Guidance

Disproportionate burden assessment for CTS Online

Published 20 December 2024

Applies to England and Wales

Impact on users

Our service and information is not specifically aimed at disabled people.

Our service and information does not specifically enable people to participate in general society.

Impact

The form is a Word document with some locked sections. It has the following accessibility issues that we think will make it difficult for screen reader users to fill in the form:

• no table headers
• merged cells in the table
• text aligned within a single cell that will not have the correct reading order
• a broken tab order

Keyboard only users:

• not all functionality can be accessed with a keyboard

• no skip links

Service can be used but will encounter barriers

Low vision or colour blind users:

• use of colour to convey information

• poor colour contrast

Service can be used but will encounter barriers

People who need larger text size or to zoom in:

• service does not reflow

• text spacing causes content to be clipped

Users not able to use the service without encountering many barriers.

Numbers affected

Estimate of users affected if we don’t make the information or service completely accessible: 56,000

Source of this data: Estimated total users that have access to CTSO. Source BCMS Operations.

The burden that making those things accessible places on your organisation

Details of the public sector body

Name of the public body: Rural Payments Agency

Nature of the public sector body: The Rural Payments Agency is an executive agency of the UK Department for Environment, Food and Rural Affairs. Prior to Brexit, the RPA delivered the European Union Common Agricultural Policy payments to farmers and traders in England,

Size, resources and budget: 3,000 employees organisation. £100 million annual budget.

Reason for burden

• Costs for the change is excessively high to amend
• There is a short timeframe left for this product. It will be replaced within 24 months

Time or cost to make accessible

• Create new fully responsive screens for CTS Online for all 286 pages
• The Supplier to redevelop the UI to meet WCAG 2.1 AA Accessibility

For the Project Implementation of both CTS Online and AMLS, one-time Charges are estimated to be in the region of £2,000,000 to £3,800,000, excluding Expenses and VAT.

The solution and price information in this document is, as requested, an indicative rough order of magnitude estimate and is intended to be for general guidance and budget planning purposes only.

This estimate is based on the terms and conditions of the Contract C5495.

Decision and claim

Claim

We’ve assessed the cost of fixing the issues. We believe that the burden of this cost would be disproportionate to the modest estimated benefits for persons with disabilities, considering the relatively low number of users and the low continuing duration of the software indicated. We believe that the benefit to the RPA of implementing changes now would consequently also be modest, and again the associated cost of that would be disproportionate.

We have added the claim for disproportionate burden to our accessibility statement.

Reason

• The resource available for a taxpayer funded organisation

• The costs of up to £3.8million for two Rural Payments services which will be replaced within 24 months

Review date

We will review this assessment on 1 April 2025.

Review and approval

Legal

This claim and assessment was checked and approved by the DEFRA legal officer on 18 April 2024.

Sign off by a senior responsible officer

This claim and assessment was checked and approved by Terry Gadd, Information Asset Owner and RPA Lead for Livestock & Trader Schemes & Services, on 19 April 2024.

Sign off by a senior responsible officer

This claim and assessment was checked and approved by Terry Gadd, Information Asset Owner and RPA Lead for Livestock & Trader Schemes & Services, on 19 April 2024.