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Accessibility statement - November 2021

Disproportionate burden

Some Portable Document Format (PDF) and Microsoft Office documents (DOC/DOCX/XLS/XLSX) are considered to be exempt from accessibility regulations if they were created prior to 23 September 2018, or if making them accessible is considered to be a disproportionate burden to the organisation. This exemption is only applies to specific documents or groups of documents that:

  • exist or are produced in exceptionally high quantity
  • are overly complicated to make accessible
  • are contributed to by multiple parties (with Wiltshire Council mainly collating the information)
  • are exceptionally large (sample size of over 10-30 pages)

Each document is assessed on a case-by-case basis. For example, while a single 30 page document of plain text may not be exempt if it's easy to convert, we might consider 10 pages of complicated diagrams, or a large group of smaller documents which are heavily related, to be burdensome to convert when the content is not critical to offering our services or frequently accessed/requested.

The following data (captured 8 September 2021) contains a sample of analysed documents (50% of the all documents uploaded to the main Wiltshire Council website) and highlights the proportion we believe to be exempt:

Status of documentsCountPercentage
Still under review185050%
Requires disproportionate burden (exempt)73619.89%
Created before 23 September 2018  (exempt)42511.49%
Removed as outdated or no longer needed40310.89%
Replaced with compliant document or HTML webpage(s)1614.35%
Other - mostly forms in development902.43%
Used as evidence in original format (exempt)350.94%

On 8 December 2021, we recorded 3295 PDF and Word documents across the main Wiltshire Council website (, shared between 469 unique pages.

The majority of the documents we consider to be exempt through disproportionate burden fall within the following service areas:


The following two tables detail the number of users impacted by non-accessible documents over the last 12 months (recorded 8 December 2021).

Any pages on Wiltshire Council website (,378,384100%
Planning pages (*) 900,2449.59%
 Highways pages (*)92,4890.98%
Licences and permits pages (*)42,3110.45%
Accessibility statement (,9060.03%
Downloads in the last 12 monthsUsersPercentage
Downloaded any document391,1124.17%
Downloaded a document from Planning pages55,4180.59%
Downloaded a document from Highways pages12,1050.13%
Downloaded a document from Licences and permits pages8,7970.09%


Increasing the rate in which new and historic document files are converted to an accessible format in order to comply with accessibility regulations to WCAG AA standard would require adding additional technical resources to the core web team or service teams affected. At a time where budgets are being reduced across the council, we cannot afford to provide additional support to convert documents.

In an effort to increase the conversion rate of PDF forms specifically, we are in the process of recruiting an additional Web Operations Officer, which would double the number of technical resources dedicated to creating forms on this website. This position has been advertised at a salary range of £32,910 - £34,728 on five occasions in the last 24 months, three of which were advertised externally and once offered to agencies. As this role requires specialist technical knowledge, there are no additional existing resources available internally. 


We do not currently foresee a point where a disproportionate burden no longer applies but plan to review this on a yearly basis.

We currently have less then 12 months left until our contract with our current platform provider expires, however, moving platform would not help to resolve the issue as it is related to the files attached.


We have made an 11% reduction in files by removing 407 outdated documents in the last two months (8 September 2021) and plan to regularly review to ensure content remains up to date and relevant across all websites.


Accessible alternatives of any content can always be provided on request - visit Requesting alternative formats for more information.

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