Disproportionate burden assessment

Updated: 14 January 2022

Dumfries and Galloway Council is committed to meeting its legal obligations set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("No. 2 Regulations").

However, we have a complex collection of websites and limited resources to check them all for accessibility issues.  

As per the Number 2 Regulations: Interpretation, we have decided it would be a disproportionate burden to pay for the services of an external auditor to perform a detailed check on our entire collection of websites.

We do not believe the benefits of paying for an external check of all our sites would justify the impact on our organisation.

How we do accessibility checks

We've decided to use a combination of methods for our organisation, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the No. 2 Regulations. 

Detailed checks

We're doing a detailed accessibility check for:

  • The main Dumfries and Galloway Council website (dumgal.gov.uk)
  • The main transactional site, which includes fault-reporting (info.dumgal.gov.uk)

The process for doing a detailed check includes:

We believe it is reasonable to carry out a detailed check in the manner above for dumgal.gov.uk and info.dumgal.gov.uk, as this covers the most important content provided by Dumfries and Galloway Council. 

Our accessibility statement for dumgal.gov.uk will cover problems we found and our plans to fix them. 

Basic checks

We'll carry out basic accessibility checks on Dumfries and Galloway Council websites that are independent of dumgal.gov.uk. 

These basic checks will be carried out by the service responsible for the website, based on:

Services will check samples of content, which will include:

  • Their homepage
  • Content pages that are mostly text based
  • Images, video and audio content
  • Interactive tools and transactions, like forms
  • Pages including login functionality, if the website has it
  • PDFs and other document types they have
  • Dynamic content like pop-up windows
  • Navigation pages, including their sitemap and pages with search functionality

Accessibility statements for these websites will be published independently of dumgal.gov.uk.

This important work will get underway in 2023 after an audit of each website has been undertaken.

Disproportionate burden

Checking websites

We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to pay an auditor to do a detailed check on our large collection of websites. 

Our most important information is provided on our main website, dumgal.gov.uk. We're doing detailed checks on this. 

However, we do not believe the benefit of paying for detailed checks of our other websites would justify the impact on our organisation except where those sites are specifically aimed at people with a disability.  

In terms of the detailed check of our main website dumgal.gov.uk, our accessibility audits have been performed internally and manually using accessibility analysis tools such as WAVE and axe DevTools, and externally, using centralised web governance platform (and automated accessibility checker) Silktide.

The manual testing looked at a 25-strong selected sample of our website's most frequently visited webpages/types of pages. We established what pages were the highest priority/most frequently used by looking over their traffic data. We established what types of pages were most common by our knowledge of our website and liaison with our CMS provider. Sample pages audited included: homepage, top-10 most-visited webpages, content pages that are mostly text-based, pages including login functionality, pages including different document types, pop-up window, navigation pages, forms, images, video and audio content, pages containing information about accessibility.

Between November 2021 and January 2022, we undertook extensive accessibility-improvement work on both dumgal.gov.uk and info.dumgal.gov.uk, fixing a series of accessibility issues across both sites in line with our ongoing commitment to make our web estate as accessible as we can. Fixes included WCAG 2.1 AA success criteria: 2.4.7 (Focus Visible), 1.4.5 (Images of Text), 3.2.1 (On Focus), 1.4.3 (Contrast, Minimum), 1.3.1 (Info and Relationships), 3.1.1 (Language of Page), 4.1.1 (Parsing), 4.1.2 (Name, Role, Value) and 2.4.2 (Page Titled), 3.3.2 (Labels or instructions). This involved a coordinated programme of work by our external CMS provider, Business and Technology Solutions (a department of Dumfries and Galloway Council) and our web team.

However, manually auditing every page on our main site, which comprises more than 9,800 pages, would, in our belief, constitute a disproportionate burden.

Fixing documents 

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they're not essential to providing our services.

Having carried out a detailed check of dumgal.gov.uk, we've also assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on dumgal.gov.uk since 23 September 2018. 

As of 14 January 2022, 5,408 documents (PDF, Word, Excel, PowerPoint) have been uploaded to our corporate website since its inception. Of these documents:

  • 4,922 are in PDF format, of which 3,102 have been published since 23 September 2018
  • 467 are Word documents, of which 258 have been published since 23 September 2018
  • Eight are Excel documents, of which 7 have been published since 23 September 2018

11 are PowerPoint documents, of which 10 have been published since 23 September 2018.

Most of these documents have never been viewed, so they are not negatively impacting users with disabilities or impairments. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified. 

Instead, we have focussed on fixing only those PDFs that have been viewed between 15 December 2020 and today (Friday 14 January). In future, we will ensure that new documents uploaded to the website are accessible where they are required for essential services or used by people with disabilities. 

Types of website and documents 


Dumfries and Galloway Council has more than 25 websites independent of dumgal.gov.uk. 

These sites cover a variety of purposes, size and content. Some are hosted by our organisation; others are hosted and maintained by external suppliers and managed and paid for by an individual council service or directorate. 

Most of our independent sites are relatively small in scale, use and complexity, and do not provide essential transactions.


As of 14 January 2022, there were 3,377 documents on dumgal.gov.uk published since 23 September 2018 (within scope of the No. 2 Regulations). 

Our time, effort and resources will be focussed on fixing the most viewed documents and ensuring that any new documents are fully accessible.

As above, to this end, over the past six weeks (start-December 2021 to mid-January 2022), our web team and other members of the communications unit have amended 363 PDFs to make them more accessible, these being the only PDFs viewed/downloaded from our corporate website over the past 13 months.

Estimated costs 

Paying for detailed audits 

We have assessed that it could cost between £58,500 and £208,000 for an external expert to do a detailed check (and later re-audit) on our full collection of 25 websites.

This assumes that 80% of our websites were considered small and 20% were considered large. 

These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. This includes:

  • A third-party day rate of £1,300
  • About 1 to 3 days to audit a small website
  • About 5 to 20 days to audit a large website

Cost of fixing documents 

It's difficult to know how long it would take to make every document accessible without first reviewing each one. However, if it took approximately one hour to review and fix each document to comply with WCAG 2.1 AA within scope, fixing all 3,014 (total documents uploaded to dumgal.gov.uk since 23 September 2018 - 3,377 - minus 363) would take 419 working days (based on a 7.2-hour working day at Dumfries and Galloway Council). 

Assessment of costs and benefits

We believe that:

  • The costs of paying for detailed checks for all our websites and fixing all documents on dumgal.gov.uk would be a disproportionate burden on our organisation
  • The benefit to users of paying for detailed checks on the independent websites (taking into account the frequency and duration of use of these websites) and assigning staff to fix all documents on dumgal.gov.uk (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on Dumfries and Galloway Council

In reaching this decision, we have considered the following:

Our organisation's size and resources

Dumfries and Galloway Council is a local authority managing increasing front-line service demands set against reducing annual budgets.

During 2020-2021 we were forced to re-prioritise resources owing to the coronavirus (Covid-19) pandemic, ensuring business continuity of essential services. 

The nature of our organisation

We do provide services aimed at people with a disability, but these are generally included on our main website, dumgal.gov.uk (which we are doing detailed checks of). 

The estimated costs and benefits for our organisation: in relation to the estimated benefits for people with disabilities, taking into account the frequency and duration of use of the independent websites

We believe the potential of paying up to £208,000 just on audits (and that's before we have done anything to fix the issues identified) is unreasonable. Especially when it is the Council's intention to redevelop its website in the coming years with a view to a fully compliant (to the latest accessibility standards at that time) dumgal.gov.uk.

In addition, many of the services that maintain sites independent of dumgal.gov.uk provide front-line services to the public. We believe that:

  • Maintaining statutory and essential front-line services should be prioritised over paying for independent website audits
  • It would be reasonable within the meaning of the No. 2 Regulations for our services to carry out basic checks of their independent websites and use any available budget to fix the main issues found on their sites

Our services will be assisted in their basic checks by:

  • Automated accessibility monitoring software (Silktide)
  • Internal guidance from the web team

Our web team is leading the detailed check of dumgal.gov.uk. However, the web team is small (1 FTE) and the scale of co-ordinating the auditing and fixing of our main website leading up to 14 January 2022 - in addition to their other essential functions - means they lack the capacity to carry out a detailed audit of our other sites.

Last, the cost of making all documents within scope of the No. 2 Regulations on dumgal.gov.uk accessible would be approximately 419 working days. Most of this work would have little to no benefit to users with disabilities due to the low/absence of views of online documents on our website. 

Documents supplied to us by outside organisations

Sometimes, documents are supplied to us by other organisations (when we don't commission or pay for them) and by members of the public.

Each document would require several hours of work to be recreated in a fully accessible version. These documents were created by third parties and publishing an updated version would mean altering content that isn't ours. Many of the documents contain complex elements that are difficult to retrospectively convert, such as diagrams. Many of these documents have never been viewed and we will always provide help with seeking an accessible version if asked.

How much users with a disability would benefit from making things accessible

Our users would benefit from us making our websites and online documents accessible. For instance, providing inclusive access to our documents and, hence, easier access to council services.

However, we do not believe that for most of our websites the extra improvements that could be gained from paying for a detailed check would justify the cost over doing a basic check internally. And fixing thousands of documents that no one views or downloads is not a good use of resource.

We also believe that users will benefit most from us focussing our available resources on fixing the most used documents on dumgal.gov.uk (already complete), continuing to fix any outstanding accessibility issues as outlined in our  accessibility statement , and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.


Where possible, we can provide accessible formats of documents on request. In addition, if you spot an accessibility improvement on dumgal.gov.uk or want to chat to us about our ongoing work to improve the accessibility of Dumfries and Galloway Council's web estate, please contact: webteam@dumgal.gov.uk.

Last update

This statement was prepared on Friday 14 January and published on Wednesday 19 January 2022.

Page last updated: 28/02/2024
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