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.


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 817 PDFs have been published and are currently live on the website. Of this total, 779 have been identified as having between one and six accessibility issues. These PDFs range in length from one page up to 186 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 Google Analytics, there are a total of around 4,400 PDF documents on our website. In the 12-month period between 5 September 2021 and 4 September 2022, only 78 of those documents had a unique page view above 50.

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 2,337 hours (or 61.5 weeks) to correct the 779 PDF documents. This would translate into a minimum cost of £35,670 - although this figure could increase if the PDFs needed to be referred back to the relevant services.


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

We have one full-time Web Communications Officer and a part-time Graphic Designer to assist with working on this issue.

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

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


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 December 2023 we aim to fix all those documents which had a unique page view of more than 100 during the period 22 September 2021 to 23 September 2022. In addition to these documents, we will also look at any documents that provide an essential service, such as a form. If it’s not possible to replace these with an eform we will fix the PDF’s accessibility issues.

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, will be sent to staff to ensure that they are aware of the regulations, and training provided where necessary. The Web Communications Officer will run all new PDFs through Adobe’s Accessibility Checking Tool before they are made live on the site.

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