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We have 677 PDFs on our website, 28% of these are alternatives to HTML (for example downloadable version of HTML information), 4% are 3rd party documents, 31% were published pre September 2018, 10% are maps, 13% are hand completed scanned documents or documents with a wet ink signature that are required to be published as completed and 21% are planning policy documents which have been assessed separately.

The accessibility regulations don’t require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services.


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. 

This assessment relates to published PDF documents that are not exempt under the accessibility regulations (approximately 10% of the published documents).


The benefits of making these PDFs into accessible HTML formats would be:

  • Documents would be fully accessible to all users
  • Documents would be more easily searchable and indexable


Our assessment of the burden of making these PDFs into accessible HTML formats is that:

  • To recreate each document in an accessible format would take between 2 and 20 hours depending on the complexity of the document
  • many of the documents are non-essential information and are of interest or reference only
  • many of the documents contain complex elements which are difficult to retrospectively convert, such as detailed tables, graphs, and diagrams

Other factors

Also relevant to this decision are that:

  • Interest in many of these documents is low
  • Requests for additionally accessible versions are very rare and any requests will be responded to appropriately
  • Other code and regulation require us to publish information in machine readable e.g. csv format


We consider that the costs of converting older documents where there is little evidence of demand would be a poor use of limited staff time, and would represent a disproportionate burden on the organisation in terms of the cost that time represents.

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