Is the draft EU Directive welcomed?
39. The draft Directive is extremely welcome and it is particularly positive that it is a single Directive extending to all the grounds, and not disability alone, as was mooted at one point. It is important that there is consistency and coverage across all the discrimination grounds. 40. Whilst it is extremely positive that there will be some consistency of approach across Europe in relation to disability discrimination, there are nevertheless some areas of the Directive which are of concern. 41. These are in particular; no addressing of the definition of disability the relatively broad justification for discrimination by insurance providers no requirement to provide alternative methods of service effect of Article 4(3) that the Directive is without prejudice to European community and domestic rules covering goods and services no mention of accessibility of manufactured goods 42. In addition, there is no protection for multiple discrimination, a subject to which we will return below. D