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Disproportionate burden statement

Sport England is committed to meeting the requirement to make websites accessible, set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("the accessibility regulations").

Our approach to carrying out accessibility checks

We've decided to use a combination of methods, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the accessibility regulations. Detailed checks have been conducted on

The process for doing detailed checks includes:

  • manual testing based on GOV.UK's guidance on doing a detailed accessibility check

  • automated testing using accessibility monitoring software.

Our for covers problems we found for our website and our plans to fix them.

Disproportionate burden assessment

We believe that our approach to carrying out accessibility checks is reasonable.

However, the accessibility regulations say that we don't need to make all elements on a website accessible, if doing so would impose a disproportionate burden on us.

We've assessed that it'd be a disproportionate burden to fix all PDF documents published on this website since 23 September 2018.

From a total number of unique downloads from this date (for all file formats) of 812,889, of which PDFs account for 85%, we've only received a single complaint from website users and this was not related to accessibility. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified.

We'll therefore focus on ensuring that new documents are accessible where they're required for essential services or specifically address the needs of, or are meant for, disabled people.


As of 26 May 2021, there were 386 documents on our main website published since 23 September 2018 (within scope of the accessibility regulations), however, if you consider our web estate prior to this, there would be a total of 868 historic documents created by the organisation.

Estimated costs

It's difficult to know how long it'd take to make every document accessible without first reviewing each one. Potentially, each document would require several hours of work to be recreated in a fully accessible version.

Based on testing a sample of 12 files, converting the documents using Adobe Acrobat pro will take between one and 32 hours per document (depending on length and complexity, plus any required sign-off, or subject matter expert involvement). To WCAG 2.1 AA certification, the hours will be higher.

If we use a conservative estimate of four hours to review and fix each document within scope, fixing all 386 would take 206 working days (based on a 7.5-hour working day at Sport England). On the basis of these assumptions, we estimate the cost to our organisation for fixing the documents would be £144,200.

Assessment of costs and benefits

We believe that:

  • The size, resources and nature of our organisation mean that there are limited public resources available which must be managed appropriately and in the public interest to prioritise the delivery of essential services to the public

  • The costs of paying for fixing all of the documents on our website would be a substantial burden on us and the public resources we manage

  • The benefit to users would be limited and their needs can be met in other ways

  • Therefore, fixing all documents on our main website would impose a disproportionate burden on us.

In reaching this decision, we've considered the following:

Our organisation’s size, resources, and nature

Sport England is a non-departmental public body under the Department for Digital, Culture, Media and Sport. Its role is to build the foundations of a community sport system by working with national governing bodies of sport, and other funded partners, to grow the number of people doing sport; sustain participation levels; and help more talented people from all diverse backgrounds excel by identifying them early, nurturing them, and helping them move up to the elite level.

Precious public resources are limited for the delivery of this broad remit.

During 2020, we've also prioritised resources owing to the coronavirus (Covid-19) pandemic, supporting sports clubs with emergency funding and safeguarding public health. Redirecting resources away from these and forward objectives, when there has already been significant investment into making accessible, would not be in the public interest.

The estimated costs and benefits for our organisation: fixing documents

The vast majority of this work would have little to no benefit to users with disabilities, based on the lack of historical complaints (in relation to the accessibility of these online documents).

The estimated benefits to users

Our users with disabilities will benefit from us making our websites and online documents accessible.

For our main website, we're already undertaking detailed accessibility checks, fixing content, and ensuring that new documents are accessible where they're required for essential services or specifically address the needs of, or are meant for, disabled people. This focuses our accessibility improvements where they'll provide the most benefits to disabled people.

However, for, we don't believe that the limited additional improvements that could be gained from historical document fixes would justify the substantial costs of doing so.

How to request content in an accessible format

If you need information in a different format, visit and tell us:

  • the web address (URL) of the content

  • your name and email address

  • the format you need, for example, audio CD, braille, BSL or large print, accessible PDF.

We’ll consider your request and get back to you as soon as possible.

This assessment was made on 30 August 2021.

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