Accessible documents policy

This policy explains how accessible the documents Rural Payments Agency (RPA) publishes on GOV.UK are.


Accessible documents policy at Rural Payments Agency

This policy explains how accessible the documents the Rural Payments Agency (RPA) publishes on GOV.UK are. It covers PDFs, spreadsheets, presentations and other types of document. It does not cover content published on GOV.UK as HTML: the main GOV.UK accessibility statement will cover that.

Using our documents

The RPA publishes documents in a range of formats, including:

  • PDF
  • PDF forms
  • Microsoft Excel
  • Microsoft Word
  • Microsoft PowerPoint
  • OpenDocument formats (for example .odt or .ods)

We want as many people as possible to be able to use these documents. For example, when we produce a document we:

  • provide an HTML option where possible
  • avoid using tables, except when we’re presenting data
  • write in plain English - although some content contains legal or other technical language
  • include a text alternative alongside non-decorative images, so people who cannot see them understand what they’re there for
  • tag headings and other parts of the document, so screen readers can understand the page structure
  • make document titles clear and meaningful
  • use descriptive link text so people understand the purpose of each link
  • avoid writing instructions that rely on visual cues

How accessible our documents are

New documents we publish and documents you need to download or fill in to access one of the services we provide should be fully accessible.

However, we know that some of our older documents (published before 23 September 2018) are not accessible. For example, some of them:

  • are PDFs that are not tagged properly
  • are not written in plain English
  • are forms that are difficult to navigate using just a keyboard
  • contain images with no description
  • include complex tables
  • are forms that have guidance in a separate PDF to help completion

This mostly applies to these document types:

  • corporate reports
  • technical guidance
  • consultations and their supporting documents
  • research and analysis reports
  • statutory guidance
  • forms
  • statistics

These types of documents are exempt from the regulations, so we do not currently have any plans to make them accessible.

But if you need to access information in one of these document types, you can contact us and ask for an alternative format.

What to do if you cannot use one of our documents

If you need a document we’ve published in a different format:

We’ll consider the request and get back to you within 15 working days.

Reporting accessibility problems with one of our documents

We’re always looking to improve the accessibility of our documents. If you find any problems that are not listed on this page or you think we’re not meeting accessibility requirements, contact webmaster.rpa@rpa.gov.uk. We will look into your comments.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’).

If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Technical information about the accessibility of our documents

The Rural Payments Agency is committed to making our documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

The documents the Rural Payments Agency publishes are partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances listed below.

Non-accessible content

The content listed below is non accessible for the following reasons.

Non-compliance with the accessibility regulations

The content listed below is non-accessible for the following reasons:

Some of our documents have diagrams with no text alternative. The information in these diagrams is not available to people using a screen reader. This does not meet WCAG 2.1 success criterion 1.1.1 (non-text content). We will add text alternatives for all diagrams.

Some of our documents have diagrams that do not meet the colour contrast ratio of at least 3:1. These diagrams may be difficult to see, or completely missed, by people with a visual impairment. This does not meet WCAG 2.1 success criterion 1.4.11 (non-text contrast). We will make sure our diagrams meet colour contrast requirements.

A few of our documents have diagrams that use colour as the only means of conveying information. The information in these diagrams may not be perceived by users with colour vision deficiencies. This does not meet WCAG 2.1 success criterion 1.4.1 (use of colour). We will make sure information is not only conveyed through colour but also by other means.

Some of our forms do not have page functionality available for using a keyboard. This content cannot be operated through a keyboard or keyboard interface. This does not meet WCAG 2.1 success criterion 2.1.1 (keyboard). We will make sure forms meet the keyboard requirements.

Some of our documents are published in an unstructured PDF. Headings, list items and paragraphs may not be recognised by a screen reader. This does not meet WCAG 2.1 success criterion 1.3.1 (info and relationships). We will make sure documents are published with the appropriate structure.

Some of our spreadsheets may not be clearly structured with labelled tables, and labelled headings. Column headings may be blank. Workbook tabs may not have a clear title. This does not meet success criterion 1.3.1 (info and relationships). We will make sure they have an appropriate structure.

Some of our documents are published using tables to lay out text in columns on the page. This often hides content from the navigation pane or table of contents. This does not meet success criterion 2.4.6 (headings and labels) or success criterion 1.3.1 (info and relationships). We will make sure that tables are not used to lay out text.

Disproportionate burden

We have:

  • reviewed our documents published on GOV.UK since 23 September 2018
  • identified that it would be a disproportionate burden to make all documents fully compliant
  • fixed documents that are most used and are essential to providing our main services

This means that some of the following types of content are not fully compliant:

  • spreadsheets which include macros and cannot easily be produced delivered in a different format
  • technical papers aimed at a small audience
  • some forms (particularly if they are complex)
  • legal instruments where we have to replicate the exact formatting, such as byelaws, charging schemes and standard rules

Contact us if you need these documents in an alternative format at the following email address: webmaster.rpa@rpa.gov.uk

Content that’s not within the scope of the accessibility regulations

Many of our older PDFs and Word documents do not meet accessibility standards - for example, they may not be structured so they’re accessible to a screen reader. This does not meet WCAG 2.1 success criterion 4.1.2 (name, role value).

Some of our documents contain maps. This does not meet a number of WCAG 2.1 success criteria, including 1.3, 1.4, 2.4, 2.5, 3.1 and 3.2. These types of documents are exempt from the regulations, so we do not currently have any plans to make them accessible. We will consider the use of maps in our documents and provide a text alternative if appropriate.

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services.

How we tested our documents

In January 2020 we audited all documents published since 23 September 2018. The Defra content team carried out the audit. As part of the audit we tested these documents to find accessibility issues.

We tested:

  • PDF documents
  • Microsoft Word documents

We decided to test these types of document as, aside from HTML, these are the most commonly used document formats the RPA publishes online.

What we’re doing to improve accessibility

RPA is:

  • updating corporate Word and PDF templates to an accessible format
  • creating corporate reports as HTML rather than PDF where possible
  • creating guidance documents in HTML rather than PDF, where possible
  • raising awareness across the organisation of the accessibility requirements
  • training staff on meeting accessibility standards
  • testing with disability networks and assistive technology software
  • making every effort to provide new or revised documents in an accessible format

This page was prepared on 18 September 2019. It was last updated on 22 September 2023.