The Council and democracy Disproportionate Burden Assessment

Under the Number 2 Regulations: Interpretation, we have determined that 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. 

The majority of our important content and transactions for residents are provided on our main website, our partner platforms and external portals. We periodically run detailed checks on these. See our accessibility statement.   

We use a combination of methods to perform these checks, as set out in the GOV.UK guidance on deciding how to check your websites, and in compliance with the Number 2 Regulations.

Review of existing documents 

Some PDFs and Word documents published before 23 September 2018 may not be accessible for several reasons. Due to the high number and age of some of the documents on the website, we are still working across our services to ensure these documents are brought in line with WCAG 2.1 standards. 

We will continue to review all new documents to ensure they meet accessibility standards before adding them to the site as part of our website governance. 

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, therefore these documents fall under disproportionate burden and are not being reviewed. 

As of 11 October 2021, there are 1,440 download files on our main website (this does not include those in applications such as Modern.Gov – Council agendas and reports). These files may contain several documents. Of these files: 

  • 1,440 are in PDF, CSV or Word format, of which 574 have been published since 23 September 2018 

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

In the past year: 

  • 62 documents (4%) have been viewed more than 1000 times 
  • 57 documents (4%) have been viewed between 500 and 1000 times 
  • 354 documents (25%) have been viewed between 100 and 500 times 
  •  967 documents (67%) have been viewed fewer than 100 times 

We are unable to track downloaded files but the numbers would be expected to be significantly lower. 

Assessment of costs and benefits 

We believe that: 

  • the costs of paying for detailed checks for all our corporate websites and included documents would be a disproportionate burden on our organisation. 
  • taking into account the low level of usage of the majority of our documents, assigning staff to fix all our documents would not be justified and would impose a disproportionate burden. 

Weighing the cost of internal and external audits 

Our accessibility audits have been performed internally using accessibility analysis tools such as WAVE, Adobe Acrobat DC Pro and NVDA screen reader. These have been performed on a selected sample of our websites’ most frequently visited webpages. 

We also use the Site Improve accessibility scanner to highlight accessibility issues with our content pages. 

In our view, it would be a disproportionate burden to: 

Services across the Council currently manage more than 90 third-party websites; we have worked with these services to review their sites and offer and support to help make them more accessible. 

When reviewing our site we audit samples of our different page types, we prioritise those which are most frequently accessed.  

An estimated cost for a third party audit of all our websites ranges between £282,000 to £658,000. 

The above figures are based on GOV.UK’s estimate figures of £3,000 to £7,000 per site, provided by the Government Digital Services' Getting an accessibility audit page

The coronavirus (COVID-19) pandemic has also led to resources being prioritised on continuing essential services. 

Time and cost of making all downloads accessible 

We have worked hard to reduce the number of downloads on our website and are working with services to present the information as fully accessible web content.   

On average, we estimate that it could take at least one hour of work to make each download accessible on Using that as an estimate, the time needed to work on all the 1,440 existing downloads would be 206 full working days. This would be the minimum amount of time that it would take to review all documents, as many documents could be longer than one page and so would require more time and resource.  

Resources available 

At the time of writing, the Digital Communications team is five full time members of staff and one part-time member of staff. We manage 22,606 pages of content on the Manchester City Council website (not including subdomain sites or third-party websites). 

We use existing resources such as SiteImprove and BrowseAloud to assess the navigation and accessibility of the site. This includes weekly checks to fix broken links and to make other accessibility amends. According to SiteImprove, our website is operating at an accessibility score of 98.6%. 

If it takes at least 30 minutes to carry out a full accessibility check on a web page, with 22,606  pages on the main website alone, a rough estimate for a full site audit would take 11,303 hours, or 1,615 days of work (assuming a seven hour working day).   

Approving and rejecting content 

112 colleagues from services across the Council have received content author training and they submit updates to ensure web content is up to date for their service area. The Digital Communications team then approve or reject the new web content, on the basis of it being accessible and WCAG 2.1 AA compliant.   

We removed the permissions which allowed content authors to add their own downloads to Jadu: if content authors submit inaccessible content updates to us, we use this as an opportunity to refresh their content author training, discuss accessibility with them and to explain the necessary measures to present the information in a more accessible way.  

Other burdens 

Several of our website’s subdomains are hosted on separate platforms, including:  

  • - a Modern.Gov platform for historic council minutes, meetings and agendas, this area of the website is managed by our governance and scrutiny support team. On this site, information must be collated and published publicly within a short legal timeframe.    
  • - is a platform for publishing data, designed to promote council transparency and accountability, this area of our website is managed by our open data team  
  • is our planning portal which is managed by our planning team  

These subdomains pre-date accessibility legislation and are not WCAG 2.1 AA compliant, however the teams that manage the content on these platforms have recently received SCULPT and accessibility training. We are working with them to focus on making their content accessible going forward. 

Civica payments 

Our payments are processed through a third-party payment platform, Civica, which is not WCAG 2.1 AA compliant. We have raised this with the supplier.  

Third party websites 

We carry out basic accessibility checks on the third-party websites that are independent of There are more than 94 such sites. 

Basic checks will be carried out by the editors for the website, based on: 

We also use this process to offer further content, accessibility and SCULPT training as a part of general good practice.

Was this page helpful?

Fields marked * cannot be left blank

Feedback submitted to us on this form is monitored but you won’t receive a reply. In an emergency, visit our emergency contact details page. Please don't include any personal or financial information, for example your National Insurance or credit card numbers.