Housing, Homelessness and Rough Sleeping Strategy documents - Disproportionate burden assessments for digital accessibility

Accessibility legislation (on legislation.gov.uk website) states that public sector websites must publish content in an accessible format, unless doing so would impose a disproportionate burden on the organisation. If that is the case, an assessment of the extent to which compliance with the accessibility requirement imposes a disproportionate burden must be carried out.

This is a Disproportionate Burden Assessment for the Housing, Homelessness and Rough Sleeping Strategy documents, which are in PDF format and cover the following:

• Housing, Homelessness and Rough Sleeping Strategy 2023-2028 and Action Plan
• Homelessness Review and Housing, Homelessness and Rough Sleeping Strategy evidence base 2021

The benefits of creating HTML versions of these Portable Document Formats (PDFs) would be:

• fully accessible versions for all users to access
• easily searchable and indexable versions

Given the high number of charts and tables within the documents and the length of them (238 pages in total), we estimate that it would take approximately 15 working days to make the PDFs fully accessible and this would not be a good use of resources.

Also relevant to this decision are that:

• We are legally required to make the homelessness strategy document available to the public, so the document must be published on the Council’s website
• Due to the nature of this content, there was a need to publish the document quickly following approval by the Cabinet, so we took the decision to publish this in a PDF
• Requests for additionally accessible versions are rare - there have been no requests from residents requesting an accessible version of these documents since the policy was approved in 2023
• The document does meet accessibility requirements for a large number of users, although some groups may find it disproportionately difficult
• We can help to provide accessible versions of any content within the document which is not clear on request

Based on our assessment, it is considered that changing the whole document to a more accessible format would be a disproportionate burden and not a good use of resources. Mitigations are in place to help provide accessible versions of specific content if requested in the future.    

19 September 2025