Wales (PIWS) North Wales
• Parents Voices in Wales
• Pembrokeshire Coast National Park
• Play Wales
• Powys Council
• Prison Advice and Care Trust (PACT)
• Pro Bono Committee for Wales
• Rent Smart Wales
• Royal College of Occupational Therapy
• Royal College of Paediatrics and Child Health
• Royal National Institute of Blind People (RNIB)
• Royal National Institute of Blind People (RNIB) Cymru
• Sense Cymru
• Shelter Cymru
• Sign School
• Sinclair Law
• Social Care Wales
• South Wales Police
• Sparkle
• Sport Wales
• St Cyres School
• STAND North Wales
• Stori Cymru
• Stroke Association
• Sustrans
• Swansea Parent Carer Forum
• Swansea University
• Taf Torfaen
• Tai Pawb
• TFW Active Travel Advisory Forum
• The Autistic Women’s Empowerment Project
• The Flintshire Disability Forum (FDF)
• The National Deaf Children’s Society
• The Poppy Factory
• The Royal National Institute for Deaf People (RNID)
• Torfaen Access Forum
• Transport for Wales (TfW)
• University of South Wales
• Vale of Glamorgan Council
• Victim Support
• Wales Council for the Blind
• Wales Council for the Deaf
• Wales Third Sector Additional Needs Alliance
• Wales Trades Union Congress (TUC)
• Welsh Ambulance Service NHS Trust
• Welsh Local Government Association (WLGA)
• Welsh Parliament
• Welsh Women's Aid
• Where I Want to Live
• Whizz-Kidz
• Women's Equality Network (WEN) Wales
• Wrexham Council
• Ysgol Bryn Castell
• Ysgol Crug Glas
• Ysgol Ty Coch School Council
• Ysgol Y Deri