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The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 states that public sector websites must publish content in an accessible format. 

Our payment system uses a 3rd party site to process payments Civica Payments Portal - Products & services (

Testing revealed the following accessibility failures:

Some text or user interface components within these services do not have sufficient colour contrast. This does not meet WCAG 2.1 success criterion 1.4.3 (contrast (minimum))

There’s no way to skip the repeated content in the page header (for example, a ‘skip to main content’ option). This does not meet WCAG 2.1 success criterion 2.4.1 (bypass blocks).

Some of our interactive forms are difficult to navigate using a keyboard. For example, because some form controls are missing a ‘label’ tag. This does not meet WCAG 2.1 success criterion 3.3.2 (Labels or Instructions) and 1.3.1 (Info and Relationships). It can also be difficult to tell where you are when using a keyboard. This does not meet WCAG 2.1 success criterion 2.4.7 (focus visible)

Benefits of creating an accessible version

The benefits of an accessible version of the payments system:

  • a fully accessible version for all users to access


We requested costings from our current supplier for upgrading our current system for full compliance which is outside of our service agreement.

Costings were supplied as sensitive commercial information and therefore not published but a full upgrade would equate to approximate 8.5 times our annual budget for the website.

Other factors

We currently have less than 5% of our population signed up for payment accounts with only about 1% logging on in 2021 therefore demand appears to be relatively low compared to the costs involved.


Given the cost of changes to our current systems and the length of time any changes made would be in place for it has been decided that upgrading the current system at this time places a disproportionate financial and resource burden on the authority and doesn’t represent a responsible spending of public money.


An alternative supplier has been sourced for payment processing, one which ensures compliance with the current accessibility regulations and, promises updates and fixes if issues are identified with any no compliance elements.

Switch over to the new supplier is anticipated to be completed by summer 2022.

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