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Disproportionate Burden Statement

Find out how we (Ashfield District Council) are checking our websites for accessibility issues, and what we consider to be a disproportionate burden.

We carry out assessments to find out what accessibility issues our website may have. The assessments include the way we check our websites, what accessibility issues we can fix and how we've assessed what we consider a disproportionate burden.

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

We do, however, have a complex collection of websites and limited resources for checking and fixing all accessibility issues.

Our approach to carrying out accessibility checks

We 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 do a detailed accessibility check for:

  • the main Ashfield District Council website (
  • digital transactions and interactions, many of which are branded consistently with our main site or hosted as a sub-domain, e.g.,

Our sample of transactions and interactions will include highly used services across different corporate portals and platforms, including:

  • Payments
  • Applications and online forms
  • Democracy / political services

The process for doing a detailed check will include:

Our manual testing is performed on a monthly schedule but is also run ad hoc when extra checks are being made. Our manual testing also includes users with disabilities and impairments, who may be using assistive technology such as screen readers. These are typically Ashfield residents and members of Ashfield’s Citizens Panel, a group of around 75 residents used for a range of testing and feedback purposes.

We currently do not have an automated testing method in place but are researching which solution would best fit our needs and then plan to procure.

We believe it is reasonable to carry out a detailed check for and our digital transactions / interactions, as this covers the most important content provided by Ashfield District Council.

Our accessibility statement for will cover problems we found for our website and its contents and our transactions / interactions, and our plans to fix them.

Basic checks

We regularly carry out basic accessibility checks on Ashfield District Council websites that are independent of

These basic checks will be carried out by the Digital Transformation Team with assistance from the service responsible for the website, based on:

Services will check samples of content, which will include

  • 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 them
  • 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

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 entire collection of websites.

Our most important content and transactions are provided on our main website,, and its associated portals and platforms. We regularly do detailed checks of these.

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

Fixing documents

Having carried out a detailed check of the document content held on, we assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on since 23 September 2018.

The majority of these documents have a limited audience, and from reviewing user analytics, has been viewed a limited number of times. We assessed that as they are not accessed often, they do not negatively impact our website visitors with disabilities or impairments. We do offer contact details on the website for people to get in touch if they do require an accessible version of any of our documents presented on the website. For this reason, we don't believe the cost of time, effort and resource to ensure all documents on our websites meet the No2 Regulations all of the time is justified.

We ensure that any new documents uploaded to the website from May 2021 onwards are checked for accessibility and any issues within the documents are fixed before they are uploaded for the public to access them. This will mean that annually or regularly updated and replaced documents will all become accessible by May 2022.

We are also working towards fixing any accessibility issues with the most viewed documents on (top 10%) and where possible are working to convert documents into web pages, to ensure the accessibility of the information.

Types of website and documents


Ashfield District Council has over 10 websites independent of, some of these being shared service websites with our neighbouring Mansfield District Council.

These sites cover a variety of purpose, 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, directorate or shared costing between District Councils.

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

Examples of these sites include:

  • Discover Ashfield (60 pages) – News updates from local business, community and public sector bodies
  • Millwaters (17 pages) – National Lottery Heritage funded joint local project.

We therefore believe it is unreasonable to carry out a detailed check of all of our websites, focusing resources on our main website ( and associated transactional portals, as these cover the most important content provided by Ashfield District Council. We will however undertake basic checks of all other independent websites.


As of 1 November 2021, there were 1311 documents on which have been accessed between 1 September 2020 and 1 November 2021.

Of these:

  • 1125 (85.82%) have been viewed fewer than 50 times
  • 98 (7.48%) have been viewed between 50 and 99 times
  • 84 (6.41%) have been viewed more than 99 times

We believe it is an unreasonable burden to ensure all of our documents on all of our websites meet accessibility guidelines all of the time. As mentioned, our focus will be to ensure the 10% most viewed documents are compliant with accessibility guidelines – this equates to around 130 documents. As fixes are made, we will iteratively fix more documents, continuing to focus on the next 10% most frequently viewed.

Estimated costs

Paying for detailed website audits

We have assessed that it could cost between £6,500 and £26,000 for an external expert to do a detailed check (and later re-audit) of and our most essential digital transactions.

This figure excludes conducting audits on our other websites, so this figure would increase if they were included.

Typically, if 80% of our websites were considered small and 20% were large, the cost to Ashfield District Council overall for detailed audits for all of our websites would be between £32,500 and £130,000.

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 individually.

However, if it took approximately one hour to review and fix each document within scope, fixing all 1311 would take 177 working days (based on a 7.4-hour working day at Ashfield District Council).

Assessment of costs and benefits

We believe that:

  • The costs of paying for detailed audits for all our websites and fixing all documents on 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 (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on Ashfield District Council

In reaching this decision, we have considered the following:

Our organisation’s size and resources

Ashfield District Council is a relatively small local authority managing increasing front-line service demands but reducing annual budgets.

During 2020 we have also been 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, these are generally included on our main website,, and associated transaction portals (which we are doing detailed checks of).

The estimated costs and benefits for our organisation

In relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the independent websites

We believe the potential of paying up to a quarter of a million pounds just on audits of all of our web interfaces that people interact with (before actual fixes) is unreasonable.

We believe that:

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

Working together across our organisation, as a minimum, basic checks will be undertaken on all of our independent websites by:

  • Scheduled checks, with automated accessibility monitoring software in the future
  • internal guidance and support from the Digital and Web Content Lead (a specialist web content and user experience member of staff)

Our Digital Transformation Team (DTT) is leading the detailed check of and our digital transactions. However, the DTT is a small team, and the scale of co-ordinating the auditing and fixing of our main website and transactions leading up to 23 September 2020 - in addition to their other essential functions - means they lack the capacity to carry out a detailed audit of our other sites.

In relation to the estimated benefits for persons with disabilities taking into account the low level of usage for most documents

The cost of making all documents within scope of the No. 2 Regulations on accessible would be approximately 177 working days.

The vast majority of this work would have little to no benefit to users with disabilities due to the low usage of the majority of online documents.

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

Our users will benefit from us making our websites and online documents accessible.

However, we do not believe that for the majority 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.

We also believe that users will benefit most from us focusing our available resources on fixing the most used documents on and ensuring that new documents are made accessible.

Please note: While this assessment explains our corporate position on disproportionate burden, some services may still choose to carry out a detailed check themselves or submit a business case to finance it.