Council of Sanctuary Framework document - 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 Council of Sanctuary Framework 2025-28 which is in PDF format.

The benefits of creating an HTML version of this PDF would be:

• a fully accessible version for all users to access
• an easily searchable and indexable version

Requiring the refreshed Council of Sanctuary Framework to fully comply with accessibility criteria is disproportionate in the current context. Implementing the changes would demand at least 2 working days and incur an additional cost of approximately £250. This places a significant burden on already time-pressured, part-time staff, who would also need extra time to interpret and apply complex technical specifications.

The previous edition has been publicly available on our website since January 2025, and this refreshed version is intended to replace it.

The updated format meets many of the Council’s accessibility requirements and also reflects the sanctuary ethos and offers a more engaging, visually appealing design. These improvements are expected to increase visibility and readership, delivering greater impact without imposing unnecessary costs or delays.

Also relevant to this decision are that:

• The extra work needed on the document would delay delivery of other priority projects
• Small accessibility improvements do not justify the cost and time of investment
• Specific enhancements have already been implemented in this new edition, i.e. clearer layout, improved readability, mobile-friendly design, more colourful and attractive photos and designs
• Requests for additionally accessible versions are rare - there have been no requests from residents requesting an accessible version of a previous version of the document
• The document does meet accessibility requirements for a large number of users, although some groups will find it disproportionately difficult
• We have and will always assist with accessible versions on request

After reviewing the requirements, costs, and timelines, it is clear that enforcing full compliance with the national standard accessibility criteria for the refreshed Council of Sanctuary Framework 2025-28 would be disproportionate.

The estimated additional cost of £250 and 2 working days of effort would place undue strain on limited part-time staff resources, diverting attention from other priority commitments.

The framework incorporates significant improvements in readability, layout, and visual appeal compared to a previous version. These enhancements align with the Council’s sanctuary ethos and are expected to increase engagement.

Further adjustments would deliver minimal added value while causing delays and reputational risk.

However, should there be a request for information contained within the document in an accessible format, we will be happy to provide it.

18 December 2025