Ad Hoc Query on challenges and opportunities in the use of digital services in legal migration procedures
This ad hoc query, which informed the preparation of an EMN Inform, collected information on how EMN Member and Observer Countries have adapted digital services in legal migration procedures to ensure accessibility and inclusion for applicants with disabilities and digitally disadvantaged applicants. It examined compliance with relevant EU and international frameworks, as well as national legislation. It also explored additional accessibility measures, support for users with special needs, GDPR safeguards, user involvement in service design, and approaches to digital disadvantage, alongside challenges and good practices identified by countries.
This ad hoc query, which informed the preparation of an EMN Inform, collected information on how EMN Member and Observer Countries have adapted digital services in legal migration procedures to ensure accessibility and inclusion for applicants with disabilities and digitally disadvantaged applicants. It examined compliance with relevant EU and international frameworks, as well as national legislation. It also explored additional accessibility measures, support for users with special needs, GDPR safeguards, user involvement in service design, and approaches to digital disadvantage, alongside challenges and good practices identified by countries.
Background:
The European Migration Network, following a vote by its Steering Board, decided to develop an Inform on "Bridging the digital divide: Digital services in legal migration procedures for accessibility and inclusion", as part of its 2025 work programme. The aim of this Inform was to map national approaches to ensuring accessibility and inclusion in the use of digital services in legal migration procedures for applicants with disabilities and digitally disadvantaged applicants. To gather reliable and up-to-date information for drafting the Inform, this ad hoc question was issued.
Respondents:
25 EMN Member and Observer Countries (including BE) provided a public answer to this ad hoc query.
Findings:
A preliminary analysis of the results of the ad hoc query shows that:
- Most responding EMN Member and Observer Countries have adapted digital services in legal migration procedures to accessibility requirements set out in EU and international frameworks, including Directive (EU) 2016/2102, the European standard EN 301 549 and the UNCRPD, although the extent of implementation varies across countries.
- The level of digitalisation of legal migration procedures differs significantly between countries, with most systems remaining hybrid and still requiring in-person steps such as biometric data collection, identity verification or the submission of original documents.
- Only a limited number of countries directly involve applicants with disabilities or digitally disadvantaged applicants in the development and testing of digital services, with most relying instead on indirect feedback mechanisms.
- Countries reported a range of challenges in ensuring accessible and inclusive digital services, including technical constraints linked to existing systems, limited digital literacy among applicants, and difficulties in user testing with persons with disabilities.
For concise and comparative information, please refer to the Inform on the subject. For detailed country-specific information, please consult the compilation of responses attached above.
