D-WISE Network. Work inclusive, work wise

The D-WISE Network welcomes the European Commission’s review of the General Block Exemption Regulation (GBER), recognising it as a cornerstone for enabling inclusive employment across the EU. As a key instrument for supporting the employment of persons with disabilities, the GBER has provided legal certainty and financial tools that empower employers to invest in accessibility, reasonable accommodation, and long-term support. Its revision offers a vital opportunity to reinforce the EU’s commitment to equality, inclusion, and the full implementation of the UN Convention on the Rights of Persons with Disabilities.

Persons with disabilities remain among the most underrepresented and disadvantaged groups in accessing quality employment. They continue to face a range of structural, economic, and social barriers that limit their autonomy, financial independence, and full participation in the labour market.

State Aid and the employment of persons with disabilities

The D-WISE Network strongly supports the strategic use of State Aid as a public policy tool to promote high quality employment of persons with disabilities. As reaffirmed in the European Commission’s Disability Employment Package and in the European Commission Study on Alternative models of employment for persons with disabilities, Member States are encouraged to leverage instruments such as the General Block Exemption Regulation (GBER) to foster inclusive labour market—particularly in the context of the green and digital transformations. 

Despite incremental progress, persons with disabilities continue to face systemic barriers to entering and remaining in the labour market. Eurostat data shows that only 54.3% of persons with disabilities aged 20–64 were employed in 2022, compared to 75.7% of persons without disabilities—a gap that widened to 24 percentage points in 2024. These disparities highlight the urgent need for targeted interventions. 

At the same time, the contribution of Work Integration Social Enterprises (WISEs) has been clearly stated in recent EU publications. The Commission’s own Study highlights the contribution of D-WISES for the creation of high-quality employment opportunities for persons with disabilities, stating that they are “characterised by work settings specially designed for persons with disabilities, but it provides workers with disabilities with full employee status including access to minimum wage or compensation determined by collective bargaining, as applicable. The providers are enterprises whose main goal is to integrate persons with disabilities in employment. In many cases, such organisations also employ larger number of persons without disabilities”. The Study also establishes the link between D-WISEs and the social economy: “Work integration enterprises can follow the non-profit social enterprise model, in which case they are referred to as work integration social enterprises (WISEs)”.  

Furthermore, it echoes the conclusions of the General Comment 8 to the UN Convention on the Rights of Persons with Disabilities, stressing that integration companies that are “managed and led by persons with disabilities, including those that are jointly owned and democratically controlled, may not be considered segregated employment if they provide just and favourable conditions of work on an equal basis with others.” This confirms that the employment model promoted by the D-WISE network is fully aligned with Article 27 of the UNCRPD, as well as with other EU policies such as the EU Disability Strategy or the Action Plan on the Social Economy. 

As a pan-European network representing Disability Work Integration Social Enterprises (D-WISEs), we believe our voice must be central in shaping State Aid policy. D-WISEs are not only aligned with the UN Convention on the Rights of Persons with Disabilities (UNCRPD), but they also demonstrate—at scale—how inclusive, rights-based employment models can deliver high-quality jobs, foster innovation, and contribute to social cohesion. With over 146,000 persons with disabilities employed across nearly 13,000 companies, our members exemplify the transformative potential of social economy enterprises. Their experience in delivering accessible, equitable, and increasingly high-tech employment opportunities makes them indispensable stakeholders in the design of future State Aid frameworks. The Commission must ensure that these models are not only recognised but actively supported and scaled through the GBER and related instruments.

Reframing the definition of sheltered employment in the GBER: a call for alignment with inclusive and rights-based models

The General Block Exemption Regulation (GBER) currently defines “sheltered employment” within its framework for State Aid targeting persons with disabilities. While this definition has historically guided Member States and public authorities, it no longer reflects the evolving understanding of inclusive employment under international human rights law and quality employment practices.

The upcoming revision of the GBER offers a crucial opportunity to update this definition in line with the latest interpretation of Article 27 of the UN Convention on the Rights of Persons with Disabilities (UNCRPD), as clarified in General Comment No. 8. This Comment, adopted after the current GBER entered into force, makes clear that traditional sheltered workshop models—those that segregate persons with disabilities from the open labour market—are incompatible with the Convention.

Importantly, General Comment No. 8 also recognizes that inclusive models within the social economy—such as Disability-Inclusive Work Integration Social Enterprises (D-WISEs)—can be fully compliant with Article 27. These models are person-led, democratically governed by persons with disabilities or their representative organisations, ensure equal pay and labour rights, and promote autonomy and inclusion while offering opportunities to transition to the open labour market.

Crucially, the definition of such models should not be based on the percentage of persons with disabilities employed, but rather on whether they are aligned with the UNCRPD, EU and national legislation. The focus must shift from the type of employment to the quality of employment—ensuring that work is dignified, rights-based, and inclusive.

Failing to revise the GBER accordingly risks reinforcing outdated, segregated models. We therefore call on the European Commission to integrate the findings of the Study on Alternative Models of Employment for Persons with Disabilities into the upcoming GBER review. This should include explicit recognition of inclusive models based in the social economy—such as D-WISEs—that reflect the principles of the UNCRPD and EU policy commitments to equality, inclusion, and social justice.

D-WISE Network Policy Recommendations for the Review of the GBER

The D-WISE Network calls on the European Commission to seize the opportunity presented by the review of the General Block Exemption Regulation (GBER) to safeguard and build upon the significant value it has generated in supporting quality employment ventures for persons with disabilities. 

Over the years, the GBER has enabled inclusive enterprises to thrive, providing legal certainty and financial tools that promote accessibility, reasonable accommodation, and long-term employment support. Ensuring the continuity and enhancement of these provisions is essential to foster innovation, social cohesion, and equal participation in the labour market—particularly as Europe transitions toward a more digital, green, and rights-based economy.

1. Preserve Section 6 provisions: The D-WISE Network urges the European Commission to maintain the current exemptions under Section 6 of the GBER, which allow for State Aid to support wage subsidies and additional employment-related costs for persons with disabilities without prior notification. These provisions are essential to ensure timely, flexible, and effective support for inclusive employment models, particularly those aligned with the UN Convention on the Rights of Persons with Disabilities (UNCRPD).
2. Retain distinct aid categories: It is vital to uphold the distinction between State Aid for disadvantaged workers and for workers with disabilities. This separation enables tailored policy responses that reflect the specific rights-based challenges persons with disabilities face, including accessibility, discrimination, and the need for reasonable accommodation. Blurring these categories risks diluting the impact of targeted interventions and undermining the effectiveness of disability-inclusive employment strategies.
3. Ensure alignment with the UNCRPD and EU Disability Strategy: The GBER must be fully aligned with the UNCRPD and the EU Strategy for the Rights of Persons with Disabilities. This includes ensuring that State Aid is directed toward employment models that promote autonomy, equal pay, and inclusive working conditions, like D-WISES. Aid should not be allocated to sheltered workshops that fail to meet these standards.
4. Recognise inclusive alternative employment models like D-WISEs: The D-WISE Network calls for a nuanced approach to sheltered employment. Blanket restrictions risk excluding innovative, rights-compliant models—particularly those owned or managed by persons with disabilities and embedded in the social economy. These models can offer pathways to high-quality, meaningful employment and should remain eligible for support under the GBER.
5. Update the definition of sheltered employment: The GBER should revise its definition of sheltered employment to reflect the interpretation provided in General Comment No. 8 of the UNCRPD. This includes recognising employment ventures that are democratically controlled by persons with disabilities or their representative organisations, and offer just and favourable working conditions on an equal basis with others, such as D-WISEs.
6. Revise financial thresholds to reflect current realities: The financial ceilings set in 2008 no longer correspond to the actual costs of inclusive employment. The GBER must be updated to reflect 2025 price levels, ensuring that State Aid remains proportionate and impactful. This is particularly important for enterprises investing in high-tech solutions, accessibility infrastructure, and long-term support systems.
7. Introduce flexibility across State Aid instruments: Disability-inclusive enterprises often require layered support mechanisms. The GBER should allow for the complementary use of other instruments—such as de minimis aid and Services of General Economic Interest (SGEI) compensation—without creating legal uncertainty. Clear guidance should be provided to Member States on how to combine aid frameworks effectively.
8. Support career development and upskilling: The GBER should explicitly enable State Aid to support retraining, upskilling, and career advancement for persons with disabilities. This includes access to high-quality and potentially high-tech jobs, as well as pathways to leadership and specialised roles. Employment support must go beyond entry-level positions and contribute to long-term social inclusion and economic empowerment.