Digital Health and Care Wales (DHCW) is an expert national body and part of NHS Wales.
We work in partnership with NHS Wales colleagues and other key stakeholders to provide national digital and data services which support the delivery of health and social care in Wales.
Our website is one way that we communicate information about our services to stakeholders, including patients, the public, and NHS Wales health boards.
DHCW is committed to making our website accessible as set out in the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. This includes making our websites and mobile apps accessible and publishing an accessibility statement.
Public bodies must comply with version 2.2 of the Web Content Accessibility Guidelines (WCAG) AA requirements at levels A and AA.
These regulations state that when it is not feasible for a public sector body to meet one of these accessibility requirements, for example because it is difficult to fix or too expensive, they must provide a disproportionate burden assessment.
We have prepared this disproportionate burden assessment to describe why we are not able to offer fully accessible versions of some content on the site, specifically PDF documents.
The DHCW website hosts a large number of PDFs that do not meet WCAG 2.2 accessibility guidelines. There are 1,093 in total as of April 2025, which have been created by multiple authors over several years. They are primarily technical or corporate, and are mostly related to:
Some of the issues identified in the PDFs include:
We believe that the total time and cost of fixing all of these PDF documents to meet accessibility standards represents a disproportionate burden.
We estimate it would take up to 3 hours to fix each document to the recommended WCAG 2.2 accessibility requirements. This is because a significant number of the documents are particularly long and complex, like board and committee papers. For example, in 2024, the average length of our board papers was 224 pages per document.
To fix all 1,093 PDFs, it could take up to 437 working days in total (based on one member of staff and a typical DHCW working day of 7.5 hours). This would take Communications team resource away from other high-priority work, including the continued development of new HTML pages.
We know that inaccessible PDF documents can be difficult to read and understand. We offer alternative support to users who have additional access needs. To request an accessible PDF, large print, easy read, audio recording or braille, contact: dhcw-enquiries@wales.nhs.uk. We will consider your request and get back to you in 10 working days.
We provide all content that is essential to providing a service in an HTML format, including information about our programmes and products. Pages that host PDFs see a much lower level of traffic, which means the number of people who would benefit from making the accessibility fixes is smaller.
For example, the number of unique users to pages that house board paper PDFs accounts for 0.46% of all website users:
(Based on 12 months of Google Analytics data captured from 1 March 2024 - 28 February 2025).
We are committed to improving accessibility. We want all users to be able to navigate and understand our content.
The Communications team is responsible for publishing most of the organisational and service-led information on the website. We've created a roadmap with three workstreams that focus on improving users' experience and further reducing the number of inaccessible PDFs on the website. These workstreams are:
We began a site-wide audit beginning in March 2025 to address all historic inaccessible PDF content. We aim to evaluate each document and determine its value based on how many people visit it, its importance to business continuity, and its impact on end users. We will use this information, together with the content of the PDF, to inform whether we should:
We aim to complete this audit by March 2026. We will provide an update here in March 2026.
We have a separate workstream for board and committee documents because of their size and how they're created, detailed below.
As a rule, the Communications team no longer adds PDFs to the website when requested. Instead, we either create an HTML web page from the content or suggest an alternative place to publish the PDF.
However, there are rare occasions when a PDF format is deemed essential for business or reporting purposes, like our board papers.
The DHCW Corporate Governance team currently uses software called AdminControl to create and manage the board and committee papers that are published on the website. This software does not meet several WCAG 2.2 compliance criteria, for example, the documents it produces have:
We are aware of this and working with AdminControl to make the improvements needed. As of March 2025, AdminControl has accessibility improvement work scheduled for completion in late 2025. We will continue to work with the product's development team to follow progress.
To supplement this, we are improving the accessibility of the templates that we submit to AdminControl, including reducing the number of unnecessary tables and setting the correct colour contrast. We are also providing further guidance to staff about accessibility checking tools and their responsibilities as document publishers.
A paper to advocate for DHCW's move to HTML-first publishing was developed in 2022, outlining the practical steps needed to reduce the organisation's reliance upon PDFs. It addressed:
Work is continuing in these areas. Since implementation, the number of new PDFs being added to the site has been significantly reduced, and many of DHCW's major publications have been published for the first time in HTML, including its Annual Report (2023 onwards) and Organisational Strategy (2024).
We offer alternative support to users who have additional access needs. To request an accessible PDF, large print, easy read, audio recording or braille, contact dhcw-enquiries@wales.nhs.uk. We will consider your request and get back to you in 10 working days.
This assessment was prepared in March 2025. It will be updated to reflect further progress in March 2026.