Under The Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018 (“The Regulations”), organisations are required to undertake an assessment for disproportionate burden where compliance with the regulations may not be feasible to achieve.  

Our site contains PDF documents that are not accessible for all users. Where these are no longer updated, we do not intend to recreate them as accessible versions as this would be a disproportionate burden.  

The Accessibility Regulations do not require us to repair documents published before 23 September 2018, unless they are essential to the provision of our services.  

Scope 

This report outlines our disproportionate assessment process in relation to meeting Web Content Accessibility Guidance (WCAG) 2.2 level AA. Specifically, Success Criterion: 

• 1.1.1 non-text content  
• 1.3.1 info and relationships 
• 1.3.2 meaningful sequence 
• 1.4.3 Contrast (Minimum) 

This is because many of our PDF documents are inaccessible. We are aware that: 

• some PDF images have no alternative text  
• headings are not tagged on the front page 
• table headers are not marked up 
• headings are not marked up 
• headings do not appear in reading sequence 
• some text has low contrast 
• documents contain images of text  

We are committed to making all frequently used documents fully accessible as HTML web pages. We hope to complete this process by the end of 2025. We will prioritise the most used documents for conversion to HTML. All future documents will have an accessible version available.  

Benefits 

The benefits of converting these PDF documents to accessible HTML formats would be that: 

• all content would be fully accessible to all users  
• content would be more easily searchable and indexable 

Burden 

In line with the regulations, the disproportionate burden assessment has been applied against documents essential to the provision of our services as well as all documents published from 2018.

There are around 20,000 assets classified as documents on our website, the majority of these are PDF files. Many of the documents contain complex elements that are difficult to convert to HTML, such as detailed tables, graphs and charts. 

Our assessment of the burden of converting these PDF documents into accessible HTML formats is that most documents would require 2 to 4 hours of work to create an accessible version. All revisions would then need to be signed off by the content owners, which would place strain on teams across the organisation. 

Assessment  

There is a prohibitive cost in terms of staff time to convert inaccessible documents. Where documents are no longer actively used or updated, we will remove them from the website as part of our ongoing content review. 

These documents are part of the public record but may no longer represent the current position and are of limited interest. They can be viewed on archive.org or through the National Library of Scotland archive. 

We will ensure that frequently used documents are converted to HTML within the next 18 months. We will also ensure that older, obsolete documents are removed.