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As per 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 are provided on our main corporate website and our partner platforms and external portals. We are periodically running detailed checks on these.

As such, we do not believe the benefits of paying for an external check of our sites would justify the impact on our organisation except in circumstances where those sites are specifically aimed at individuals with a disability.

Review of existing documents

PDFs and Word documents published before 23 September 2018 may not be accessible for several reasons. Due to the high number of documents on the website, to amend every document would be a disproportionate burden, therefore we are unable to fix this problem.

We will continue to review all documents as part of our ongoing website monitoring arrangements.

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.

Where possible, any new PDFs or Word documents we publish will meet accessibility standards.

As of 8 September 2021, there are 6,694 documents on our corporate website. Of these documents:

  • 6,515 are in PDF format, of which 1,327 have been published since 23 September 2018
  • 179 are Word documents, of which 40 have been published since 23 September 2018

In the past year (8 September 2020 to 8 September 2021), of all our PDF documents only 140 unique PDF files have been downloaded, with the top 10% compromising of only five documents and the rest of our PDFs making up less than 1% each.

Adjusting documents to meet accessibility standards

After a detailed assessment of our corporate website we have determined that it would be a disproportionate burden to fix all documents published since September 2018 within the meaning of the Number 2 Regulations: Interpretation.

The vast majority of these documents have never been viewed and therefore are unlikely to be negatively affecting users with disabilities or impairments. Therefore, we believe that the cost of time, effort and resources required to rectify these documents does not justify the requirement to do so.

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

Timescales for fixing documents

It would be difficult to calculate how long it would take to make every document accessible without thoroughly reviewing each document individually.

Based on it taking around one hour for one document to be fixed within scope we estimate it would take around 734 working days to fix all 5,142 PDF documents.

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 on East Ayrshire Council.

Weighing the cost of internal and external audits

Our accessibility audits have been performed internally using accessibility analysis tools such as axe and WAVE. These have been performed on a selected sample of our websites’ most frequently visited webpages.

We have established what pages are the highest priority/most frequently used by looking over their traffic data.

We also use the Contensis accessibility scanner to highlight accessibility issues with content on pages on

Auditing every page on our organisation’s sites would, in our belief, constitute a disproportionate burden. This is because we currently manage 40+ websites, many of which are large and have hundreds/thousands of pages.

The site itself has over 5,000 pages, many of which use different templates. The pages we audited are samples of those which are most frequently accessed, however many pages on the site do not receive a high level of traffic and as such they may not be picked up in the audit samples.

An estimated cost for third party audit of all our websites has an estimated range of between £120,000 - £280,000.

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

The coronavirus (COVID-19) pandemic also resulted in resources being prioritised on continuing essential services.

Analysis for our organisation in relation to persons with disabilities taking into account the low level of usage for most documents

The estimated cost of making all our documents accessible within the scope of the Number 2 Regulations: Interpretation on would be approximately 730 working days.

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

Organisational size and resource limitations

East Ayrshire Council is a local authority and due to competing priorities, the resources available to tackle outstanding accessibility issues of low priority are limited.

While we do and can address accessibility issues, the resources required to address many of the lower priority accessibility issues in a short period of time would mean resources would need to be diverted from maintaining essential services and continuing current development.

We continue to utilise our existing resources to perform accessibility audits and address outstanding accessibility issues.

Presuming 30 minutes per page, with 5,000+ pages on the main site alone, a rough estimate for a full site audit would take 2,500 hours.

Presuming 8 hours is a working day, this would take 312 and a half days.

Mitigating burden

We currently perform internal audits of our websites and prioritise our most frequently accessed pages for our samples.

We have also brought in guidelines so that, where possible, content being added to the site is now being done so in a way in line with accessibility regulations.

In terms of our older, less accessible documents like PDFs, we scan our pages for content that may be inaccessible and present them with a modal that allows them to request accessible copies of these documents. This allows users with disabilities to still access these documents, even if replacing all of them is not a possible task.

Since the launch of the above system, the number of requests we’ve received for more accessible versions of older documents is very low. This is because it is mostly found on pages with low traffic and our high-traffic pages do not have such content on them.

Along with the current efforts to make sure all content being added to the site is now accessible where possible, we hope to resolve outstanding issues as we reassess our resources when we run our internal audits.

Other burdens

  • Our payments are processed through Civica and when needed users will be automatically redirected to this service to make payments. The payment process can sometimes time out causing users to lose the information they input without warning. The form will also time out if when redirected to the payment provider users don't reach the site within 60 seconds. We are unable to change this as we use a third-party payment provider.
  • When online forms timeout, the information input is not saved resulting in failure of criterion 2.2.5 (Reauthenticating) due to having a session time limit without a mechanism for saving user's input and re-establishing that information upon re-authentication. Our digital platform provider which hosts our forms does not currently have this functionality.
  • The video controls do not have enough contrast. This is an issue with the YouTube video player and not within our control. We will continue to look for ways around this.
  • Some video controls have a tooltip which does not stay open when moving the cursor to them. This is an issue with the YouTube video player and not within our control. We will continue to look for a more compliant player.
  • Planning application documents which are hosted on a third party system.
  • Older Council minutes and agendas.
  • Older large document repository systems.

Where possible, we could provide accessible formats of these documents on request.


Last update

This statement was prepared on 10 September 2021 and was published on 21 September 2021.

Contact Information


Council Headquarters
London Road
East Ayrshire
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