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Disproportionate burden assessment: Taking steps to ensure accessibility of the current PSOW website



The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 require public sector bodies, subject to various exemptions and conditions, to:

  • Make public sector websites and mobile applications accessible.
  • Provide an accessibility statement.

The accessibility regulations state that a public sector body does not need to meet the accessibility requirement if this would put a disproportionate burden on them, provided that a disproportionate burden assessment is undertaken.

We have carried out a disproportionate burden assessment on the possible steps we could take to ensure accessibility of the current our website. This means we are not able to offer fully accessible versions of the website at this time. The assessment below sets out our reasons, on the grounds that a new product is due to shortly supersede the existing website.

The issue

Our website is currently not fully accessible. Government Digital Service checked the website ( on 9 October 2023 against the Web Content Accessibility Guidelines (WCAG) 2.1 AA standard. Based on the testing, it decided that the site is partially compliant with WCAG 2.1 AA. This means there are some things which are not fully accessible. These include issues in relation to:

  • accessibility of some of the website content using keyboard at high zoom (over 200%)
  • visibility of keyboard focus and some navigation features in some sections of the website at high zoom (over 200%)
  • keyboard navigation not always reflecting a navigation sequence that is consistent with the meaning of content
  • a lack of ability to dismiss some content without changing the hover or focus
  • colour contrast in some sections of the website
  • a lack of ALT text and page titles in a PDF document tested

The audit underlined that it focused only on the most common barriers to users with accessibility needs and that a fully audit of the website may uncover other accessibility issues. The audit also noted a lack of up to date Accessibility Statement.

PSOW operates two separate sites, in English ( and Welsh ( Any accessibility issues affecting the English language will also affect the Welsh language site.

Government Digital Service informed us of the intention to retest our website after 2 February 2024 to ensure that any accessibility issues have been addressed.

Benefits of creating an accessible version

Users would be able to use fully accessible PSOW website, helping to remove barriers that some users may be facing when engaging with PSOW content.


There are two ways to resolve the existing issues:

  • undertake full accessibility audit and amend the existing website in line with the audit findings
  • develop a new website, with clear focus on meeting accessibility standards and accessibility audit undertaken prior to website launch.


Over the recent years, we have identified and addressed some accessibility issues in a piecemeal fashion. For instance, we developed new brand colours to ensure that the colour contrasts across most of the site are accessible. However, these incremental amendments involve significant costs and do not allow us to address broader issues with accessibility of our website user journey. For this reason, in November 2022 we invited tender applications to develop a new website.

The tender specification for this project underlined that the product must be fully W3C compliant and enables easy access for vulnerable users. We will ensure our website designers take these issues and requirements fully into account and will arrange accessibility testing of the new website during development and once launched.

The new website is on track to be in place by 27 February 2024.

To undertake an accessibility audit of our current website and to address the existing issues at this point would incur costs greater than the organisation has funds for. It would also not represent value for money, as the new product is in development, with attention to accessibility integral to the development process. As such, option 1 would be a disproportionate burden and option 2 is preferable and already in progress.

In light of this, we have requested that Government Digital Service delays retesting of our website until the new product is in place.