Disproportionate burden assessment


Our site contains a large number of PDFs created in previous years (around 400-500). Although some are accessible, we know that many of these documents have one or more accessibility issues.

Where these are no longer being updated, we do not intend to recreate them in accessible versions as this would be a disproportionate burden. The accessibility regulations don’t require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services.

This assessment relates mostly to PDF documents no longer in active use. However, there will be some PDF documents that are still in active use or that are updated regularly that is in scope.

Whilst we will try to ensure that new documents and the documents which get the highest use are fully accessible, it would currently be a disproportionate burden for us as an organisation to ensure that all PDF documents on the website are fully accessible.


The benefits of making these PDFs into accessible PDF or HTML formats would be:

  • Materials would be fully accessible to all users
  • Materials would be more easily searchable and indexable


Our assessment of the burden of making these PDFs into accessible PDF or HTML formats is that:

  • there are around 400-500 historical documents created by the organisation
  • each document would require a number of hours of work to be recreated in a fully accessible version (estimated between 2 and 30 hours per document, depending on length and complexity, plus any required sign-off)
  • many of the documents contain complex elements which are difficult to retrospectively convert, such as detailed tables, graphs, and diagrams

Other factors

Also relevant to this decision are that:

  • Interest in some of these documents is low – few people access them
  • The documents do meet accessibility requirements for a large number of users, although some groups will find them disproportionately difficult
  • Of the documents we are proposing would represent a disproportionate burden, requests for additionally accessible versions are rare
  • We have and will always assist with accessible versions on request
  • We suffered a cyber attack in December 2020 where we lost many documents and some of those documents were only recovered in PDF format therefore some documents would require to be fully rewritten
  • The vast majority of information on our site is fully accessible already and have a plan in place to fix the remaining issues.


Where documents are no longer in active use, or no longer being updated, there is a high cost in terms of employee hours to convert. We are a small organisation with limited resources available for work on the website and creating accessible materials. We always respond to requests for our publications in different formats on a case-by-case basis, so accessible versions are available on demand. We consider that the costs of converting all documents, especially older documents where there is little evidence of demand would be a poor use of limited staff time, and would represent a disproportionate burden on the organisation in terms of cost. However we will review this again in another 12 months.

Assessment date: 31 January 2024

Review date: 31 January 2025