A/HRC/34/26 services may not yet be developed, reasonable accommodation may function as a means of providing support in a particular case. 35. Similarly, reasonable accommodation should not be confused with procedural accommodations in the context of access to justice, as this would fall short of the full provisions enshrined in the right. During the negotiations on the Convention, the term “reasonable” was intentionally left aside in the framing of article 13. Article 13 requires “procedural accommodations”, which are not limited by the concept of “disproportionate or undue burden”. This differentiation is fundamental, because the right of access to justice acts as the guarantor for the effective enjoyment and exercise of all rights. Failure to provide a procedural accommodation therefore constitutes a form of discrimination on the basis of disability in connection with the right of access to justice. 36. Reasonable accommodation, as seen, plays a bridging role between immediate and progressive obligations. As part of non-discrimination, reasonable accommodation applies immediately to all rights, including economic, social and cultural rights. Secondly, as it may require positive action (with or without cost), it blurs the idea that civil and political rights imply only negative duties, and economic, social and cultural rights only positive duties. From a practical perspective, the systematic implementation of reasonable accommodation contributes to fostering compliance with progressive obligations; for example, the provision of reasonable accommodation as a means to ensure accessibility may benefit others beyond the individual concerned. 2. Elements of the implementation of reasonable accommodation in practice 37. To date, no globally accepted justification has been made of the elements of reasonable accommodation, in particular of what constitutes “undue and disproportionate burden”. Indeed, the evaluation of whether an accommodation is “necessary and appropriate” or imposes an “undue or disproportionate burden” depends on several factors, and the evaluation will differ from case to case. A review of national legislation reveals that certain criteria are used across countries to guide such evaluations. The most commonly used criteria – although only indicative and not to be considered an exhaustive list – are described below. 38. In a comparative analysis, reasonable accommodation has several key elements. A reasonable accommodation must be possible or feasible, from both a legal and a practical perspective (not contrary to the law, and not impracticable). Furthermore, it must be relevant, that is, necessary and appropriate for the exercise of the right on an equal basis with others. It must not constitute a “disproportionate or undue burden” upon the entity responsible for its provision (including from the financial and economical perspectives). It should be noted that reasonable accommodations usually have either a low cost or none at all .26 39. National laws and regulations should provide guidance on these elements and on desirable steps in providing reasonable accommodation. Rights, duties and time frames for each of the parties involved should be clearly stated. States should seek to develop policy guidelines, specific training and awareness-raising activities to disseminate relevant information in order to promote inclusive attitudes and environments and to ensure that their own agencies and non-State actors are prepared to provide reasonable accommodation. 26 10 See United States Department of Labor, “Employers and the ADA: Myths and Facts” (available from www.dol.gov/odep/pubs/fact/ada.htm).