Dr. Emer Begley:

I extend our thanks to the Chair and committee members for the invitation to attend in order to discuss this important topic. We welcome the committee's consideration of the general scheme. The Disability Federation of Ireland, DFI, is a pan-disability federation. We have over 100 member organisations. We work with our members to support the implementation of the UN Convention on the Rights of People with Disabilities and are guided by values that reflect the rights, dignity and lived experience of disabled people. We believe in a society that values every person equally.

People with disabilities face many practical disadvantages. They are less likely to be in paid employment and are significantly more likely to live in poverty or to be at risk of poverty, in part due to the considerable additional daily costs that come with having a disability. Structural barriers impact opportunities for inclusion, so any reform of equality legislation is timely. DFI notes the progressive elements of the proposed Bill, as already mentioned, such as head 8, which relates to the removal of provisions that allow employers to pay people with disabilities lower wages compared with other employees in the same position. Disabled people often experience multiple forms of intersectional discrimination. We join others in the call for the addition of the tenth ground, socioeconomic status, particularly as this is an area in respect of which people with disabilities are more likely to face additional discrimination in light of the high proportion who experience poverty.

The current definition contained in the Equal Status Act and the Employment Equality Act is not in line with the model of disability expressed in the UNCRPD. It is medically focused and uses negative and derogatory language. Ireland requires a definition that embraces a social model which asserts that people are disabled not just by physical aspects of their disability but by social barriers that exclude them. Such a definition would be in line with current thinking, would reflect a rights-based approach and would further support our implementation of the UNCRPD.

Another important provision is the expansion, under head 14, of the undue burden standard of reasonable accommodation. A failure to accommodate customers is not the biggest challenge people with disabilities face. The Equal Status Act allows insurance companies to charge disabled people higher premiums in some cases. This has resulted in people being unable to secure mortgages due to the high cost of life assurance or as a result of not being granted approval. Others financial barriers are experienced in the form of higher travel insurance costs. Some people have lost job opportunities due to higher employer insurance.

Many of the provisions in the general scheme relate to complaints to the WRC. These are positive, but, again, there is a failure to address barriers that prevent people with disabilities from accessing the WRC in the first place. These include complicated online procedures and paperwork, with limited support and accommodation for filing available. In addition, the lack of free legal aid adds further a further cost, which, in turn, adds to the cost of disability experienced by people.

The DFI believes these changes would move towards a more equal society for disabled people and strengthen our equality framework. However, it is only one step and further work needs to be done for Ireland to fully ratify the UNCRPD. I thank the committee again for the opportunity to contribute. We are happy to take any questions.