The Commission considers that in this particular case it is justified to ask Member States to communicate explanatory documents to the Commission in order to clarify the relationship between the provisions of this Directive and the corresponding parts of national transposition documents.
National legislation and its implementation in the field of accessibility is challenging due to the great variation of the legal traditions in the different Member States, for example some Member States regulate accessibility under anti-discrimination law, others under disability law, others under sector-specific legal instruments. In addition, this Directive covers accessibility requirements for a selected list of products and services. It therefore contains a wide variety of legal obligations.
The Directive's implementation will require the amendment of various branches of the national legal order in the Member States. Its provisions will be transposed through amendments to national rules, laws, regulations and administrative provisions. It is likely that the implementation will not only concern the central/national level of legislation in the Member States, but touch different levels of regional and local legislation. The transposition at national level is therefore indeed expected to be scattered throughout the national legal order.
For these reasons the Commission considers that explanatory documents accompanying the notification of transposition measures will be essential to understand fully the national transposition process. Against this background it is proportionate to ask Member States to take on the administrative burden of providing explanatory documents in order to achieve the objective of putting the Commission in a position to carry out its task of overseeing the transposition of this cross-cutting Directive, which is central to the EU measures on accessibility.