89f9cffe-ad5e-4d4f-aca5-c950f2a5d99f_St_Stephen_in_Brannel_Accessibility_Proposal-artifacted.pdf — PaddleOCR-VL (Baidu)

Proportionate action is permitted—but must be evidenced

The regulations recognise that fixing everything immediately may create a disproportionate burden. Any staged approach should still consider organisational size and resources, cost, impact and the benefit to disabled users. The basis for prioritisation should be recorded and reflected in the accessibility statement where relevant.

Documents and the 23 September 2018 exemption

PDFs published before 23 September 2018 are generally exempt unless users need them to access a service. The crawl identified 72 PDFs / 283 pages under this date filter. These should be reviewed rather than automatically retained: essential content may remain in scope, while genuinely historic material may be archived.

THE GOVERNANCE TEST: Could the council show what it assessed, how it prioritised the estate, what it completed, what remains and the evidence supporting its staged plan?

Assessment outcomes

The council has a strong process and capable staff. The assessment shows why a more automated and WCAG-focused workflow would still add value.

1. Current publishing process

New documents are checked in Word, converted to PDF and checked again in Adobe; some documents are checked a third time before or after publication.
Policies and older documents are being improved gradually through the council's three-year review cycle.
Third-party PDFs and tables require more technical correction and can take substantially longer than documents created internally.
A recent batch of meeting documents took approximately 70 minutes to check and upload, notwithstanding some interruptions.

2. Why double-checking is not enough

Adobe’s checker is useful and is closely associated with PDF/UA, but it does not map perfectly to every WCAG 2.2 technique expected of a public-sector body. Passing one checker is therefore not the same as demonstrating full WCAG conformance.