Disproportionate burden assessments

PDFs and other documents on this site

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 on PDFs and other documents on our main website (www.slough.gov.uk).


To make all our PDFs and documents accessible would benefit our users as:

  • they would be fully accessible to all users
  • it will provide easier access to council services
  • if converted to HTML they would be more easily searchable.


We have just under 800 documents on this site, some of which were published after 23 September 2018. Some documents published prior to 23 September 2018 would be required to meet accessibility standards as they may be accessed a lot or are essential to providing our services.

The total unique page views for these documents from April 2022 to March 2023 is 46,843. In the same duration, the highest unique page view for a document was 4,952, with 492 of those documents having between 1 and 10 unique page views each.

Our assessment of the burden of making these documents into an accessible format is:

  • it is difficult to assess how long it would take to make every document accessible without first reviewing each one. Some documents would also require the relevant service's input. If it took approximately between one and 51.8 hours depending on length and complexity, the cost to the council, depending on the grade of the post working on this work will be between, around £24 to £26 and around £1,250 to £1,352 per document to review and fix each of them within scope
  • if we prioritised making these documents accessible this will have a negative impact on:
    • the posting, updating and maintaining of our essential service information on the website and that of the others we are responsible for
    • the designing of material for essentail services
  • due to the council’s current financial situation, we are unable to employ additional staff to make documents accessible:
  • extra costs would impact negatively to the budget
  • interest in some of these documents are low
  • as always, we will assist with alternative formats if there is a request for it.

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.

Our current resources available to tackle outstanding accessibility issues are limited. The following roles that would directly assist with these issues from the digital communications team are:

  • 1 FTE team lead
  • 1.5 FTE who post, edit and maintain content within the websites we are responsible for
  • 1 FTE senior graphic designer officer

The resources required to convert these existing documents to HTML or fix these existing documents would mean resources would need to be diverted from:

  • posting, editing and maintaining information about essential council services available from the main website as well as essential information on our other sites and
  • designing material for essential services.

We do not have the resources to outsource this work.

Our graphic designer had found a bespoke training course for the design tool available for this post but was cancelled by the supplier. Our graphic designer has since used free online resources for some self-learning in making PDFs accessible.

We do aim to make any documents that has a unique page view of 500 or more, (statistics taken between April 2022 and March 2023), accessible by December 2023.

Our Accessibility Statement (as per requirements) includes our contact details for anyone to get in touch if they have any issues with our site and documents. We will certainly be open to our users approaching us on any accessibility issue.

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 documents produced by them, which need to be posted on our site, are accessible.


We consider that the resources needed to ensure all the existing documents on our site are accessible, 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 and time.