Annual Governance Statement documents - Disproportionate burden assessments for digital accessibility

Accessibility legislation (on legislation.gov.uk website) states that public sector websites must publish content in an accessible format, unless doing so would impose a disproportionate burden on the organisation. If that is the case, an assessment of the extent to which compliance with the accessibility requirement imposes a disproportionate burden must be carried out.

This is a Disproportionate Burden Assessment for each of the Annual Governance Statement documents which are published in PDF format.

The benefits of creating an HTML version of this PDF would be:

• a fully accessible version for all users to access
• an easily searchable and indexable version

An Annual Governance Statement is produced on an annual basis, so it would take a disproportionate amount of a content designer's time to create a new HTML version of this PDF document each year. 

The time it would take to make the document accessible is approximately 2 working days. This length of time is disproportionate to the demand.

By Statute the Annual Governance Statement must be published alongside the authority’s Statement of Accounts. It must be the actual document as approved by the Audit and Governance Committee that is published not a facsimile of it. There is a statutory deadline by which this and the statement of accounts must be published on the Council’s external website so each year there would be a very limited timeframe after the accounts have been signed to then convert the information into HTML before the statutory deadline; sometimes this may be a matter of hours.  The document is approved in its published form by the Audit and Governance Committee and must be published as it is agreed in order to comply with the legal requirements.

Also relevant to this decision are that:

• We are legally required to make the document available to the public, so the document must be published on the Council’s website
• Requests for additionally accessible versions have never been received – no residents requested an accessible version of a previous version of the document
• The document does meet accessibility requirements for a large number of users, although some groups will find it disproportionately difficult

This is a technical document used for assurance purposes and is a formal document agreed by the Council’s Audit and Governance Committee and so it should continue to be uploaded as a PDF.

We assess that the time involved in creating a fully accessible version of the documents would place an undue burden on the Council, given the small number views received per year.

20 February 2025