Accessibility of Heritage Sites for Persons with Disabilities: Unlocking the Potential of the European Heritage Label

Abstract

In the European Union (EU), cultural participation is recognised both as a human right and as a key factor in fostering a shared European identity. To promote access to culture, the EU has launched several initiatives, including the European Heritage Label (EHL), which aims to highlight heritage sites of symbolic significance for Europe. This article discusses how accessibility for persons with disabilities features in the EHL. It does so further by outlining the international obligations undertaken by the EU to promote participation in culture and ensure accessibility, particularly under the United Nations Convention on the Rights of Persons with Disabilities (CRPD). Drawing on a document analysis of key legal and operational EHL texts, the article demonstrates that accessibility is only partially integrated into the initiative and is weakly prioritised in both the site selection and monitoring processes. While self-reporting by the EHL sites on accessibility has improved in recent years, the measures adopted tend to be limited in scope and depth. Overall, the article calls for a stronger and more systematic integration of accessibility requirements within the EHL framework, as well as for the meaningful involvement of organisations of persons with disabilities in assessing and monitoring the accessibility of EHL sites.

1. Introduction

Within the European Union (EU), cultural participation has been recognised as a key factor in fostering social cohesion, European identity, and intercultural dialogue [1]. Findings from a recently released European Commission’s Eurobarometer further show that 87% of EU citizens think culture should have a very important place in the EU so that “citizens from different Member States can feel more European”, while 86% believe that culture is important for well-being and economic development [2]. As reiterated in the recent communication from the European Commission, ‘A Culture Compass for Europe’ [3], the EU is strongly committed to fostering cultural participation by broadening access to culture and enhancing active participation of EU citizens as artists and cultural workers. In particular, among the EU’s various initiatives aimed at broadening access to cultural heritage, the European Heritage Label (EHL) stands out as one of the most significant, highlighting the central role of culture within the EU [4].

The EHL initiative was established to highlight heritage sites of symbolic European value and to support the engagement of all European citizens with culture to enhance their sense of belonging to the EU. It originated as an intergovernmental initiative in 2006 and was set up as an official EU action in 2011 through a legislative act—Decision No 1194/2011/EU of the European Parliament and the Council establishing a European Union action for the European Heritage Label (EHL Decision) [5]. Extending access to sites carrying symbolic meaning linked to the European shared history is a core feature of the EHL initiative, but this goal cannot be fully achieved if the sites are not accessible to everyone, including persons with disabilities.

Access to EHL sites for persons with disabilities is not only essential to achieving the overall ambitions of the EHL provided for in Article 3 of the EHL Decision [5]. It also contributes to fulfilling the right to participation in cultural life, which is a fully fledged human right [6], enshrined in the Universal Declaration of Human Rights (Article 27(1)) [7], the International Covenant on Economic, Social and Cultural Rights (Article 15) [8], and, most significantly for the purpose of this analysis, the UN Convention on the Rights of Persons with Disabilities (CRPD) (Article 30) [9] among other international human rights instruments. Since the CRPD was concluded by the EU in 2010 [10], the EU has an obligation to fulfil Article 30 CRPD, as well as to ensure, as underscored by Article 9 CRPD, accessibility of cultural sites and venues as a precondition to participation in cultural life for persons with disabilities. In that connection, the EU Disability Strategy 2021–2030 [11], which sets out to implement the CRPD, espouses accessibility of culture as a critical element for the full social participation of persons with disabilities and commits to making cultural heritage accessible to persons with disabilities.

Yet, notwithstanding the celebrated importance of culture in the EU and the commitments to foster the shaping of the EU identity through cultural participation, and despite the obligations that the EU has undertaken under the CRPD, persons with disabilities in the EU continue to face barriers in accessing cultural heritage [12,13,14]. In a piece on cultural space and intercultural dialogue, Lähdesmäki et al. drew attention to the exclusion of “marginalised and oppressed people” from community belonging through both implicit and explicit means [15]. This critique clearly concerns persons with disabilities, who are often excluded from EU initiatives aimed at fostering community, identity, and belonging. According to Eurostat data, around 100 million EU citizens are persons with disabilities, including approximately 73 million with moderate disabilities and 27 million with severe disabilities [16]. The latest figures from the EU Statistics on Income and Living Conditions (EU-SILC) reveal significantly lower rates of cultural participation among persons with disabilities (or “persons with activity limitations”, as classified in EU-SILC) compared to the general population [17]. These disparities in cultural participation point to a disconnect between the EU values and legal commitments to inclusiveness and accessibility of culture and their practical implementation.

Against this background, this article critically examines the extent to which accessibility for persons with disabilities is integrated and operationalised within the EHL initiative and how the EHL actually fosters access to culture for persons with disabilities. This article does not engage with the concept of European identity, which has already been the focus of considerable academic debate [18,19]. On the bedrock of a legal doctrinal analysis of EU accessibility obligations under the CRPD and accessibility norms in the relevant EU legal framework, it conducts a document analysis of the EHL operational documents related to the EHL—namely the EHL Decision, periodic evaluation reports of the initiative, and monitoring reports of a sample of EHL sites of all reporting cycles from 2016 to 2024. As it will be explained later in the article, EHL evaluation reports provide an external and independent appraisal of the EHL action as a whole and are released every six years. EHL monitoring reports concern the EHL sites and are released every four years. On the basis of the document analysis supported by legal-doctrinal analysis, the article identifies whether and to what extent accessibility for persons with disabilities is dealt with in the EHL initiative and assesses the extent to which the EHL legal and operational frameworks foster access to cultural heritage for persons with disabilities and accomplish their right to participate in cultural life. It further aims to provide recommendations and inform policy improvements, advocating for stronger integration of accessibility measures within EHL processes, thereby enhancing cultural participation for persons with disabilities.

This article is particularly timely, considering that the EU is expected to act on the recent EHL evaluation report undertaken in 2024 and published in 2025 [20] in order to enhance the initiative’s overall effectiveness, including by revising the EHL Decision. In fact, in the recent ‘A Culture Compass for Europe’ [3], the Commission vowed to ‘renew and strengthen the European Heritage Label to ensure its continued relevance’. Moreover, the next Multi-Annual Financial Framework is currently under negotiation, and the European Commission has proposed a substantial increase in funding for culture [21] by virtue of the new AgoraEU programme, which is expected to merge the existing Creative Europe and Democracy, Citizens, Equality, Rights and Values programmes [22]. Therefore, this is an appropriate opportunity to urge EU institutions to prioritise the accessibility of cultural heritage in important EU initiatives such as the EHL. Besides being timely, this article fills a gap in the literature. No study has yet examined how accessibility for persons with disabilities is addressed in practice within the EHL initiative. Scholars at the University of Jyväskylä issued a policy brief on the EHL in 2018, seeking to understand, among other things, how this initiative could improve its approach to accessibility and openness as key EU values [23]. This group of academics, including Lähdesmäki, Mäkinen, and Čeginskas, published extensively on EU heritage policy and specifically the EHL [23,24] as part of the EUROHERIT project [25], yet they did not address the accessibility of EHL sites for persons with disabilities. Recent work has critically examined the EU’s role in promoting accessibility to cultural goods and services, but has not examined the EHL [26].

Beyond this EU policy-focused scholarship, this article is also timely in that it contributes to scholarly debates on accessibility within the remit of disability law, disability studies, and beyond. In fact, such debates also offer important conceptual tools that underpin a deeper understanding of how cultural participation by persons with disabilities is framed and pursued within the EU. Garland-Thomson [27] has argued that the lack of accessibility creates “misfits” and that the built environment can act as a form of oppression, the same way attitudes toward disability can create social oppression. Following Fineman’s, Butler’s, and Turner’s works on inherent vulnerability, Garland-Thomson argues that environments are either “hostile” or “sustaining”: a hostile (inaccessible) environment realises/exposes the inherent vulnerability of the misfit, while a sustaining (accessible) environment keeps the inherent vulnerability dormant [27], p. 600. This relational understanding of disability, which foregrounds the role of environmental design in creating misfits or “fits”, aligns closely with the CRPD’s social-contextual model and its emphasis on accessibility as a precondition for participation in cultural life. Titchkosky’s [28] arguments that inaccessibility reflects the understanding of collective conceptions of normalcy and that access should be understood as an ongoing practice of reshaping social and material environments rather than as one-off technical fixes for individual impairments. Building on that, and drawing on the human rights approach to disability by Degener and others [29,30,31], this work conceives the need to make the EHL accessible to people with disabilities as essential to realise an enabling cultural environment. Moving beyond treating accessibility as a “tick-box exercise” epitomises, in this article, a shift towards a collective understanding of the environment’s potential to disable individuals with impairments.

After this introduction, this article is structured as follows. Section 2 contextualises the analysis by providing an overview of the EHL initiative and how it is deployed. Section 3 discusses the methods used for the study, with a focus on the document analysis. Section 4 discusses how accessibility is protected and promoted in the EU legal framework. In that regard, the section also outlines the obligations stemming from the CRPD that the EU has undertaken. Section 5 presents and discusses the findings of the analysis. The final section provides some concluding remarks and sets out tailored recommendations for strengthening accessibility within the EHL framework.

Cognisant of the ongoing debate on the language of disability, but consistent with the language used by the CRPD and in EU law, this article uses people-first (or person-first) language (i.e., “people/persons with disabilities”) and, only sporadically and in an interchangeable fashion, “disabled person/people”.

2. Setting the Scene: The European Heritage Label

While significantly impacting cultural policy through its internal market regulation, the EU has a limited competence in the cultural field strictu sensu [32,33,34], as outlined in Article 6 and Article 167 of the Treaty on the Functioning of the European Union (TFEU) [35]. On the basis of these provisions, the EU mostly supports projects that have a European added value, as well as it funds or organises emblematic European initiatives that develop and promote the sense of belonging [36]. The current EU Work Plan for Culture for 2023–2026 places emphasis on such initiatives [37], with reference to the European Capitals of Culture, which has been running since 1999 [38], and the EHL, which is illustrative because of its emphasis on European history and the development of the feeling of belonging to the EU.

As noted in the introduction, the EHL was set up in 2011 by virtue of Decision No 1194/2011/EU (EHL Decision) [5]. According to Article 3 of the EHL Decision, the EHL aims at “strengthening European citizens” sense of belonging to the Union, in particular that of young people, based on shared values and elements of European history and cultural heritage, as well as an appreciation of national and regional diversity” and at “strengthening intercultural dialogue”. These overarching objectives are complemented by intermediate objectives which focus on “stressing the symbolic value and raising the profile of sites which have played a significant role in the history and culture of Europe and/or the building of the Union” as well as “increasing European citizens’ understanding of the history of Europe” and the process of European integration (Article 3(2) of the EHL Decision). As it emerges from the text of the Decision, while being an initiative aimed at all EU citizens, the EHL’s primary (although not exclusive) target group is that of “young people”, as the initiative aims to address the growing distance between the younger generations and the European integration project (Article 3(1)(a) and Article 3(3) of the EHL Decision). Accordingly, the core expectation of the EHL is to encourage European citizens—especially young people—to visit EHL sites and engage with a European narrative, thereby contributing to the development of a European identity.

Sites that can qualify for the EHL include “monuments, natural, underwater, archaeological, industrial or urban sites, cultural landscapes, places of remembrance, cultural goods and objects, and intangible heritage associated with a place, including contemporary heritage” (Article 2(1) and Article 6 of the EHL Decision). Sites can be national (Article 13 of the EHL Decision), i.e., located in one Member State, or transnational (Article 12 of the EHL Decision), i.e., located in different Member States. After a pre-selection occurring at the Member State level (Article 10 of the EHL Decision), a European Panel of 13 independent experts (European Panel) selects the sites on the basis of the criteria laid out in Article 7 of the EHL Decision. Candidate sites for the EHL “must have a symbolic European value and must have played a significant role in the history and culture of Europe and/or the building of the Union”, and they must present both a project to be implemented and a work plan on the management and preservation of the site. Each Member State may pre-select up to two sites, while the Panel may select no more than one site per country. On the basis of the recommendations formulated by the European Panel, the European Commission designates the sites to be conferred the EHL (Article 14 of the EHL Decision). To complement the EHL Decision and assist candidate sites in preparing their applications, the European Commission published the ‘European Heritage Label Guidelines for Candidate Sites’ (Guidelines) in 2022, which reiterates the importance of ensuring wide access [39]. As of 2025, there were 67 EHL sites in total, spread across the Member States, and an additional 21 sites were pre-selected for the EHL in 2025 [40].

In alignment with the overarching EHL objectives, sites themselves must attain specific objectives (Article 3(3) of the EHL Decision), which somewhat tally and overlap with the criteria for selection. These objectives include those of “highlighting their European significance” and “increasing and/or improving access for all, especially young people” (Article 3(3) of the EHL Decision). In that connection, while the EHL is awarded on a permanent basis, each EHL site is monitored on a regular basis “in order to ensure that it continues to meet the criteria and that it respects the project and work plan submitted in its application” (Article 15 of the EHL Decision). In particular, monitoring reports are prepared by Member States every four years and then submitted to the European Panel for examination. This means that the monitoring is conducted by EHL sites themselves and national coordinators in the Member States. The most recent set of monitoring reports was made publicly available in April 2025. The European Panel will then issue a report on the state of the sites by the end of the year of the monitoring procedure, “including if necessary, recommendations to be taken into account for the following monitoring period” (Article 15(4) of the EHL Decision).

The EHL initiative is managed by the European Commission (Article 17 of the EHL Decision) and particularly by its Directorate-General for Education, Youth, Sport and Culture. An independent entity—the EHL Bureau—has been established to further support the Commission in managing the EHL for the period 2023 to 2026 [40]. The EHL Bureau collaborates with the network of sites through training and other forms of assistance and is funded with €3 million from EU funds. The funding available for the EHL stems from the Creative Europe programme, but only covers the costs of the initiative at the EU level and the costs of networking between the sites [39] (p. 14). It does not fund specific activities (such as accessibility adaptations) or preservation actions at the site level.

Besides the periodic monitoring of EHL sites, as outlined in Article 15 of the EHL Decision and mentioned above, the EHL initiative as a whole undergoes an evaluation every six years. Such evaluation is meant to examine “all elements, including the efficiency of the processes involved in running the action, the number of sites, the impact of the action, the widening of its geographical scope, how it could be improved, and whether it should be continued” (Article 18 of the EHL Decision). It is conducted by external experts who are different from the members of the European Panel. The first evaluation report was published in 2019 [41], while the latest evaluation report, as noted earlier in the introduction to this article, was published in 2025 [20]. Once the evaluation is finalised, the Commission must present the evaluation report to the European Parliament, the Council of the EU, and the Committee of the Regions within six months.

3. Methods

After having introduced the EHL initiative and highlighted its core aims, this section outlines the methods of the study presented in this article. Notably, this study, which is part of a larger project on cultural participation of persons with disabilities in the European Union, combines legal doctrinal analysis [42] and document analysis [43] to examine whether and to what extent accessibility for persons with disabilities is dealt with and operationalised in the EHL initiative. The use of document analysis is premised on the idea that, as noted by Mitchell [44] (p. 102), “law is a key site of interest for qualitative researchers”(see also Coffey [45]). In particular, we adopted a thematic qualitative approach to document analysis following a la Braun and Clarke [46].

3.1. Doctrinal Legal Analysis

The doctrinal legal analysis centres on how the EU protects and promotes accessibility in its legal framework. Particular attention is paid to the obligations that the EU has undertaken under the CRPD in relation to the cultural participation of persons with disabilities. In that regard, the article outlines and comments on relevant CRPD provisions. This analysis briefly addresses how accessibility is governed in EU legislation to frame the EHL initiative and support the document analysis.

3.2. Document Analysis

Document analysis is a form of qualitative research that uses a systematic procedure to analyse documentary evidence to address a specific research question. It is a recognised method for reviewing or evaluating documents, combining elements of content analysis and thematic analysis [43]. It usually seeks to make evident the implications of formulations and phrases. In this study, document analysis entailed the examination of a series of relevant EU legal and operational documents concerning the EHL to elicit themes and patterns around accessibility.

3.2.1. Retrieving and Analysing the Documents

The identification of relevant documents entailed a search of the official EU law database EUR-Lex [47] as well as of all relevant EHL official webpages on the European Commission website [48] and the website of the EHL bureau [40]. With respect to the timeframe, this study encompassed the years 2011–2024, commencing from the release of the EHL Decision, which was accordingly selected as the starting point of the time range. The time frame allowed us to exclude all preparatory documents that led to the decision.

We collected three types of documents: the EHL Decision [5], evaluation reports [20,41], and publicly available monitoring reports of the EHL discussed in the sections below. As noted earlier, evaluation reports are compiled by independent experts and published by the European Commission in compliance with Article 18 of the EHL Decision. Monitoring reports contain EHL sites’ self-reported information (consolidated by the European Panel) together with the assessment of the European Panel, which ascertains whether the EHL sites continue to meet the criteria for the designation of the label. These reports also include an assessment of the EHL and recommendations. They are published by the European Commission in line with Article 15 of the EHL Decision on the EHL dedicated webpage. We also retrieved an additional document—the Report of the European Panel to the European Commission published in 2021—which marked the 10th anniversary of the initiative. This report was considered in conjunction with the analysis of the EHL Decision and will be discussed in Section 5. We have excluded documentation related to the newly pre-selected EHL sites as their status is not confirmed.

The document analysis revolved around a key research question: How and to what extent has the EHL initiative addressed accessibility for persons with disabilities? In the case of the EHL Decision, the document analysis allowed us to ascertain the extent to which accessibility for persons with disabilities featured in the initiative as a whole. In the case of evaluation reports and monitoring reports, we looked at whether and how accessibility was operationalised and achieved. Within the monitoring reports, our analysis focused on 20 EHL sites that were reviewed in all the monitoring cycles. Given that EHL sites are selected every two years, many underwent their first review only in 2020 or 2024. To enable the tracing of changes in reporting and accessibility over time, we focused on the 20 sites that were first reviewed in 2016 and subsequently included in both the 2020 and 2024 reports. The sites (and relevant reports) were selected to cover a range of different EU Member States (

Table 1. EHL sites examined across three EHL monitoring reports: 2016, 2020, and 2024.

Site	Country
Heart of Ancient Athens	Greece
Archaeological Site of Carnuntum	Austria
Abbey of Cluny	France
Archive of the Crown of Aragon	Spain
Great Guild Hall	Estonia
General Library of the University of Coimbra	Portugal
Union of Lublin (1569)	Poland
Sites of the Peace of Westphalia (1648)	Germany
3 May 1791 Constitution	Poland
Hambach Castle	Germany
Charter of Law for the Abolition of the Death Penalty (1867)	Portugal
Peace Palace	Netherlands
Student Residence/Residencia de Estudiantes	Spain
Kaunas of 1919–1940	Lithuania
Camp Westerbork	Netherlands
Franja Partisan Hospital	Slovenia
Robert Schuman’s House	France
Alcide de Gasperi’s House Museum	Italy
Historic Gdańsk Shipyard	Poland
Pan-European Picnic Memorial Park	Hungary

EHL = European Heritage Label.

).

We analysed the documents thematically, following Braun and Clarke’s [46] six-phase approach of thematic analysis (familiarisation, systematic coding, generating initial themes, developing and reviewing themes, refining, defining and naming themes, and writing up) and combining deductive and inductive coding. Drawing on the normative framework outlined in Section 4, the first author first developed a deductive coding frame to capture explicit and implicit references to “access” and “accessibility”, and mentions of “disability”. Attention was paid to the language used in the documents to describe and interpret the word “access” to find repeated patterns of meaning reflected in text. The initial deductive coding allowed the capture of general access measures (e.g., introduction of multilingual tours, reduced entrance fees for youth) and disability-specific measures concerning accessibility. This allowed us to categorise the documents (as discussed later in the paper) and identify reports that do not engage with accessibility for persons with disabilities. Through inductive coding, we identified general/unspecified access measures for people with “special needs” as part of broader strategies and specific measures concerning physical accessibility for people with “reduced mobility” and measures related to accessibility of information with reference to Braille, from which the theme of accessibility as an EHL objective arose. While “accessibility” is a term used to mark different concepts and is not exclusive to the field of disability law [49], in the present article, accessibility is understood as the possibility for persons with disabilities to access goods, services, facilities, transportation, spaces, places, information, and communications on an equal basis with others [50]. In relation to heritage, accessibility for persons with disabilities encompasses physical access to the sites, including existing accessible transportation to the site itself, cognitive and sensory access to the site, as well as access to information and communications that are important for understanding the heritage sites’ significance, characteristics, and other elements that are usually available to visitors, such as how to navigate the site [51,52]. In that connection, our document analysis is informed by the normative meaning of accessibility, which stems from the legal analysis of the CRPD and the EU legal framework conducted in Section 4.

Our qualitative analysis takes into account the diverse purposes of the various documents. With regard to evaluation and monitoring reports, we paid attention to different cycles to detect developments or changes across the time periods considered, to detect temporal patterns. In relation to monitoring reports, the focus on 20 sites allowed us to explore trends in site-level reporting on accessibility as well as the consistency of the European Panel’s engagement with accessibility in the three monitoring cycles of 2016, 2020, and 2024. While the analysis carried out cannot fully disentangle whether improvements reflect substantive changes at the site level or are primarily driven by procedural adjustments in the monitoring framework, it does highlight patterns of continuity and neglect—for example, repeated non-reporting or limited reporting by certain sites and the European Panel’s failure to respond through recommendations.

Being aware of the diverse purposes of the three types of documents reviewed, the findings are presented and discussed in three separate sections, with the concluding remarks bringing together all the strands of the document analysis and providing recommendations. Considering the document types and functions helped to give clarity to the ways in which accessibility is framed and addressed.

3.2.2. Limitations

The limitations of this study concern the limited corpus of documents and the inherently diverse functions of the documents. The selection of 20 sites, although justified to ascertain some temporal patterns, is also a limitation. Furthermore, evaluation and monitoring reports present intrinsic weaknesses.

The evaluation reports were drafted on the basis of data collected through methods that differ. The first evaluation ‘made extensive use of documentary evidence to gain a good understanding of the EHL action’s internal operations, its performance and links with other initiatives’, complemented by stakeholder consultation in the form of an open public consultation (OPC), interviews, and focus groups [41] (pp. 6–9). The second evaluation, besides desk-based and qualitative research, also included case studies, ‘providing detailed insights into the operation and impact of the EHL’ initiatives and action. Thus, the two reports are not—stricto sensu—comparable. Further, the same evaluations present limitations that are overtly highlighted in both reports [20,41].

With regard to the monitoring reports discussed further in Section 5, other limitations intrinsic to these documents need to be highlighted. As mentioned earlier, each Member State monitors the site on its territory, and the European Panel issues a consolidated monitoring report based on national submissions, thus providing only a sort of “indirect” assessment based on the national monitoring. Hence, all data included in such monitoring reports were self-reported by the sites to the national coordinators in Member States, which may imply bias and potential limitations in terms of reliability and completeness of the documents. Moreover, following the 2018 Evaluation Report, the European Commission decided to harmonise monitoring practices across Member States. Hence, similarly to the evaluation reports, these monitoring reports differ in the methods used and present differences also in relation to the content and structure. These limitations were critically accounted for when analysing the findings.

This study examines, as noted above, how accessibility is addressed in the EHL by focusing exclusively on relevant EU policy documents as identified above and does not include qualitative research with persons with disabilities. This is a limitation of this study. However, this research is an essential analytical and conceptual stepping stone for future scholarship. By mapping the normative framework, policy objectives, and institutional approaches to accessibility embedded in the EHL initiative, this study lays the groundwork for subsequent empirical investigations that can meaningfully engage with the perspectives of persons with disabilities. It also foregrounds research that focuses on their lived experiences of participation, access, and inclusion within the EHL. Such future research would be well placed to assess the extent to which the EU’s stated commitments to accessibility are perceived by people with disabilities and whether the measures that are intended to benefit them are effectively realised.

4. The Normative Framework for the Document Analysis: Accessibility in the EU Legal Framework

Guaranteeing accessibility for persons with disabilities in the context of culture is a duty that stems from both EU constitutional law (the EU treaties and the Charter of Fundamental Rights of the EU) and from the CRPD that the EU has ratified and EU legislation. This section does not endeavour to provide any detailed doctrinal analysis of the relevant EU provisions but to highlight how accessibility is guaranteed in EU law and to highlight the normative meaning of accessibility, which stems from the CRPD and is part of the EU legal framework.

While neither the EU Treaties nor the Charter mentions accessibility specifically, they embed the principle of non-discrimination on various grounds, including that of disability. This entails that persons with disabilities should not be discriminated against and should be able to enjoy their rights on an equal basis with others. Article 26 of the Charter of Fundamental Rights of the European Union (CFR) [53] on the social integration of persons with disabilities affirms the right to benefit from EU measures designed to ensure full participation in the community. Such measures encompass accessibility measures that have, in fact, been enacted by the EU.

Particularly relevant international instruments, which the EU has acceded to and that have become an integral part of EU law and have a sub-constitutional status, include the United Nations Educational, Scientific and Cultural Organization (UNESCO) Convention on the Protection and Promotion of the Diversity of Cultural Expressions (UNESCO Convention) and the CRPD. The UNESCO Convention, concluded by the EU in 2006 [54], does not mention accessibility for persons with disabilities specifically. However, it stipulates equitable access to culture, which entails ensuring that culture, including cultural heritage sites, is accessible to all, particularly to social groups for whom it is typically less accessible due to various circumstances. Further, the CRPD, ratified by the EU in 2010 [10], places several obligations on the EU in terms of accessibility, albeit within the limits of EU competences. Article 9 CRPD requires States Parties to ensure accessibility for persons with disabilities as a precondition for full participation in the life of the community and in many essential aspects of life, such as education, work, or enjoyment of culture, including cultural heritage. Consequently, States Parties (including the EU) are obliged to take appropriate measures to guarantee access to the physical environment, transportation, information and communication technologies, and facilities and services open to the public for persons with disabilities. In the CRPD, accessibility as a legal principle is subject to progressive realisation, but States Parties are nonetheless obliged to undertake appropriate measures to advance accessibility [55] (para. 24). Accessibility is an ex ante duty, meaning that it should be ensured proactively [55] (para. 25). This distinguishes it from the duty to provide reasonable accommodation, which is an ex nunc obligation triggered by a specific request and tied to a specific individual [55] (para. 26). Accessibility is aimed at groups of people, whereas reasonable accommodation is aimed at accommodating specific individuals in a specific case. Considering that some persons may face specific barriers that cannot be adequately addressed through general accessibility measures, the duty to provide reasonable accommodation remains critical to ensuring equal access. This is also in the context of EHL sites. This approach recognises the vast differences in impairments that, in interaction with different environments, may impede a person’s access to a heritage site. Besides Article 9 CRPD, accessibility of cultural heritage sites is specifically addressed in Article 30(1)(c) CRPD, which obliges States Parties to take all appropriate measures to ensure access to heritage sites for persons with disabilities, as far as possible. This obligation not only requires the provision of accessible paths, routes, and trails, but also the provision of Braille or tactile information supported by audio information, as well as information in sign language as appropriate. Article 30(1), however, recognises the challenges of making heritage accessible, and by requiring States Parties to ensure accessibility ‘as far as possible’, de facto acknowledges that some heritage sites are located in hard-to-access areas and locations, making it unrealistic to expect that every site will be made fully accessible. In certain cases, authorities must strike a balance between the need to preserve sites and the need to make modifications that would enable access. However, many improvements in accessibility can be implemented without compromising the preservation of the sites [56,57], and the EU, in its cultural action, is still obliged to ensure that appropriate measures are considered and undertaken.

Secondary EU legislation addressing accessibility is fragmented and overlapping [26]. For the most part, it does not specifically address the accessibility of cultural heritage or the built environment, which largely fall within the remit of Member States, but concern an array of goods and services. While not geared to heritage, the European Accessibility Act (EAA) [58] and the Web Accessibility Directive (WAD) [59] are relevant. The WAD applies to public websites and mobile applications, including websites of publicly owned cultural heritage sites, and prescribes that they are accessible to persons with disabilities. The EAA applies to commercial websites and equally prescribes their accessibility [26]. Notably, websites and mobile applications have become key features to book and purchase tickets to visit heritage sites, and web presentations of heritage sites are an essential part of the outreach of cultural institutions [60]. Thus, digital accessibility—required by the EAA and the WAD—is a key component to allow persons with disabilities to visit EHL sites and is indispensable for providing information to visitors with disabilities about the actual physical accessibility of the site itself, as well as about other features of the site (e.g., opening hours, cost of the tickets, etc.).

On the whole, accessibility for persons with disabilities is protected and promoted within the EU legal framework, and this framework is relevant to the interpretation and implementation of the EHL initiative. Further, the EHL itself should contribute to fulfilling CRPD obligations and to realising Article 26 of the Charter.

5. Findings and Discussion

5.1. Accessibility for Persons with Disabilities in the European Heritage Label Decision

After having recalled the normative framework, this section examines how accessibility is addressed within the EHL Decision.

While the EHL Decision is clear in emphasising the importance of increasing access for the wider public as one of the key elements expected of sites participating in the initiative, it does not mention accessibility of sites for persons with disabilities or disability. The word “accessibility” as such does not feature in the EHL Decision, while the word “access” appears in a few instances but mostly in a generic fashion. Taking into account the function of the EHL Decision, two main themes can be detected. First, accessibility for persons with disabilities underpins the EHL initiative by being an implicit objective to be achieved by EHL sites. This theme is consistent with a reading of the Decision, which aligns with the CRPD. Secondly, accessibility is a (somewhat hidden) criterion for site selection. However, the lack of explicit references to accessibility for persons with disabilities constitutes an ostensible gap and hampers compliance with Article 9 CRPD and Article 30(1) CRPD, as well as undermines the realisation of Article 26 of the Charter. As it will be discussed later in this article, this gap should be addressed when revising the EHL initiative.

5.1.1. Accessibility as an “Implicit” Objective to Be Achieved by EHL Sites

Accessibility is not an overarching objective of the EHL initiative, which aims to strengthen “European citizens’ sense of belonging to the Union” and “intercultural dialogue”. However, it is an objective for EHL sites, albeit an implicit one. Article 3(3)(d) of the EHL Decision states that one of the specific objectives of EHL sites must be to “increas[e] and/or improv[e] access for all, especially young people” (emphasis added). The term “for all” clearly points to the principle of equitable access, which encompasses persons with disabilities. To attain this overarching goal, the EHL must improve the accessibility of its sites, which is an intermediate objective toward ensuring access for all. The EHL Decision identifies a specific concrete means of advancing this objective—multilingualism (Article 7(b)(iii))—which requires sites to provide information, materials, tours, and web presentations in several European languages. The EHL Decision does not mention Braille or sign languages, but these features are mentioned in the evaluation reports, as further discussed in Section 6. Further, a broad interpretation of multilingualism, one that complies with the CRPD and with Article 26 CFR, should encompass means of communication used by persons with disabilities and sign languages.

5.1.2. Accessibility as a Hidden Criterion in the EHL Sites Selection Process

As noted above, the selection of EHL sites, i.e., the identification of sites that will be awarded the EHL, is a two-stage process conducted at both national and EU levels and takes place every two years (Article 10 of the EHL Decision). To be selected, sites need to demonstrate that they fulfil the criteria set out in Article 7 of the EHL Decision. None of these criteria specifically mentions persons with disabilities or accessibility. However, among the criteria that sites must meet to obtain and retain the EHL, there is the requirement to have a work plan that, among other elements, aims to “[…] ensure access for the widest possible public, inter alia, through site adaptations or staff training […]”. In this provision, the phrase “the widest possible public” signals again a commitment to equitable access, while the reference to specific measures, such as site adaptations or staff training, indicates that sites should adopt measures (including physical adaptations such as ramps or digital tools) to make the site accessible to persons with disabilities. Although this provision is arguably not limited to disability-related access, the formulation suggests an obligation to include persons with disabilities, given that they are disproportionately affected by inaccessible heritage sites and that both the EU and all its Member States are bound by Articles 9 and 30 CRPD. This is confirmed by the report issued in 2021 in relation to the selection of EHL sites [61]. Some of the sites include in their application references to measures adopted to foster accessibility for people with reduced mobility [61] (p. 19).

5.2. Accessibility for Persons with Disabilities in the Evaluation of the European Heritage Label Initiative

While the EHL Decision provides a framework for promoting access of persons with disabilities to cultural heritage, albeit in general terms, the analysis of evaluation reports allows us to understand whether and how accessibility has been considered and operationalised. To date, two evaluation reports have been published. The first covered the period from 2011 to 2017 [41]. Another evaluation was conducted to encompass the period from 2018 to 2024 [20].

In these evaluation reports that in substance concern the EHL initiative as a whole, we saw that accessibility for persons with disabilities remains a somewhat hidden and low-priority criterion in the EHL site selection. This emerges particularly from the first evaluation. Such a report examined the extent to which sites’ own objectives aligned with those laid out in the EHL Decision to assess the relevance of the EHL framework for participating sites. To do this, the evaluators compared successful (N = 38) and unsuccessful (N = 50) applications submitted between 2013 and 2017 [41] (pp. 21–22). They examined whether EHL Decision objectives appeared in these applications. Notably, for the purpose of this analysis, the objective of ‘developing visitor accessibility’ did not rank highly: only 38 of the 88 sites included it in their applications, and among those, 23 were selected. If the objective of ‘developing visitor accessibility’ had carried greater weight for the European Panel, then sites without this objective in their applications would arguably not have been selected, or at least their selection would have been less likely.

By contrast, the analysis of evaluation reports reveals that accessibility for persons with disabilities is in fact an objective for EHL sites, and one that is increasingly relevant.

5.2.1. Accessibility for Persons with Disabilities as an Essential Facet of Access for All

The analysis of both reports first reveals that accessibility—as an objective for the EHL sites—is understood broadly and in a non-disability-specific manner. In that regard, accessibility tallies with the concept of “access for all”. Given that the EHL Decision does not mention accessibility explicitly and does not place any overt emphasis on persons with disabilities, this is unsurprising. However, both reports do recognise, albeit to a different extent, that accessibility also means accessibility for persons with disabilities.

In the first evaluation report, the evaluators recognised that ensuring access for all involves a dual obligation for EHL sites: first, to make sites generally accessible to the public (e.g., free entrance, online ticket options, transport connections …), and second, to meet bespoke accessibility needs of different target groups and individuals (e.g., accessible websites, ramps, accessible toilets, sign language tours, easy-to-read materials) [41] (p. 74). The report does mention that people with disabilities are considered a specific target group by some sites [41] (p. 75). The second and most recent evaluation report approaches accessibility similarly to the first report. While it suggested the need “to sharpen the focus of the action’s objectives and translate them into more observable operational terms” and incorporated operational objectives that include that of “enhancing various forms of accessibility of sites to effectively engage and cater to diverse audiences” [20] (p. 19), it does not engage with accessibility for persons with disabilities in any detail.

The two-fold framing of accessibility emerging from the reports confirms that accessibility for persons with disabilities is a facet of broader accessibility, and it is an objective to be accomplished by the EHL sites. However, both reports still somewhat obscure the distinction between accessibility for persons with disabilities and general measures to widen access, weakening the possibility for the EHL initiative as a whole to implement Article 30 CRPD.

5.2.2. The Growing Relevance of Accessibility as an Objective to Be Achieved at EHL Sites

Accessibility for persons with disabilities has become increasingly relevant and more visible as an objective to be attained by the EHL sites.

The first evaluation of the initiative considered 28 EHL sites (which do not coincide with our sample of sites for monitoring reports), 24 of which reported having undertaken activities to improve access for all, primarily through free admission [41] (pp. 75–76). This well exemplifies that, as discussed above, sites must cater to diverse needs and groups, but they are not specifically called upon to implement accessibility measures for persons with disabilities. Yet, the evaluation report mentions improvements related to access for persons with disabilities at several sites, including noticeboards in Braille and easy-to-understand information sheets at two sites, with the evaluators concluding that the “[…] sites have been effective in improving access to their sites, with most sites implementing activities in this regard” [41] (p. 76). In that connection, it also seems that accessibility as an implicit objective for EHL sites has likely been advanced, but the report does not provide any conclusive evidence on the extent to which it has been achieved.

In the second report, although accessibility is still considered very generally with references to material and information accessible in various languages (multilingualism), persons with disabilities are highlighted to a larger extent than in the first evaluation report. Namely, data collected for such the evaluation show “that 86% (N = 50) of sites report providing accessible informational materials, and 80% (N = 50) ensure physical accessibility to a large or moderate extent” [20] (p. 42). Additionally, the report recalls that many of the sites reported promoting the inclusion of minorities and marginalised groups [20] (p. 42). The evaluators refer to activities such as “sensory-friendly tours to better accommodate visitors with disabilities”, although they mention these alongside activities that are not disability-specific. Interestingly, the evaluation report indicates that progress on accessibility was “somewhat uneven across different aspects of accessibility”, with most sites focusing on multilingualism (unsurprisingly, given that this is an aspect mentioned in the EHL Decision). The report contends that “[i]n comparison, dedicated activities for people with disabilities are less common: 49% reported making physical accessibility improvements since 2020, while 35% implemented activities specifically for people with disabilities”. While case studies further revealed that sites most often face financial and staff-related obstacles to improving accessibility, including through architectural modifications [20] (pp. 42, 49), the report suggests that the EHL made progress in aligning with EU policy priorities, including that of inclusion [20] (p. 78). Participation in the EHL action was also said to positively influence ‘accessibility and inclusivity efforts at many sites, though these efforts are often interconnected with broader national policies and pre-existing initiatives’ [20] (p. 83).

Overall, while the first evaluation conflated all activities aimed at improving access, the second evaluation included more references for accessibility for persons with disabilities and highlighted increased commitment towards increasing access for visitors with disabilities. Particularly, the second evaluation report hints at the importance of the EHL initiative to support and propel accessibility efforts within the broader commitment to increase and widen access.

5.3. Accessibility for Persons with Disabilities in the Monitoring Reports of European Heritage Label Sites

After having explored the extent to which accessibility features are in the EHL Decision and in the overarching EHL evaluations, this section engages with the monitoring reports. It focuses on the 20 sample sites selected to assess the extent to which accessibility is an objective that EHL pursues and how they do this. We also aimed to detect whether the trend of growing attention to accessibility for persons with disabilities—which is noticeable in the evaluation reports—is also visible in these monitoring reports. In that connection, we looked at how the European Panel approaches accessibility.

With regard to the 20 sites examined, some reports did not include any reference to accessibility for persons with disabilities, while others included a reference to accessibility without details on measures or practices. Some reports included detailed information. We hence identified three broad categories of reports—referenced in

Table 2. Categories for accessibility reporting, with definitions and illustrative examples from site monitoring reports.

Category	Definition	Example
No reference	No mention of accessibility for persons with disabilities.
General reference	Accessibility mentioned generally and briefly, without detail on measures or practices.	“Measures have been implemented to […] improve accessibility for visitors with impairments”
Reference accompanied by specific information	Accessibility mentioned together with examples of at least one specific measure or practice adopted.	“Accessibility is a key priority, and significant efforts have been made to improve it, especially for visitors with disabilities. New tools for guided tours for visitors with vision impairments have been introduced, along with a special app designed for children on the autism spectrum”

. While these categories are deliberately broad and descriptive, they allow for the capture of the variety of wording included in the reports.

We note, however, that some sites that did not report on accessibility measures may not have developed them yet or may simply have omitted them from their reports. Therefore, a lack of reporting should not be taken as conclusive evidence of the absence of accessibility measures.

Turning to the results, this study confirms a growing attention to accessibility for persons with disabilities by sites themselves. Yet, accessibility remains somewhat peripheral within the Panel’s monitoring practice.

5.3.1. The Growing Relevance of Accessibility as an EHL Site Objective

Across the 2016, 2020, and 2024 monitoring cycles, accessibility reporting at EHL sites shows a strong shift toward more detailed and specific reporting and a marked decline in sites providing no accessibility information. By 2024, the number of sites providing no accessibility information has decreased by more than two-thirds compared with 2016. A few sites moved from giving no information to giving some information (e.g., Archaeological Site of Carnuntum in Austria, Abbey of Cluny in France), while others shifted from general information to more detailed information (Heart of Ancient Athens) in the reports examined, as detailed in the

Table 3. Distribution of accessibility reporting across EHL sites in the 2016, 2020, and 2024 monitoring cycles.

	No Reference	General Reference	Reference Accompanied by Specific Information
2016	18	1	1
2020	15	2	3
2024	5	4	11

below. The latter is the most notable change. The number of sites giving specific accessibility information more than triples between 2020 and 2024 and increases elevenfold compared to 2016.

The trend indicates a clear improvement in the quality and presence of accessibility reporting across EHL sites. Over time, sites are moving away from silence on accessibility and toward providing more detailed, concrete, and useful accessibility information. This trend also mirrors the increasing visibility of accessibility in evaluation reports, expounded in the previous section. Furthermore, the trend appears to be closely linked to changes in the monitoring methodology, notably, to the introduction of a specific question on accessibility in the 2020 monitoring form—which sites have to fill in—which confirms that accessibility is an objective to be achieved by sites as articulated earlier. In fact, the 2016 questionnaire included only a line on “Access for all” [62] (Q 10 of the monitoring form 2016–2020, p. 46), requiring sites to describe measures undertaken to improve access for everyone, whereas subsequent questionnaires contained more specific questions referring to access to the EHL site for people with disabilities. Despite introducing the specific question on measures to improve accessibility for persons with disabilities in 2020, only five sites reported relevant measures that year. By 2024, however, 15 sites reported on accessibility. For instance, the reports for 2016 [62] and 2020 [63] on the General Library of the University of Coimbra in Portugal did not include any information on accessibility, whereas the 2024 report provided some information: ‘All public spaces are accessible, with the “Inclusive Library” launched in 2021 to support individuals with impairments using advanced technology’ [64] (p. 57). Another example of a site going from no information (in 2016 and 2020) to providing some information in 2024 is Franja Partisan Hospital in Slovenia: ‘[…] accessibility remains a challenge, especially for visitors with reduced mobility, as the site’s hilly terrain makes technical adaptations nearly impossible. To ensure inclusivity, the site offers personalised tours and additional assistance for individuals with physical and cognitive disabilities’ [64] (p. 114). In the case of the site Heart of Ancient Athens, the information on accessibility evolved from vague to more elaborate over time. In 2016, the report simply stated, ‘Much has been achieved in terms of […] access for the disabled […]’ [62] (p. 11). In 2020, it noted only that attention was given to accessibility for persons with disabilities and that an educational programme would be developed for children with autism [63] (p. 16). By 2024, however, the report emphasised that ‘Accessibility is a key priority, and significant efforts have been made to improve it, especially for visitors with disabilities. New tools for guided tours for visitors with vision impairments have been introduced, along with a special app designed for children on the autism spectrum’ [64] (p. 29).

All in all, improvements in site reporting between 2016 and 2024 are evident, yet they appear to be closely linked to procedural adjustments in the monitoring tools—namely, the introduction of a specific question on accessibility in 2020—rather than to a consistent and substantive prioritisation of accessibility by the Panel itself. On the one hand, the steady increase in the number of sites reporting accessibility measures indicates that the issue is gradually gaining ground within the monitoring framework. On the other hand, the uneven depth of reporting shows that this growth cannot yet be described as a systematic trend. It is also important to stress that these findings are based entirely on self-reporting. This introduces the risk of both underreporting and overestimating actual accessibility levels. Moreover, the quality of information provided is often vague and lacking in detail, leaving readers to infer which accessibility measures are in place at the sites. The reliance on self-reporting significantly limits the capacity of monitoring to provide an accurate or comprehensive picture of accessibility and makes accessibility also a “hidden” objective in practice.

5.3.2. Scant Recommendations on Accessibility as Still “Hidden” Objective

Apart from assessing whether the EHL sites meet the criteria, the Panel also issues recommendations to each site in its monitoring reports, as well as general recommendations. This would have been a good opportunity for the Panel to draw the attention of the site management to improving accessibility for persons with disabilities and how to achieve it. Yet, across all three monitoring cycles examined, only one recommendation on accessibility for persons with disabilities was issued (among the 20 examined sites). Namely, the Panel recommended to the management of the Peace Palace [65] (p. 96): ‘Preparing special programmes for groups with visual and hearing impairments would align with the sub-criteria established for organizational capacity.’ The Panel did not recommend any improvement in the reporting to the sites (Great Guild Hall, Sites of the Peace of Westphalia (1648), Alcide de Gasperi’s House Museum, and Historic Gdańsk Shipyard) that failed to report any measures on accessibility in all three.

In addition, in its general recommendations, the European Panel called on all sites to pay special attention to the needs of persons with disabilities (referred to as “impaired”), among other recommended improvements, in its 2016 Monitoring Report [62] (p. 34). No similar general call was made in the subsequent reports in 2020 and in 2024.

On the whole, the analysis shows that general aspects of improving ‘access for all’ are addressed more often and in more detail by the Panel. This is particularly relevant to multilingualism, which is mentioned in the EHL Decision, or providing sites’ information, materials, and tours in several European languages, then providing sufficient information on web presentations, as well as improving access for youth. In that regard, the Panel issued recommendations on improving access for foreign visitors through multilingual offers, such as in the case of the Student Residences in Madrid in 2016, where it encouraged ‘access for on-line visitors and the use of more languages’ [62] (p. 23). Looking at the same 20 sites, the Panel issued recommendations on multilingualism to 10 sites in 2016, 6 in 2020, and 7 in 2024. Thus, while accessibility for persons with disabilities has gained a degree of visibility in the EHL site reports, it remains peripheral within the Panel’s monitoring approach. This raises questions about whether accessibility is being recognised as a core dimension of the EHL ‘access for all’ goal and of the EHL initiative as a whole. It seems that it continues to be treated as an ancillary issue by the Panel, addressed very limitedly.

A further implication concerns the role of monitoring in driving change. Monitoring frameworks are not only evaluative tools but also mechanisms for “dialogue, coaching and mutual learning”, which has also been underscored by the Panel [63] (p. 8). By failing to systematically flag gaps in accessibility, the Panel has missed opportunities to use its authority as a catalyst for change. The case of the Peace Palace, which received the only explicit recommendation on accessibility in 2024, illustrates what more consistent engagement might have achieved across other sites that persistently failed to report measures. Without such reinforcement, progress in accessibility remains fragile, uneven, and largely dependent on other factors rather than on the EHL initiative itself. This stands in contrast to the Panel’s approach to multilingualism, where its recommendations created a positive loop that drove consistent improvements across sites, as demonstrated by the reports in 2020 and 2024 [63,64].

Finally, from a broader methodological perspective, a revamp of the EHL initiative will need stronger verification mechanisms and clearer indicators for accessibility to be systematically integrated into the EHL framework for the EHL to comply with and fulfil accessibility obligations. A better connection between the monitoring of the WAD and the monitoring of EHL sites’ digital accessibility might also support coherence in the implementation of existing accessibility standards in the EU.

6. Conclusions

The analysis undertaken in this article reveals persistent shortcomings in how accessibility for persons with disabilities is addressed within the EHL initiative. While the EHL Decision frames ‘access for all’ as one of the core objectives, the absence of explicit reference to accessibility for persons with disabilities has resulted in a weak strategic focus throughout monitoring and follow-up processes. Improvements in reporting between 2016 and 2024 were largely driven by procedural changes in the monitoring framework rather than by consistent engagement from the Panel. As a result, accessibility remains only partially integrated into the initiative’s operational practices and continues to lag behind other elements of ‘access for all’, such as multilingualism. While some sites reported innovative practices—such as the Inclusive Library in Coimbra or personalised tours at Franja Partisan Hospital—these remain isolated examples rather than evidence of a broader trend. The findings of document analysis suggest that while the EHL monitoring process has generated modest improvements in accessibility reporting, it has not yet embedded accessibility as one of the central criteria.

To align with the CRPD, it is recommended that the Panel treat accessibility not as a peripheral aspect of ‘access for all’ but as one of the core requirements for the realisation of the EHL’s objectives. This would require more consistent recommendations, more robust indicators, and greater engagement with the substantive content of site practices. The Panel’s strategic guidance could make a huge difference in enhancing accessibility for persons with disabilities in EHL sites and stimulating good practices. Monitoring frameworks can serve as drivers of change when combined with meaningful recommendations, but the Panel has not used its mandate in this way. To fulfil its potential, the EHL monitoring process must embed accessibility as a central evaluative criterion, alongside multilingualism, thereby aligning with the CRPD and fulfilling the call for inclusion of persons with disabilities in Article 26 CFR. Of course, an update of the EHL Decision itself to explicitly mention accessibility for persons with disabilities might support this goal.

The involvement of organisations of persons with disabilities, in line with Article 4(3) CRPD, within the monitoring processes of each site and/or within the Panel itself would strengthen both the quality and legitimacy of these processes. Guidelines and standardised indicators for reporting on accessibility could be developed in conjunction with the project AccessibleEU [66]. Where sites initially lack accessibility, they should be required to develop detailed plans for improvement and to ensure accessibility to the extent possible. The EHL Bureau could collaborate with site management to facilitate such improvements, thereby enhancing its own role and relevance in the EHL initiative.

Often, the limited emphasis on accessibility within the EHL may stem from the perceived financial burden associated with such measures, especially given the absence of dedicated EHL funding to support their implementation. To address this, the Commission should consider introducing targeted grants for heritage sites aimed at improving accessibility, utilising funding sources like the European Structural and Investment Funds and the Citizens, Equality, Resilience and Values Programme [67]. These funding mechanisms could significantly enhance accessibility at EHL sites, and would respond to the Panel’s own call for tailored support for sites with limited resources [64] (p. 7).

Implementing these recommendations could significantly enhance the accessibility of EHL sites and broaden the initiative’s reach and impact. Greater accessibility would not only expand participation but also strengthen the sense of belonging for persons with disabilities that the initiative is meant to foster.

Alongside supporting key policy recommendations that would allow the EU to fulfil its obligations under the CRPD, the analysis conducted also advances disability scholarship from a theoretical standpoint. It shows how international human rights obligations on accessibility, as articulated in the CRPD, are only partially translated into EU cultural policy. Accessibility is not fully realised when it is operationalised merely through soft instruments such as selection criteria, monitoring templates, and self-reporting. In this connection, by highlighting the limits of broader “access for all” narratives that risk undermining accessibility for persons with disabilities, it further evidences the need for a renewed disability focus when critically analysing EU action in the cultural field. Future research could build on this document analysis and engage in additional empirical research involving organisations of persons with disabilities and EHL site managers, in order to advance understanding of how accessibility requirements are interpreted and implemented in practice.

More broadly, this article has endeavoured to contribute to the understanding of how and to what extent EU law and policies support accessibility, and to provide additional evidence of the key role that the EU can play in enhancing disability rights when it uses its powers and instruments to their full potential.