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INTERNAL MARKET FOR INCLUSIVE AND ASSISTIVE ICT ATIS4ALL Sebastiaan van der Peijl Madrid, 14 March 2011

Internal Market for Inclusive and Assistive ICT_Sebastiaan van der Peijl_Deloitte

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Presentation about Internat Market for Inclusive and Assistive ICT by Sebastiaan van der Peijl (Deloitte). ATIS4all First Workshop, 14th and 15th March, 2011. Madrid.

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Page 1: Internal Market for Inclusive and Assistive ICT_Sebastiaan van der Peijl_Deloitte

INTERNAL MARKET FOR INCLUSIVE AND ASSISTIVE ICT

ATIS4ALL

Sebastiaan van der PeijlMadrid, 14 March 2011

Page 2: Internal Market for Inclusive and Assistive ICT_Sebastiaan van der Peijl_Deloitte

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Contents

Aims and objectivesScopeApproachEU policy contextMain findings of the studyConclusionsRecommendations

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Aims and objectives

Main research question:“What are the main barriers and opportunities today in the European Internal Market for Assistive

ICT, and what could be gained in terms of economic and social impacts derived from addressing barriers and embracing opportunities in the market for Assistive ICT?”

Tasks:– Gather representative evidence on the market for Assistive ICT products and services in

Europe, including market mechanisms.– Analyse barriers and opportunities in relation to social and economic impact associated

with the use of Assistive ICT, including the impact for users, the Assistive ICT industry and the administrations.

– Propose recommendations for improvement, building on the advice of experts and relevant stakeholders.

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Scope

9 Member States: ES, DE, DK, FR, IT, LV, NL, SE, UKAssistive ICT:

External Assistive ICT

Independent Living

Work

Education & Training

ICTAccessible

ICT

Embedded Assistive ICT

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Approach

Extensive desk researchMS and EU level interviewsCase StudiesScenarios

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EU policy contextUN convention: signed and ratified by the EU, signed by all MS (ratified by 16), protocol signed by 22 MS (ratified by 14)

European Disability Strategy (2010-2020): equal rights, dignity, treatment, independence, full participation

– Accessibility: improving the availability and choice of assistive technologies, public procurement

– Participation: e.g. use of sign language, Braille, accessible websites and copyrighted works, etc.

– Employment, education, independent living, health: focus on sound working conditions, personal-assistance schemes, legal and organisational barriers, inclusive education, non-discriminatory health services and facilities, disability part of curricula of health professionals

– MS cooperation: information exchange and policy coordination (High Level Group on Disability)

– Awareness raising and data collection

European Accessibility Act in 2012?– To substantially improve the proper functioning of the internal market for accessible

products and services

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EU policy context

Digital Agenda– Enhancing digital literacy, skills and inclusion– Inclusive digital services, web accessibility, ambient assisted living

e-Inclusion: e-Accessibility– Ensure that people with disabilities and elderly people can access ICTs

on an equal basis with others

e-Accessibility and Assistive Technology (AT):– Design for All: universal design, adaptive design,

interfacing/interoperability with AT– Public procurement & Mandate 376

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Provision of assistive ICT in the EU The market for assistive ICT

No recent and consistent data on people with a disability on the EU level (only 2002 LFS Eurostat)No quality data on take-up of ICT by people with a disability (some MS-data)No quality data on take-up of assistive ICT (some studies (MEAC, AEGIS))Little data on public expenditure on Assistive ICT (some data in e.g. NL GIPdatabank)No consistent data on the assistive ICT supply (only national databases)

Romania

Italy

Slova

kia

Lithuan

iaMalt

aSp

ain

Greece

Irelan

d

German

y

Hungary

Luxe

mbourg

Cypru

s

Austria

EU 25

Norway

EU 15

Belgium

Slove

nia

Denmark

Portuga

l

Swed

en

Czech Rep

ublic

Estonia

France

Netherl

ands

United Kingd

om

Finlan

d0.05.0

10.015.020.025.030.035.0

Disability prevalence rates across countries

Source: EUROSTAT

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Provision of assistive ICT in the EU The market for assistive ICT (public) service

provider

Manufacturers / distributors

People with a disability

Disability organisations

(e.g. associations, charities, NGOs,

etc)

Source: Robotiker–Tecnalia, 2009

Different actors involvedGov support schemes implemented by (public) service providers: Service Deliver Models (SDM)SDMs play an important role in the value chain: financing and procurement.

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Provision of assistive ICT in the EU Service Delivery Models

Different types of SDM:– Medical / social model:

• Service providers act as intermediaries• People with a disability are generally not the final

decision makers

– Consumer oriented model:• Service providers act as advisor and funding provider• People with a disability, or a representative, are the

final decision makers

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The most prevailing type of SDM is the medical/social modelFreedom of choice: often none (limited to lists), but more freedom of choice schemes are being implemented (e.g. DE, DK, NL, SE)SDMs have an important influence, they are the main buyers on the market

Provision of assistive ICT in the EU Service Delivery Models

Education Work Home/independent living

Denmark M/S Mixed: M/S, C Mixed: M/S, CFrance M/S Mixed: M/S, C Mixed: M/S, CGermany Mixed: M/S, C Mixed: M/S, C Mixed: M/S, CItaly M/S M/S M/SLatvia M/S, limited * M/S, limited * M/S, limited*The Netherlands

M/S M/S Mixed: M/S, C

Spain M/S M/S M/S or noneSweden Mixed: M/S, C M/S Mixed: M/S, CUnited Kingdom

M/S M/S M/S

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Provision of assistive ICT in the EUA complex reality…

Government support differs widely across MS and life environments, even regions:

– different beneficiary types, different actors involved, differences in prescription or reimbursement processes, different types of procurement, different governance models (more or less decentralised), different levels of coverage (ranging from full reimbursement models to none, depending on the country/region), differences in eligible products...

Overlaps between the different systems across the life environments can result in unclear responsibilitiesDisabled people face a complex environmentAssistive ICT companies similarly face a complex environment

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Provision of assistive ICT in the EUA complex reality…The market structure for Assistive ICT can be characterised by ‘supply push’: companies compete to get in the SDM system, lower attention to end-users

Some key dimensions emerged and were addressed through case studies

People with a disability

Manufacturers / Distributors

of Assistive ICT

Service Delivery Models

Supply push

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Provision of assistive ICT in the EUImportant trends / opportunities

In the work environment, support schemes are usually well defined, supported by the focus on reasonable accommodationFreedom of choice schemes are on the rise, either with a reimbursement or personal budget scheme (e.g. DE, DK, NL, SE)Function vs. Form debate: functional descriptions of products eligible for funding (e.g. NL, SE)Many organisations are active in the MS to provide information and advice to people with a disabilitySingle points of access are hardly established, with exceptions in e.g. DE, FR

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Provision of assistive ICT in the EUMain findings

Different levels of coverage

Different actors in the

life environments

Localised MarketsLong supply chains

Limited cross border trading within the Internal

Market

Non-transparent pricing, can lead to high prices and

price differences

De facto restrictions on market entry Small production volumes

High investment for market entry

In some cases: high margins

Different types of support

Supply: Company perspective

Demand: End-user perspective

High efforts to get access to funding and the right

solutions

Limited choice

Lack of information / independent advice

Need to work through local distributors or local

presence

Difficulties with overlap in different life environments

Service Delivery Models

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Case studies

Main findings from the case studies2 Case studies on

freedom of choice (DE, SE)

2 Case studies on info provision(ES, UK)

1 Case study on internet and mobile uptake

1 Case study on pricing of assistive ICT

1 Case study on product and cross-border activity

Freedom of choice turns people with a disability into decision makers and stimulates the market.

Information is key to a successful implementation of a freedom of choice scheme. Information will increasingly be provided by manufacturers themselves, government will also have a role to play.

Stark differences across Europe. High market potential for assistive ICT

Price differences occur within the internal market, due to complex supply chains and other factors

Most EU assistive ICT companies do not operate cross border and are highly specialised, targeting niche segments of the market

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Case Studies (1/7)

Freedom of choice in Sweden (Fritt Val)– User empowerment:

• Better informed, better choices• Function vs. form

– Stimulating the market: • Closer relations with the customer• Bundling: services and extra features• Price reduction

– At no additional cost

Potential for: more user focus, better information provision, more competition.

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Case Studies (2/7)

Freedom of choice in Germany (Persönliches Budget)– Public agencies:

• Fear of loosing control over: the system, the quality, type of fundable devices

• Higher administrative costs• Non-standardised admin procedure and faulty

individual target agreements

– Stimulating the market: new user group expected to emerge, more competition and innovation

Transition issues, but expected to grow

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Case Studies (3/7)

Information provision by local charities in the UK– The need for: ‘good information’, close customer relationships,

services close to the user (e.g. assessment, training)– Local charities:

• Information provision, awareness, try out ATs, conferences, exhibitions

• Geographically close to users, no registration required• Support informed decision making: both for occupational therapists

and end-users• Provide ‘second-tier’ assessment and training to meet specific needs• Established networks with: suppliers, agencies, technology

networks, education& training inst. / employers, end-users

Filling the gap: enabling blind people, market facilitation

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Case Studies (4/7)

Information provision by RETADIS in Spain– Try out assistive ICT:

• 26 centers throughout Spain with computers and assistive ICT + 50 private home-users

• RETADIS social network: contact with peers, forums, newsletters

• Training by occupation therapists and for education and work

Bringing together stakeholders, manufacturers, end-users, occupational therapists for better information and hands-on experience

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Case Studies (5/7)

Product pricing of Assistive ICT– CNSA, AT price-monitoring agency

• Issues: complexity of use, prices differences, difficulties for new entrants, knowledge of professionals

• Recommendations: information sharing between beneficiaries and distributors, showrooms and regional centers, include training in public funding

– Non-transparency is a big issue

Opportunities for improvement– Need for product reviews– Separation of services from product pricing– e-Commerce provides transparency– towards a more Consumer Oriented Model

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Case Studies (6/7)

Assistive ICT supply– Based on 8 National Databases (810 Assistive ICT companies)– Available information is inconsistent across databases– The analysis adds insight, but the market remains opaque

Fragmentation: narrow markets, mostly SMEsNumber of ISO subcategories per company (total sample)Average ISO groups per company 1.523

Companies with 8 ISO groups 3

Companies with 7 ISO groups 3

Companies with 6 ISO groups 13

Companies with 5 ISO groups 10

Companies with 4 ISO groups 22

Companies with 3 ISO groups 47

Companies with 2 ISO groups 120

Companies with 1 ISO group 592

Total number of companies in sample 810Total Number of assistive ICT companies in the overall sample per ISO 22 subcategory(multiple presence of companies possible)

ISO 22.03

ISO 22.06

ISO 22.09

ISO 22.12

ISO 22.15

ISO 22.18

ISO 22.21

ISO 22.24

ISO 22.27

ISO 22.30

ISO 22.33

ISO 22.36

ISO 22.39

126 16 9 65 12 57 155 252 67 79 28 371 135

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Case Studies (6/7)

Origin of foreign companies per countryCountries of origin of foreign companies

Database

DE DK ES FR IT NL SE UK US Others Foreign companies

DE - 1 2 1 2 2 4 8 27 11 58DK N/A - N/A N/A N/A N/A N/A N/A N/A N/A N/AES 1 0 - 1 0 0 0 1 1 1 5FR 10 2 1 - 2 4 4 12 30 26 91IT 10 1 3 7 - 5 6 15 42 19 103NL N/A N/A N/A N/A N/A - N/A N/A N/A N/A N/ASE N/A N/A N/A N/A N/A N/A - N/A N/A N/A N/AUK N/A N/A N/A N/A N/A N/A N/A - N/A N/A N/A

Little cross border presence:International presence of assistive ICT companies in the sample (8 countries)Average presence of companies (number of countries in sample)

1.162

Companies with presence in 5 countries 2

Companies with presence in 4 countries 8

Companies with presence in 3 countries 26

Companies with presence in 2 countries 48

Companies with presence in 1 countries 726

Total number of companies in sample 810

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Case Study (7/7)

Estimating demand for Assistive ICT– Lack of data on both the PWD population and the

take-up of Assistive ICT

Assessment of internet and mobile phone uptake: 1. Estimation of PWD population2. Estimation of internet uptake3. Estimation of assistive ICT uptake

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Case Study (7/7)

Methodology: estimating internet uptake for PWDs

0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.90

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

f(x) = 0.0534130706013989 exp( 2.99839594437232 x )R² = 0.972246698921777

Exp.function fitting

PWDExponential (PWD)

General population

PWD

popu

latio

n

Austria

Belgium

Bulgaria

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

SloveniaSpain

Sweden

United Kingdom

y = 0.0534e2.9984x

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

Fitted

value

s for

PWDs

uptak

e

General population uptake

exp fitted values

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Case Study (7/7)

Methodology: internet uptake rates for PWDs

00.10.20.30.40.50.60.70.80.9

Au

stri

aB

elg

ium

Bu

lgar

iaC

ypru

sC

zech

Re

pu

blic

De

nm

ark

Esto

nia

Fin

lan

dFr

ance

Ge

rman

yG

ree

ceH

un

gary

Ire

lan

dIt

aly

Latv

iaLi

thu

ania

Luxe

mb

ou

rgM

alta

Ne

the

rlan

ds

Po

lan

dP

ort

uga

lR

om

ania

Slo

vaki

aSl

ove

nia

Spai

nSw

ed

en

Un

ite

d K

ingd

om

EU-2

7

internet uptake rate forPWDs in the EU (2009)

0.00

0.10

0.20

0.30

0.40

0.50

0.60

Au

stri

a

Be

lgiu

m

Bu

lgar

ia

Cyp

rus

Cze

ch R

ep

ub

lic

De

nm

ark

Esto

nia

Fin

lan

d

Fran

ce

Ge

rman

y

Gre

ece

Hu

nga

ry

Ire

lan

d

Ital

y

Latv

ia

Lith

uan

ia

Luxe

mb

ou

rg

Mal

ta

Ne

the

rlan

ds

Po

lan

d

Po

rtu

gal

Ro

man

ia

Slo

vaki

a

Slo

ven

ia

Spai

n

Swe

de

n

Un

ite

d K

ingd

om

EU-2

7

Internet use age group 65-74 (2009)

uptake 65-74

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Case Study (7/7)

Methodology: assistive ICT uptake rates for PWDs

0

500000

1000000

1500000

2000000

2500000

3000000

Austr

iaBe

lgium

Bulga

riaCy

prus

Czec

h Rep

ublic

Denm

ark

Esto

niaFin

land

Fran

ceGe

rman

yGr

eece

Hung

ary

Irelan

d Italy

Latvi

aLit

huan

iaLu

xemb

ourg Malt

aNe

ther

lands

Polan

dPo

rtuga

lRo

mania

Slova

kiaSlo

venia Spain

Swed

enUn

ited K

ingdo

m

PWDs using assistive ICTs to access the internet

assistive ict use pwds 15-64

assistive ict use pwds 65+

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Case Study (7/7)

Methodology: assistive ICT uptake rates for PWDsMain results:– Estimation of more than 29 million disabled people

using internet in the EU in 2009• 21 million aged 15-64, • 8 million aged above 65

– Estimation of 9.86 million EU citizens already using assistive ICT to access the internet in the EU

– Large existing disparities in uptake, especially for old people

– Internet uptake is increasing fast

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Scenarios

Conceptual framework Freedom of choice

Awareness and information

Level of competition in the assistive ICT market

Competitive pricing

Demand:informed and empowered consumers

Supply: competitive supply of assistive ICT

Supplypush

Demandpull

Supp

ly

Demand

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Demand: informed & empowered usersFreedom of choice & information, awareness

Freedom of choice, drivers– User empowerment– Role of SDM– Functional description of needs– Mainstreaming– e-Commerce

Awareness and information, drivers:– Digital literacy– Close relationship with consumers– Multi-stakeholder approach– Independent information / advice– Training

Freedom of choice

Awareness and information

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Supply: competitive supply of A-ICTLevel of competition & pricing

Competition, drivers:– Transparency– Competition IN the market not FOR the market– Barriers within the market– e-Commerce

Pricing, drivers:– Transparency– Supply chain– Comparing– Knowing what you pay for

Level of competition in the assistive ICT market

Competitive pricing

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Demand and supplyDemand pull and supply push growth

Demand: informed and empowered consumers

Supply: competitive supply of assistive ICT

Supply push

Demand pull

Freedom of choice

Awareness and information

Level of competition in the assistive ICT market

Competitive pricing

Demand

Sup

ply

Scenario 4:Large scaledemand pull

Scenario 1: supply push

Scenario 2: supply push with increased awareness

Scenario 3: small scale demand pull

Scenario 4: large scale demand pull

Freedom of choiceLimited increase Limited increase High Fully available

Information & awareness Limited increase Increased High Fully aware

CompetitionIncrease,

Reduced marginsIncrease Increased High

Competitive pricing Minor changes Increased Increased High

Scenario 1Scenario 2Scenario 3Scenario 4

Demand: informed and empowered consumers

Supply: competitive supply of assistive ICT

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Toward a consumer oriented market

User empowerment, more transparent market, closer customer relations, more cross-border trade, changing the role of SDMs

People with a disability

Manufacturers / Distributors

of Assistive ICT

Service Delivery Models

Demand pull

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Forecasting exerciseImpact on the market

Based on internet uptake:

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Forecasting exercise Impact on the market

Impact on internet uptake

2010 2012 2014 2016

Austria 561,325 853,393 1,124,505 1,338,905Belgium 1,086,415 1,564,422 1,963,778 2,269,527Bulgaria 230,744 449,159 731,082 1,007,122Cyprus 24,904 49,783 79,102 107,503Czech Republic 742,025 1,198,437 1,665,558 2,047,361Denmark 869,481 1,070,888 1,208,964 1,267,217Estonia 134,847 198,362 256,355 301,029Finland 1,066,818 1,359,316 1,591,930 1,726,066France 6,375,984 9,427,246 12,378,853 14,836,371Germany 6,838,776 9,610,234 11,755,177 13,241,029Greece 212,728 415,706 717,307 1,058,091Hungary 397,629 672,632 984,222 1,260,813Ireland 223,826 370,360 514,965 637,203Italy 1,149,297 2,518,188 4,208,465 5,883,910Latvia 136,433 218,188 296,378 360,048Lithuania 94,242 173,014 256,638 332,397Luxembourg 51,304 64,742 75,050 80,810Malta 16,160 27,925 40,385 50,859Netherlands 3,399,454 4,018,832 4,367,321 4,478,640Poland 1,847,128 3,167,317 4,588,220 5,836,980Portugal 452,116 877,234 1,388,599 1,868,047Romania 211,264 496,229 908,198 1,380,916Slovakia 239,376 356,324 474,583 577,287Slovenia 133,338 218,181 305,834 379,787Spain 1,593,669 2,892,120 4,283,536 5,528,850Sweden 1,620,299 1,940,472 2,130,547 2,201,595United Kingdom 11,251,668 14,441,832 16,753,777 18,017,768European Union (27 countries) 35,867,061 57,509,219 76,765,969 91,506,917

2010 2012 2014 20160

10,000,00020,000,00030,000,00040,000,00050,000,00060,000,00070,000,00080,000,00090,000,000

100,000,000

EU 27, estimated internet uptake by PWDs

European Union (27 coun-tries)

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Forecasting exerciseImpact on the market

Impact on assistive ICT usage

2010 2012 2014 2016

Austria 190,851 290,154 382,332 455,228Belgium 369,381 531,903 667,684 771,639Bulgaria 78,453 152,714 248,568 342,421Cyprus 8,468 16,926 26,895 36,551Czech Republic 252,289 407,468 566,290 696,103Denmark 295,624 364,102 411,048 430,854Estonia 45,848 67,443 87,161 102,350Finland 362,718 462,167 541,256 586,863France 2,167,835 3,205,264 4,208,810 5,044,366Germany 2,325,184 3,267,480 3,996,760 4,501,950Greece 72,328 141,340 243,884 359,751Hungary 135,194 228,695 334,635 428,676Ireland 76,101 125,922 175,088 216,649Italy 390,761 856,184 1,430,878 2,000,529Latvia 46,387 74,184 100,768 122,416Lithuania 32,042 58,825 87,257 113,015Luxembourg 17,443 22,012 25,517 27,475Malta 5,494 9,495 13,731 17,292Netherlands 1,155,814 1,366,403 1,484,889 1,522,738Poland 628,023 1,076,888 1,559,995 1,984,573Portugal 153,719 298,260 472,124 635,136Romania 71,830 168,718 308,787 469,512Slovakia 81,388 121,150 161,358 196,278Slovenia 45,335 74,182 103,983 129,128Spain 541,847 983,321 1,456,402 1,879,809Sweden 550,902 659,761 724,386 748,542United Kingdom 3,825,567 4,910,223 5,696,284 6,126,041European Union (27 countries) 12,194,801 19,553,134 26,100,429 31,112,352

2010 2012 2014 20160

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

EU 27, estimated assistive ICT use

European Union (27 coun-tries)

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Forecasting exerciseImpact on the market

Estimates are based on assumptions and are projected in accordance with the S-curve of the NetherlandsActual internet take-up developments depend on many exogenous factors, such as general development of internet connections (infrastructure), digital literacy, etc.Yet, this analysis shows the expected direction, although country specifics should be taken into accountThis also shows that currently there is a large unexploited market potential

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Conclusions The impact of the role of government

Public procurement: – Can reduce cost (e.g. volume contracts) – But leads to competition FOR the market not IN the

market: i.e. market distortion– Result: a heterogeneous EU Market (mainly local markets),

limited economies of scale for producers, limits incentives for R&D and investment

Information provision:– Training of professionals in the SDM is essential– End-user should be aware and well informed

Funding:– Uneven across MS, as well as prices paid by the SDM

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ConclusionsFunction vs Form

Away from ‘positive lists’ of eligible products…– Keeping positive lists up-to-date is cumbersome or

simply not happening (e.g. IT)– It can take a lot of time for new products to become

‘eligible’

…towards a function based approach (with possibly a ‘negative list’)– A function based approach opens up opportunities

for new products, innovation– A function based approach enables choice and user

empowerment

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ConclusionsTowards a Consumer Oriented Model

Empower people with a disability: decision makersEncourage interaction between companies and end-users: closer customer relationships, more information aimed at people with a disability (direct marketing, try-out sessions)Scope for reduced prices (e.g. SE)Mentality change: SDM becomes principally advisor and funding providerSingle access points, across life environments

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ConclusionsDemand

Information provision: essential for professionals and end-users, the internet offers important opportunities (e-Commerce, product reviews, etc)Empowerment: more focus on desirable products (less stigma)Training: also essential for both end-users and professionalsMaintenance, upgrades: clear rules are needed

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ConclusionsSupply

Market fragmentation: mostly local markets, small companiesLack of transparencyDistributors are essential today for local market accessLong supply chains: high pricesFocus on SDM reduces consumer orientationMore consumer orientation opens possibilities for: – easier market access– more competition– lower prices– potentially better after sales services– e-Commerce– more information aimed at the end-user– increased economies of scale and incentives to invest and conduct R&D– mainstreaming: accessible mainstream solutions become attractive

alternatives, incentives for Design for All

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ConclusionsData availability

There is a general lack of statistics– People with a disability: wide divergence due to different applied

definitions across MS, lack of cross-country comparable data– Use of ICT and assistive ICT: only ad-hoc national measurements– Supply of assistive ICT: definition of assistive ICT: ISO 9999 Cat 2? EU

NACE has no classification for A-ICT, resulting in lack of data

Demand SupplyDemographics -> uptake

Prevalence of disability Work, Education, Independent Living:

nr of PWD (un)emplyment rate, supported employment

nr of PWD in mainstream/special education, educational attainmentnr. of PWD living independently

Uptake of Information and Communication Technology by PWD(only available in some countries)Uptake of Assistive ICT by PWDExpenditure (public and private)-not available at the granular level of assistive ICT

Market information -> market structure

Nr of companiesMarket share (e.g. sales / turneover)Pricing and profitabilityLevel of competitionDistribution channels

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Recommendations

Shaping a more competitive and better functioning market for assistive ICTImprove the availability of data:– common and consistent definition and measurement of people

with a disability and their use of ICT and assistive devices– need for granular data on MS expenditure– need for an extensive survey at an EU level– a common taxonomy of assistive ICT

Fine-tune the role of government: – consumer oriented, empower the end-user, freedom of choice– provision of independent information and advice– a common functional list for Europe– establish single access points

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