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Disproportionate burden assessment for PDF documents

The University of Bradford submitted a disproportionate burden assessment in relation to WCAG 1.3.1 Info and Relationships impacting PDF documents, dated 28 June 2022.

The University makes use of PDFs to distribute documents created in office productivity suites or to make graphical content portable and easy to print, since the opening of PDF files is native to many devices’ applications and operating systems. The University generally makes use of such files for the purposes to make information available publicly, to demonstrate and provide evidence of transparency and governance, as well as marketing activity.

The University also uses PDF documents to retain information in a durable format relating to details of the University’s student contract at any given time, and is required under consumer legislation to make this information available in this durable format

This assessment examines the cost and benefits making documents hosted on the website compliant with WCAG 2.1 based on:

  • The number of documents identified with accessibility issues
  • The number of service users of the University Disability Services
  • The impact of resolving all issues in affected documents on the organisation’s operational activities
  • The ability to provide content in these documents in alternative formats and the number of such requests

Size, resources, and nature of the University of Bradford (Regulation 7(3)(a) PSB 2018))

The University of Bradford is a higher education establishment that serves to “advance education and knowledge through teaching and research;” according to its Charter.

The University employs 1502 ‘core’ staff (this excludes casual workers and non-paid associates). It attracts students from both domestic and international markets. There are 12,370 students currently enrolled on any programme of study as of 28 June 2022.

For 2021/22 the University of Bradford Disability Service identified 37 students based on Learner Support Profiles (LSPs) and Higher Education Statistics Agency (HESA) disability categories where alternative formats for documents are required as part of those LSPs.

From 28 June 2021 to 27 June 2022, the University website had 2.28 million website users with the average session duration on the website being 3 minutes. These figures include all University website users, including employees and students on campus.

Estimated costs and benefits for the University of Bradford in relation to the estimated benefits for persons with disabilities (Regulation 7(3)(b) PSB 2018))

The accessibility auditing platform indicates there are 888 PDF files with one or more accessibility issues. The University estimates that, across this number, the average time required per document to fix accessibility issues could be up to 1 hour due to the varying nature of the documents.

This forms the basis of a calculation and scenario to scope and determine the impact this would place on the operational activity of the University, resulting in 888 working hours or approx. 24.5 weeks (5.75 months) where the University’s standard employment contractual hours are 36.25 hours. In this scenario, University employees would be taken away from other duties, which may include serving the requirements of people with website accessibility needs.

There were 37 students identified within the University who could benefit from making these PDFs fully compliant (0.3% of the University student population. The University marketing department (responsible for the website) received a total of two requests for document alternative formats during the academic year 2021-2022.

The benefits of having accessible PDFs for people with disabilities is that they are not excluded from the ability to understand the information contained with the documents against other people. It is considered that there are more proportionate means to address this approach rather than correcting all PDF documents within 12 weeks (see below).

The benefits to the University of correcting issues identified with PDF files would be that users of the website who access the files, and who have any disabilities, are able to make use of and understand the content of the files.


Comparing the costs and benefits as described above, there would be a disproportionate burden upon the University of carrying out this work within the 12 week period specified, when considering University resource constraints, the population of disability service users and the number of requests for documents in alternative formats received in the last academic year.

Nevertheless, to address this requirement:

  • The University has expressly acknowledged this issue within its accessibility statement published at:
  • Any person may request documentation provided on the website in alternative formats at present
  • In addition, the University has implemented a policy review process through which much of the PDF document produced and published on the website will be periodically reviewed. As and when these documents are reviewed and new PDF documents produced, the accessibility issues relating to these documents will be addressed at the same time. This is considered a sensible and proportionate means of correcting the accessibility issues with PDF documents on the website, having regard to the resource burden outlined above.