Disproportionate burden

Where we are unable to meet our legal obligation to meet the WCAG 2.1 accessibility standards we are required to carry out a disproportionate burden assessment.

Having carried out a check of our website (www.dacorum.gov.uk) we have assessed that it would be a disproportionate burden to fix all accessibility issues on our PDF documents published since 23 September 2018, when the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations came into force.

Burden

Using the Siteimprove content performance platform we have carried out an assessment that has revealed that since the regulations came into force on 23 September 2018, a total of 778 PDFs have been published and are currently live on the website. Of this total, 587 have been identified as having between one and five accessibility issues. These PDFs range in length from one page up to more than 200 pages.

While it would be beneficial for these documents to be fully accessible, the majority of these are rarely viewed, so unlikely to have a negative impact on those with disabilities and impairments. According to Siteimprove, there are a total of 3,059 PDF documents on our website. In the 90-day period between 19 February 2025 and 19 May 2025, only 13 of those documents were downloaded more than 100 times.

Since the regulations came into force we have received no complaints regarding the accessibility of the documents on our site. However, we would always provide alternative versions if requested and our contact details are available on our accessibility statement.

Estimated costs

While it is difficult to quantify exactly how long it would take to either make the PDFs accessible or create HTML alternatives, using a small sample of PDFs suggests that it would take on average at least three hours of officer time to review, liaise with the relevant service and then make the required changes to a PDF.

On that basis, it would take 1,761 hours to correct the 587 PDF documents. This would translate into a minimum cost of £35,220 - although this figure could increase if the PDFs needed to be referred back to the relevant services.

Resources

We are a borough council faced with ever-reducing annual budgets. Currently, resources to fix this issue are limited.

If we prioritised making all these documents accessible it would have a negative impact on the core work of officers - namely posting, updating and maintaining essential service information on the site.

Due to the current financial situation, there are no funds for additional resources to assist with this task.

Assessment

For the reasons stated above, we do not believe the cost of time, effort and resource to fix all the documents is justified.

The benefit to website visitors with disabilities of this work being carried out would be negligible given the low demand of the majority of these documents. However, if specific concerns were raised we would do our utmost to assist.

What we will do

Our first priority will be to address the most frequently used documents. By 31 May 2026 we aim to fix all those documents that were downloaded more than 100 times during the past 90 days (19 February to 19 May 2025). We will also look at any documents that provide an essential service, such as a form. Our aim is to replace these with a digital solution using our new Digital Platform.

Going forward, we will aim to create HTML pages in the first instance. Where this isn’t possible we will ensure that all new PDF documents are compliant before being published. Communications, including a guide on how to make PDFs accessible, has been sent to staff to ensure that they are aware of the regulations, and training provided where necessary. All new PDFs are checked using Adobe’s Acrobat Pro's accessibility checking tool, as well as carrying out manual checks, before they are made live on the site.