Cost of Disability Payment Consultation Submission

Published April 2026
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An overview of ODI’s recommendations included in our submission to the Department of Social Protection’s public consultation on a cost of disability payment.  

The Open Doors Initiative (ODI) welcomed the opportunity to contribute to the Department of Social Protection’s public consultation on the introduction of a Cost of Disability (COD) Payment.

Our submission advocates for a permanent, non-means-tested Cost of Disability payment that recognises the additional costs faced by disabled people and supports their full participation in society, education and employment. The additional annual cost of living with a disability is estimated at €11,500–€16,284. ODI emphasises that the payment should be based on a social model of disability and human rights approach, rather than traditional medical assessments.

Key Recommendations in Our Submission

• Introduce a permanent, non-means-tested Cost of Disability payment that is decoupled from employment status.
• Ensure payments are based on individual need and additional costs rather than a flat-rate approach.
• Adopt a whole-of-government implementation model supported by a stakeholder advisory committee.
• Embed the social model of disability and a human rights-based approach.
• Use the Minimum Essential Standard of Living (MESL) framework to determine payment levels and adjust for inflation.
• Simplify eligibility and application processes, minimising repeated assessments and excessive documentation.
• Allow alternative forms of evidence and ensure all application systems are fully accessible.
• Ensure the payment complements, rather than replaces, existing disability services and supports.
• Launch a public awareness campaign to improve understanding of disability-related costs and reduce stigma.
• Establish ongoing review and feedback mechanisms involving disabled people and representative organisations.