Disproportionate burden assessments

Conducting a full audit and buying auditing tools used

We are required by law to carry out disproportionate burden assessments where we are not able to meet our legal obligation to reach the WCAG 2.1 AA accessibility standard.

This assessment relates to our accessibility audit for our main website (www.slough.gov.uk) and the tools used for it.


To conduct a full accessibility audit and to have access to a paid for / full version of a web governance platform which, will run automated accessibility and quality assurance checks, would benefit our users with:

  • a more accessible website for all our users
  • easier access to council services
  • a more efficient and comprehensive automated check.


Full audit costs

The CDDO states you could expect to pay a third-party up to £1,300 a day for a detailed accessibility audit, examples are based on previous costs.

We also received a quote for an accessibility audit and support for £2-3,000 plus VAT.

Web governance platform costs

Quotes we’ve received or costings we’ve found online range from £4,630 to £11,400 per year.

Burden due to costs

Historically, we have had no budget line for web bar for staff. This is still the case. We do not have the technical expertise to do a full test internally. Under normal circumstances we would have paid a third-party to conduct a full accessibility audit. However, we are not able to do this currently, nor are we able to invest in a web governance platform because as a council we are suffering from severe financial issues:

  1. Council pauses non-essential spending following Section 114 notice
  2. Council accepts review reports and looks to the future.

Extra costs would impact negatively to the budget.

Our organisation's size and resources

Slough Borough Council is a unitary authority, going through some huge financial issues as described above, with the future of the council looking to be downsized over the next 5 years.

We do not have the technical expertise in-house to conduct a full audit. And we do not have the resources to get a third-party to conduct a full audit.

We do not have the resources to pay for a web governance platform. We are relying on the free tools that are available:

  • Axe
  • Colour Contrast Analyser (CCA)
  • WAVE

We will run the free accessibility checks that the following offer:

  • Accessibleweb
  • SiteImprove
  • Silktide
  • Tenon

We used WebFX to check for readibility.

And in addition to the basic accessibility check, we will also perform manual checks to:

  • search and fix raw urls
  • search and replace words such as click, see, view with more inclusive terms, such as select, check, find
  • ensure meaningful link text are used
  • check links go to the right destination
  • check text is web friendly and in plain English.

We appreciate a basic audit may not pick up all issues. This site was built in 2021 and launched in November 2021 with accessibility at the forefront of the build and content. Our Accessibility Statement (as per requirements) includes our contact details for anyone to get in touch if they have any issues with our site. Although we can't determine what issues would come up on a full audit or from using a full version of a web governance platform, we will certainly be open to our users approaching us on any accessibility issue and be forthcoming to resolve it.

Furthermore, we are raising staff awareness on the importance of accessibility and:

  • provide guidance and training to teams within the council on creating accessible documents. To complement this, we are working on an (in-house) accessibility training video for staff
  • include reminders in Newsround, our weekly email update to staff
  • have added a creating accessible content training course within our website guidance page of the intranet as well as our talent management system, Cornerstone, for staff to access and learn from
  • engage with our services who have invested in third-party software to make sure their products are accessible.


We consider that the costs to conduct a full accessibility audit on this site and to invest in a web governance platform for our site will represent a disproportionate burden to the organisation in terms of cost.

We have therefore had to conduct a basic accessibility check as advised on GOV.UK, as part of our accessibility audit and used the free resources and tools that are available.

This disproportionate burden will apply until the council’s financial situation has been settled. Our Financial Recovery Plan is for 5 years, so we expect the disproportionate burden to apply until 2026.