Section 106 agreement template - 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 Section 106 agreeement template which is in PDF format.

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

• a fully accessible version for all users to access

To make this document template fully accessible would require detailed review of the structure, formatting and legal content of the template. It would then need to be reworked into an accessible format, which is expected to take a significant amount of officer time, including input from staff with knowledge of accessibility as well as the legal and procedure of Section 106 agreements.

Also relevant to this decision are that:

• Due to the nature of this content, there was a need to publish the document quickly, so we took the decision to publish the PDF
• Interest in the document is low - only developers are expected to use this document
• Requests for additionally accessible versions are expected to be rare
• We have and will always assist with accessible versions on request
• Purpose of the document is to have a downloadable template version for developers and their legal team to take away and to start their own draft agreements - they need it in a downloadable form
• Needs to be in a legal agreement format

The S106 agreement template is aimed at a relatively limited number of people and is only intended to be used to speed up planning legal matters. Any previous versions of the document have attracted low levels of public access and have had no requests for an alternative accessible format.

Converting the template into a fully accessible format would require a significant amount of officer time to review, restructure and quality check the content to ensure compliance.

Due to the length of the document, we estimate it would take 3 working days to convert it into a fully accessible version which would place an undue burden on the Council, considering the low number of views expected.

However, should there be a request for information contained within the document to be provided in an accessible format we would be able to assist.

23 June 2026