Disproportionate burden assessment - non-CMS sites

The disproportionate burden assessment for our non-CMS sites.

  • Date: 18 January 2022
  • Latest revision: 31 March 2022


As of September 2018, accessibility legislation states that public sector websites must publish content in an accessible format. 

The wider university digital estate (non-CMS and hosted on cPanel) has at least 1,130 websites.

Benefits of creating an accessible version

All visitors to the cPanel-based, University-affiliated websites and applications will be able to use accessible websites and access content in an accessible format.


We’ve estimated that to review and migrate all the websites would take 12 years 7 months with a team of two. 

We conducted an initial review of a sample of 160 sites in January 2021 to estimate that with a dedicated team of four content specialists we could review and remedy the sites over a 2-3 year period through retiring sites or migrating them to accessible platforms.

In addition, the subject matter experts, technologists and principal investigators who commissioned every website would be required to engage with the project to review content, site functionality and maintenance and seek approval. Based on the previous build and migration of the public website, we estimate this requires 95 hours per site over a 12 week period. There are 1,130 sites which equates to 107,350 hours.

Other factors

The cPanel service is used to host highly bespoke, technical features such as research project work, and for that reason many do not have a large volume of visitors and require greater technical resource to develop fully accessible solutions every time. 

The University has related projects running to help meet accessibility standards. 

These include a public website project and an internal website project, all drawing on the same pool of staff for their expertise and knowledge of systems.


Due to the scale of the work; the need for staff from all areas of the organisation to review its content; and experience from a previous web migration project delivering an accessible website; it is not feasible to make every website WCAG 2.1 AA compliant before August 31 2022 and doing so would be a disproportionate burden.

The project to review the 1,130 websites is in progress and is due to complete 30 June 2023.

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