Guidance

Disproportionate burden assessment for AMLS2

Published 17 December 2024

Applies to England

Assessment for: AMLS2 

URL: https://t1.amls.defra.gov.uk 

Assessment completed on: 29/05/2023

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

Assistive technology may not be able to render text as accurately as the language is not able to be identified

Keyboard only users: 

• there is no way to bypass blocks of content present across multiple pages
• edit field is automatically focused which can be navigationally disorientating as does not start at the beginning
• visually hidden links showing
• subheadings do not have a visible downward facing chevron to indicate drop-down links
• images which link to information are not able to be accessed
• unexplained terminology

Service can be used but will encounter barriers

Screen reader users:

• there is no way to bypass blocks of content present across multiple pages.
• page titles unspecific meaning title is not able to be used to distinguish between pages
• no indication whether search has been successfully submitted and updated
• images do not give supplementary information. For example, whether the image is decorative and to be ignored or whether it’s functional and has information or a link
• unclear what information is required at times as it shows as ‘unlabelled’
• headings not in logical order / clearly structured
• visually hidden links showing
• bold and colour used for emphasis which does not feed through
• relationship between the table headers and the table data not relayed
• items not grouped so not able to identify how items are related to each other
• no alert when a link takes them into a new tab
• labels and fields not programmatically associated with each other
• logged off due to timeout without previous warning
• missing descriptive labels
• unexplained terminology
• examples not identifiable

Service can be used but will encounter barriers.

Voice activation users:

• fields have no accessible name by which they may be referenced via voice activation software
• visually hidden links showing
• bold and colour used for emphasis which does not feed through
• images which link to information not able to be accessed
• unexplained terminology

Service can be used but will encounter barriers

Low vision users:

• visually hidden links showing
• when zoomed in, page contents spill off the sides
• content missing to explain pages
• unexplained terminology
• badly formatted layout
• controls and navigational buttons not highlighted when hovered over in high contrast mode

Service can be used but will encounter barriers

Numbers affected

Estimate of users affected if we don’t make the information or service completely accessible: 1,785

Source of this data: estimated total users that have access to AMLS2. Source AMLS team.

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 (RPA)

Nature of the public sector body: The RPA 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

1. costs for the change is excessively high to amend
2. 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 AMLS2 for all 230 pages (192 dynamic screens and 94 static screens)
• 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 the Information Asset Owner and RPA Lead for Livestock & Trader Schemes & Services, on 19 April 2024.