Digital accessibility

To help better understand what the digital accessibility regulations mean for public sector bodies, LGcomms, the Local Government Association and the Government Digital Service hosted a webinar, led by Richard Morton, Head of Accessibility at the Government Digital Service.

You can now watch a recording of the webinar, which includes an overview of the regulations and practical tips on how to improve accessibility. 

There were a number of questions posed by delegates that Richard Morton was unable to get to during the webinar. He has subsequently answered them below.

Are there any tools available where you can check contrasts of web and social graphics?

A: There are a number of different tools around, some are online, some are downloadable. One we use is a tool we developed in house

Presumably mobile apps include social – Facebook, Twitter, Instagram. We would need to add text on images using Alt text option?

A: No, mobile apps for the purposes of the regulations are apps created by or procured by a public sector body. For example the HMRC personal tax app, and the Transport for London TfL Go app. It is of course still important to make Facebook, Twitter, LinkedIn, Instagram etc. posts accessible and alt text is part of that.

Where a website has been built by a third party, would claiming disproportionate burden apply to financially stricken LAs where they are unable to provide budget to the third party business to conduct accessibility related alterations to a bespoke website?

A: Guidance around disproportionate burden is at – you would need to do an analysis of the costs versus the benefits, and even if you claim disproportionate burden, the Equality Act and Public Sector Equality Duty still apply, so you need to understand whether that puts you at legal risk – if in doubt consult your legal team.

Is the onus on us or our suppliers to ensure existing third party systems are compliant?

A: No, the onus is on the public sector body who publish the website/intranet/extranet/app/document – suppliers will only have obligations under whatever contractual relationship they have with you.

Hi all, I’d love to know if you have any personal favourites/recommends for website audits/evaluation for accessibility.

A: Can’t give any specific recommendations in the interests of impartiality, but there are a small number of specialist providers, and my advice would be to make sure you have clear understanding of the scope of the work they will do, how they will communicate things, and whether you can observe testing (if that is important for you – and presumably not possible at the moment anyway). Worth asking them for a sample report (which could be anonymised) to get an idea of how their approach works.

What are the key things to look out for when producing accessible pdfs?

A: Similar to web pages: structure (which is done by tagging) of headings and other semantic elements, reading order (particularly as PDF was designed as a print medium so the source code order may not reflect the layout order), alternative text for images, and avoiding things like forms within PDF which are really difficult to make accessible. Good font choices/sizes, text/background contrast, meanginful link text…

We have thousands of archaeology documents. Some of them are scans of written or typed documents. Do these need to be transcribed. What about all the photos in the document?

A: For the new regulations, only if they were published after Sep 2018 (I am assuming they wouldn’t include content needed to access a service). For those documents published since then you could look into whether they count as third party content not under your control, or consider making a disproportionate burden assessment. Guidance is at and

Our interactive map is via Google.  How can we make it accessible please?

A: There may be customisation options you can use for colours and controls, and that may be via an API (Application Programming Interface). You do need to consider how the data in the map works though and how everyone could access that information.

We are an arms length organisation from our local authority – and are in the process of auditing and working towards compliance as we deliver public services. We have a sub-website for a project funded only until 2022 and this team think it will place disproportionate burden to progress through this process given limited funds anyway for project delivery. Can you give any guidance on this?

A: the guidance on disproportionate burden is at – we can’t offer further interpretation of the guidance so if in doubt you should seek legal advice.  

Does website accessibility software such as Browsealoud help achieve website compliance?

A: It can do. There are different schools of thought on these sorts of tools. Things to consider include: do the benefits outweigh the costs (which can be significant depending on your site traffic). Would someone who needs this feature already be using a screen reader so not benefit from it?

Any help and advice on how to ensure PDFs are more accessible would be a big help – either in amending existing PDFs or ensuring future PDFs are all accessible.

A: We link to some specific external guidance on this at from – for future PDFs it is also important to create a culture/process where accessibility is built in as much as possible, so for example if you don’t have Acrobat DC or DC Pro you can create accessible templates in Microsoft Word using proper heading styles which export the structure when saving as PDF. We would always recommend moving away from PDF though –