Request for an EU Regulation Explicitly Guaranteeing the Right to Analogue (Non-Digital) Access to Essential Services

PETITION TO THE EUROPEAN PARLIAMENT

Submitted by:
Europeans for Safe Connections, ESC,VZW

Non-Governmental Organisation (NGO)
Representing approximately 30 European organisations and more than 10,000 members across the European Union

www.esc-info.eu

NGO established in Belgium
Contact information: Charlotte Ryø,

Date: January 21, 2026

Subject of the Petition

We – Europeans for Safe Connections – respectfully request that the European Parliament urge the European Commission to propose a Regulation establishing an explicit and enforceable Right to Analogue Access for all EU citizens and residents, ensuring that no individual is compelled to use digital tools, smartphones, mobile applications, or mandatory digital identification systems in order to access essential public or private services.

This petition is submitted by a European non-governmental organisation representing approximately 30 member organisations across the EU and more than 10,000 individuals. Our members include vulnerable persons and individuals affected by electromagnetic hypersensitivity (EHS), disabilities, age-related limitations, health conditions, and other circumstances that make the use of mandatory digital technologies difficult or impossible.

The issues raised in this petition directly and materially affect our members’ ability to access essential services on equal terms, and therefore fall squarely within the scope of admissible petitions under Article 227 TFEU.

This request is fully within the competences of the European Union as established by the Treaty on European Union (TEU) and the Treaty on the Functioning of the European Union (TFEU).

Legal Basis for Admissibility (Treaty References)

1. Article 10 TEU — Representation of citizens
   The Union shall be founded on representative democracy and ensure that citizens’ concerns are taken into account, including in the context of digital transformation.
2. Article 11 TEU — Participatory democracy
   Citizens and representative associations have the right to make known their views and to petition the EU institutions.
3. Article 16 TFEU — Protection of personal data
   The EU has explicit competence to ensure protection of personal data, including the right to avoid unnecessary or disproportionate digital data processing.
4. Article 114 TFEU — Internal market regulation
   The EU may harmonise rules necessary for the functioning of the internal market, including non-discriminatory access to essential private-sector services such as banking, telecommunications, insurance, energy, and transport.
5. Article 169 TFEU — Consumer protection
   The Union shall promote the interests of consumers and ensure a high level of consumer protection, including for vulnerable groups affected by digital-only access models.
6. Article 19 TFEU — Anti-discrimination
   The EU may take appropriate action to combat discrimination based on disability, age, and other relevant factors exacerbated by mandatory digitalisation.
7. Article 26 TFEU — Free movement and citizenship rights
   Access to public services and the effective exercise of EU citizenship rights must not be impaired by compulsory digital systems.

These treaty provisions establish that the EU is competent to legislate in areas affecting fundamental rights, digital services, internal market fairness and accessibility of essential services.

Background and Purpose of the Petition

Across the European Union, public authorities and essential private service providers increasingly adopt digital-only systems, without providing equivalent non-digital alternatives, requiring:

• smartphone ownership
• mandatory mobile applications
• digital identity systems
• app-based authentication
• online-only customer service
• digital-only forms, communication, or billing

While digitalisation brings clear benefits, digital-only systems exclude millions of EU citizens, including many of our members, such as:

• elderly persons
• persons with disabilities
• individuals affected by electromagnetic hypersensitivity (EHS)
• persons with health conditions aggravated by wireless or digital technologies
• individuals without smartphones or reliable internet access
• low-income citizens
• persons living in rural or remote areas
• individuals with legitimate privacy or data-protection concerns

This results in systematic exclusion through the removal of meaningful choice, undermining equality, accessibility, consumer protection and data protection principles established by EU law.

Existing EU Legal Framework (with references)

Despite the European Union’s strong framework for fundamental rights, EU law does not explicitly recognise or guarantee a right to analogue (non-digital) access to essential services. Any protection against digital-only service provision must therefore be derived indirectly from a combination of legal instruments, creating legal uncertainty and inconsistent application.

1. EU Charter of Fundamental Rights

• Article 21 – Non-discrimination
• Article 26 – Integration of persons with disabilities
• Article 41 – Right to good administration
• Articles 51–52 – Scope and proportionality

Digital-only systems disproportionately exclude vulnerable groups, including persons unable to use mandatory digital tools, thereby undermining these rights.

2. GDPR (Regulation (EU) 2016/679)

• Article 7 – Consent must be freely given
• Article 5(1)(c) – Data minimisation

Where access to essential services is conditional on digital consent and no genuine analogue alternative is offered, individuals have no meaningful choice. In such circumstances, consent cannot be regarded as freely given, and individuals are compelled to accept digital data processing even where less intrusive analogue alternatives would suffice.

3. European Accessibility Act (Directive (EU) 2019/882)

Requires accessible services and alternative solutions where digital access is not possible.

4. Digital Decade Policy 2030

Explicitly states:
“Digital-by-default must not become digital-only.”
However, this remains political guidance and is not legally binding, therefore the need fort a Regulation.

5. eIDAS Regulation (EU) 910/2014

Requires preservation of non-electronic access in specific contexts, but does not address the broader and growing problem of digital-only access to essential services.

6. European Parliament Resolution of 17 December 2025 (2025/2080 (INL)

The European Parliament has affirmed that new technologies must be deployed with a human-centric, ethical-by-default and precautionary approach, serving people as an overarching objective.
The recognition of a right to analogue (non-digital) access to essential services is consistent with this principle and helps ensure that digitalisation does not lead to exclusion or indirect discrimination.
While not legally binding, this resolution constitutes a formal expression of the European Parliament’s political position and legislative expectations, adopted under Article 225 TFEU.

Conclusion:

There is currently no explicit EU-level right to analogue access, leaving millions of citizens — including our members — exposed to exclusion.

Problem Identified

Digital-only service provision without genuine analogue alternative is:

• legally inconsistent across Member States
• discriminatory toward vulnerable groups
• incompatible with GDPR principles
• undermining fundamental rights
• creating barriers to essential services
• forcing dependence on private technology platforms
• reducing resilience by eliminating analogue fallback systems

Without EU-level action, digital-only systems will continue to expand, intensifying exclusion and inequality.

Request to the European Parliament

We respectfully request that the European Parliament:

1. Recognise that analogue access is a necessary component of EU fundamental rights in the digital era.
2. Call upon the European Commission to propose a new EU Regulation titled:
   “Regulation on the Right to Analogue Access in Essential Services.”
3. Ensure that such a Regulation includes:

A. Explicit right to analogue (non-digital) access

For all essential public and private services, including banking, healthcare, telecommunications, energy, insurance, transport, and public administration.

B. Prohibition of digital-only service models

No authority or essential service provider may require smartphone apps, mandatory digital IDs, or online-only communication as the sole or unavoidable means of access.

C. Analogue equivalence and meaningful choice

Paper-based, telephone, or in-person alternatives must be:
• valid
• accessible
• effective
• timely
• free of penalties or disadvantages

D. Special protection for vulnerable groups

Including elderly persons, persons with disabilities, low-income individuals, persons with cognitive difficulties, individuals affected by electromagnetic hypersensitivity (EHS), and persons without digital access.

E. Enforcement and monitoring

Member States must report on compliance, and citizens and organisations must have access to effective redress mechanisms.

Conclusion

The EU’s digital transformation must be inclusive, proportionate, and respectful of fundamental rights.

An explicit, binding Right to Analogue Access is urgently needed to ensure that no citizen is excluded from essential services due to lack of digital tools, digital competence, or ability to tolerate digital technologies.

We therefore respectfully ask the European Parliament to take up this matter.

Rob van der Boom, Chair of Europeans for Safe Connections

For Europeans for Safe Connections
The Netherlands
January 21, 2026