Last updated:

20th June 2024

Non-accessible content

    The content listed below is non-accessible for the following reasons:

    Non-compliance with the accessibility regulations

    PDFs and other documents

    • Many of our older PDFs and Word documents don’t meet accessibility standards - for example, they may not be marked up so they’re accessible to a screen reader. We now have governance in place to make replacements in an accessible format. Any new PDFs or Word documents we publish will meet accessibility standards unless we determine that they represent a disproportionate burden within the meaning of the accessibility regulations. 
    • Some of our PDFs and Word documents are essential to providing our services. For example, we have PDFs with information on how users can access our services, and forms published as Word documents. 
    • 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.

    Third-Party Content

    Our website contains third-party content. We do not have control over and are not responsible for the accessibility of this content, but we endeavour to work with the third party to improve its accessibility. This may include:

    • Links to websites.
    • Content/functionality on our website.
    • Content hosted on other websites, such as social media sites.

    What we're doing to improve accessibility

    We regularly monitor the accessibility of this website using automated Quality Assurance software. We use this software to identify and fix any issues that arise.  We also use tools such as 'Accessibility Insights for Web' to assess our websites and find and fix issues.

    We work with our suppliers and third parties to ensure compliance with standards and plan for improvements and fixes where possible. 

    Disproportionate burden

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

    1. Make public sector websites and mobile applications accessible.
    2. 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. The following disproportionate burden assessments relate to a) Inacessible PDFs on our sites b) accessibility issues identified in our interactive chat tool, which is present on a number of website pages.

    Inaccessible PDFs

    Our assessment of the burden of making the large number of PDFs on our site into accessible versions is that:

    • there are historical documents created by the organisation
    • each document would require a number of hours of work to be recreated in a fully accessible version (estimated based on extensive experience of converting the active documents at between 2 and 30 hours per document, depending on length and complexity, plus any required sign-off)
    • many of the documents are officially published and publishing a new version requires detailed checking, a formal sign-off process
    • many of the documents contain complex elements which are difficult to retrospectively convert, such as detailed tables, graphs, and diagrams

     Also relevant to this decision are that:

    • Interest in these documents is low – few people access them
    • The documents do meet accessibility requirements for a large number of users, although some groups will find them disproportionately difficult
    • Of the documents we are proposing would represent a disproportionate burden, requests for additionally accessible versions are rare
    • We have and will always assist with accessible versions on request


    Where documents are no longer in active use, or no longer being updated, there is a high cost in terms of employee hours to convert. Some documents are part of the public record, but no longer represent the current position, and interest is limited. We always respond to requests for different formats on a case-by-case basis, so accessible versions are available on demand, with a short lead-time.

    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 cost.

    Interactive Chat Tool

    The interactive chat tool is provided via a third party widget, which is provided by a company called Netcall.

    The current interactive chat tool does not meet WCAG 2.2 AA standards for the following reason:

    When the screen is at 400% zoom, the chat bot displays text which should read ‘Wokingham Borough Council’ but this text is cut off and incomplete. This relates to the accessibility rule WCAG 1.4.10 Reflow

    The tool is provided by a third part under contract, the council does not have direct access to the design or codebase, which would be necessary to update the interactive chat tool to meet current obligations. We have contacted the third party and requested they make this change to their product but they have not been able to.


    The current interactive chat tool provides supplementary navigation services to our website users, helping them to find what they are looking for. The core functionality of the tool is not affected by the reflow issue. As core functionality is not impacted we will continue to use it, while we investigate possible improvement and replacement. 

    Mitigation and next steps

    The Council commits to:

    • Review the contract and/or provider's obligation to provide a fully compliant interactive chat tool. This will ensure that no reflow issues exist on the system's update or replacement. This action will be completed by July 2025.


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