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Disproportionate Burden Statement

West Lothian Council is committed to meeting the requirement to make websites accessible, set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("the accessibility regulations").

Accessibility Checks

We have made every effort to ensure this web site is easily readable using plain English. Our web team regularly review content and provide training and recommendations to all our content publishers to ensure all web content is written in a format which is as easy to understand where possible..

Detailed checks have been conducted on

The process for doing detailed checks includes:

  • regular manual testing by way of a content review based on GOV.UK's guidance
  • automated testing using accessibility monitoring software.

Our Accessibility page covers problems we found for our website and our plans to fix them.

Disproportionate burden assessment

We believe that our approach to carrying out accessibility checks is reasonable.

However, we have assessed that it'd be a disproportionate burden to fix all documents published on this website since 23 September 2018.

Despite a very large amount of content currently in document form, to date, no complaints have been received in relation to document accessibility. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified.

We are therefore focussing on ensuring that new documents are accessible where they're required for essential services or specifically address the needs of, or are meant for, disabled people. Where possible these will be available in HTML format as well as a downloadable version.


As of 10 July 2023, there were 12726 documents on our main website published since 23 September 2018 (within scope of the accessibility regulations)

Estimated costs

It is difficult to ascertain the time required to make every document accessible without first reviewing each one. It is likely each one would take several hours of work to be recreated in a fully accessible version.

Currently the software required (Adobe Acrobat pro) is not available to colleagues across the council therefore licences would require to be purchased to allow all users to convert documents into an accessible format. However upon using a trial version we have sampled a test set of documents to assess how long it would take to convert these. It is estimated it will take between one and eight hours per document, depending on length, which elements require to be fixed and any required sign-off.

Were we to halve this time to four hours per document to review and fix each document within scope of the requirements,  fixing all 12726 would take 1696 working days (based on a 7.5-hour working day at West Lothian Council). On the basis of these assumptions, we estimate the cost to the council for fixing the documents would be £554,853.

Assessment of costs and benefits

We believe that:

  • The resources within the team whom would be responsible for converting the documents is limited and is already heavily involved in a cross section of areas dedicated to the delivery of essential services to the public
  • The costs of paying for fixing all of the documents on our website would be a substantial burden on us and the public resources we manage
  • The benefit to users would be limited and their needs can be met in other ways - such as requesting the documents in another format, or utilising our accessibility tools where possible
  • Therefore, fixing all documents on our main website would impose a disproportionate burden on us.

In reaching this decision, we've considered the following:

Estimated costs and benefits for our organisation: fixing documents

The vast majority of this work would have little to no benefit to users with disabilities, based on a complete absence of complaints (in relation to the accessibility of these online documents).

The estimated benefits to users

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

We are already undertaking detailed accessibility checks, fixing content, and ensuring that new documents are accessible or converting these to web content where they're required for essential services.

However, for , we don't believe that the limited additional improvements that could be gained from historical document fixes would justify the substantial costs involved.

How to request content in an accessible format

If you need information in a different format, you can request it using this online form:

Request content in an alternative accessible format