Disproportionate Burden Assessment

Organisation: Shropshire Fire and Rescue Service
Website: https://www.shropshirefire.gov.uk
Date of Assessment: 10/03/2026

1. Reason for this Assessment

Shropshire Fire and Rescue Service (SFRS) received accessibility findings from the Government Digital Service (GDS) as part of their statutory monitoring under the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. These findings highlighted areas of non‑compliance and required SFRS to complete a formal disproportionate burden assessment before referencing any disproportionate burden claim in the Accessibility Statement, as instructed by GDS.

This assessment considers whether fixing all highlighted issues immediately—during the review phase of our newly launched website—would place a disproportionate burden on the organisation.

2. Context and Background

SFRS has recently launched a new website to replace the legacy Drupal 7 platform, which had reached end‑of‑life and failed a number of accessibility requirements identified during the 2022 GDS audit.

Immediate high‑impact issues were previously remediated through outsourced work (costing £2,000), but further fixes were delayed due to the decision to fully redevelop and replace the old platform.

Following launch, the new website is now in a structured review phase. Developers are actively investigating all reported issues and are working to rectify them as part of the ongoing post‑launch development cycle.

3. Why Fixing All Issues Immediately Would Be a Disproportionate Burden

After reviewing available resources, operational impact and the nature of the outstanding issues, SFRS concludes that fully resolving all identified defects immediately—rather than as part of the planned review and improvement cycle—would place a disproportionate burden on the organisation for the following reasons:

3.1 Operational Impact During Critical Review Phase

The new website has only just launched, and the service is currently within the stabilisation and review window required to identify, triage and resolve post‑launch issues. GDS confirmed that the new site has now gone live and is under review.

Prioritising wholesale corrections outside of this structured process would divert resources away from essential launch‑stability work and disrupt the planned progressive fixes that are already underway.

3.2 Developer Capacity and Ongoing Investigations

All outstanding accessibility issues—including those listed within Level 1, 2 and 3 severity categories—are currently being investigated by the website developers. These are being addressed as part of the agreed remedial schedule following launch. Forcing immediate intervention on all issues would require significant developer reallocation, compromising both quality and timelines for sustainable fixes.

3.3 Resource and Cost Constraints

SFRS has already invested in outsourcing accessibility remediation work on the previous website and absorbed the cost of a full platform rebuild.

Redirecting additional budget into expedited development work at this stage—outside of the scheduled review programme—would impose further unplanned costs that are disproportionate to the marginal benefit of delivering fixes a few weeks sooner.

3.4 Limited User Benefit of Immediate Full Fixes

All issues identified by GDS relate to defects in specific components (e.g., focus indicators, labelling, role assignments, instructional wording). These are being addressed systematically as part of the post‑launch phase. Addressing all issues instantly, rather than in a controlled sequence, would offer minimal short‑term benefit compared to the long‑term improvement already planned and resourced.

3.5 Planned Remediation Pathway Already in Place

The new platform has been designed with accessibility compliance as a core requirement and is still undergoing refinement. The earlier disproportionate burden assessment stated that rapid fixes on the retiring website would divert resource from the new accessible site; this logic extends to the current context, where immediate all‑at‑once fixes would disrupt planned development work.

4. Actions Already Taken

SFRS has:

• Launched a new website designed for WCAG 2.2 AA compliance.
• Actively logged and prioritised all issues identified by GDS.
• Confirmed developers are investigating and rectifying issues in the review phase.
• Addressed immediate high‑risk accessibility issues where feasible.
• Ensured a compliant accessibility statement is being prepared, including method of testing, as required by GDS.

5. Future Timeline for Fixes

• All identified issues will be addressed progressively during the ongoing post‑launch review and development cycle.
• Fixes will be deployed in scheduled development sprints rather than through urgent, accelerated intervention.
• Full accessibility compliance is expected as part of the continuous improvement plan for the new website.

6. Conclusion

SFRS concludes that fixing all accessibility issues immediately—outside the structured post‑launch review process—would impose a disproportionate burden in terms of cost, developer resource, and operational stability.

All issues are already under remediation, and SFRS is committed to bringing the website to full WCAG 2.2 AA compliance through a managed, sustainable improvement process.

This assessment is retained and available on request, in line with GDS requirements for monitoring bodies.