What Is a VPAT? Tips for Filling Out a VPAT

The request usually arrives buried in an RFP. Somewhere in the procurement documents, past the security questionnaire and the insurance requirements, is a line asking for your VPAT. If you have never sold to a government buyer before, this is often the first time you learn that the document exists.

It is not a formality. For federal agencies and the organizations that work with them, Section 508 of the Rehabilitation Act(opens in a new tab) requires that information and communications technology (ICT) be accessible to people with disabilities. Agencies cannot buy what they can't verify, so they push the verification back to the vendor. Your VPAT is that verification.

Which puts you in an uncomfortable position. You are being asked to document your own product's accessibility gaps, in writing, for a buyer who is deciding whether to sign. The vendors who handle this well treat it as the opposite: a chance to show they understand their product deeply enough to name what does not work yet and what they are doing about it.

In this post, we provide an overview of VPAT objectives, break down the different types of VPATs, and share tips and resources for completing a VPAT.

What is a Voluntary Product Accessibility Template (VPAT)?

A VPAT is a standardized document that reports how well a product conforms to accessibility standards. Vendors complete it to show buyers which accessibility requirements their software, hardware, electronic content, or documentation meet, partially meet, or do not meet.

The standard a VPAT measures against depends on the buyer. Section 508 requires conformance with the Web Content Accessibility Guidelines (WCAG) version 2.0 Level AA. Some organizations may prefer to report against a newer version, so they include the success criteria from WCAG 2.1 (the de facto standards for ADA compliance) or WCAG 2.2. The template allows for this and buyers generally welcome it.

What a VPAT contains:

• The name, version, and description of the product being evaluated.

• The accessibility standard used for the evaluation, such as WCAG 2.0 Level AA or EN 301 549.

• The level of conformance claimed. Typically, this is Level AA. Learn more about WCAG conformance levels. 

• The methods and tools used for the evaluation.

• The results of the evaluation, along with remarks and explanations where relevant.

• The date of the evaluation and contact information for the assessor.

How a VPAT works in practice:

• Who completes it: The vendor selling the product, either internally or through a third-party assessor.

• Who asks for it: Federal agencies, state entities receiving federal funding, universities, and increasingly private enterprise buyers.

• What it covers: Most commonly, Section 508 standards, which incorporate WCAG 2.0 Level AA by reference.

• What it is not: Proof of legal compliance. It documents conformance to a technical standard at a point in time.

What is an Accessibility Conformance Report (ACR)?

An Accessibility Conformance Report (ACR) is a completed VPAT. The VPAT is the blank template; the ACR is the filled-out, published result, usually produced by an independent third-party assessor and written with more detail for end users.

For example, a VPAT may simply state that an app has text alternatives for non-text content — but the ACR might go into more detail about what those alternatives are and how they improve experiences for people. It may also include support documentation that directly demonstrates how the product supports the experiences of users with disabilities.

An ACR is a public document, typically created by an independent third-party assessor. The General Services Administration (GSA) recommends that vendors generate an ACR for “any ICT that’s intended to be marketed to the Federal government.”

The bottom line: you fill out a VPAT to produce an ACR. Most people asking for "your VPAT" are asking for your ACR.

Illustrations of different assistive technologies under a label that reads "Assistive Technology"

Why Use a VPAT?

Broadly, Section 508 compels federal agencies and their contractors to create, buy, and use electronic and information technology that is accessible to people with disabilities, whether they are employees or members of the public.

For users, that means all web content must be compatible with a broad range of assistive technologies, such as screen readers.

VPATs help operationalize accessibility into a series of templates in order to:

• Help procurement teams assess the accessibility of products before making a purchase.

• Help people understand the accessibility features and limitations of a product or service for disabled users.

Who Is Required to Fill Out a VPAT?

There is often confusion about who needs to complete a VPAT document. Section 508 is considered federal legislation, but it can also apply to:

• State, county, and municipal authorities that receive financial assistance from the US government.

• Universities, museums, galleries, medical centers, and other organizations that receive federal funding.

• Any contractor — regardless of size or services offered — that wants to work with the US government.

A courthouse with an arrow and a dollar sign that points to a place of business

What Are the Different Types of VPAT?

The Information Technology Industry Council(opens in a new tab) (ITI) is a global advocate for technology whose aim is to promote public policies and industry standards that advance competition and innovation worldwide.

The ITI has created four different editions of the VPAT(opens in a new tab), enabling agencies, manufacturers, and vendors to focus on the standards relevant to their specific markets and contract requirements:

• Revised Section 508 standards(opens in a new tab): the U.S. Federal accessibility standard.

• EN 301 549(opens in a new tab): the European Union’s “Accessibility requirements suitable for public procurement of ICT products and services in Europe.” Like most international digital accessibility laws, EN 301 549 is also based on WCAG.

• WCAG: Web Content Accessibility Guidelines.

• INT: Incorporates all three of the above standards.

It’s worth noting here that Section 508 incorporates most of WCAG 2.0 by reference, so on the surface, there’s not much difference between the Revised Section 508 Standards and WCAG 2.0.

However, Section 508 standards are written in a less “technologically neutral" format: They’re more detailed, specific, and directly applicable to the types of ICT that federal agencies procure.

All four VPAT templates are free to use and available to download(opens in a new tab) on the ITI website, and have instructions covering essential requirements and best practices for consistent and comprehensive reporting. The ITI also provides additional training and resources(opens in a new tab) to help fill out a VPAT document.

A text document with the words Voluntary Product Accessibility Template

How to Fill Out a VPAT

The VPAT document contains two sections: instructions on how to use the document and the conformance template itself. Organizations should present a thorough and honest analysis of their product.

Here's how to complete a VPAT:

1. Choose your VPAT edition. Pick the edition that matches the market you sell into: Revised Section 508, EN 301 549, WCAG, or INT if you need all three. All four are free to download from the ITI website.

2. Define the scope. Name the exact product, version, and components being evaluated. A VPAT that covers "our platform" without version detail is not usable by a procurement team, and it will be sent back.

3. Test the product. Run both automated and expert testing against the applicable standard. Automated tools catch a portion of issues at scale. Expert testing with assistive technology is what verifies whether a feature actually works for the people using it.

4. Assign a conformance level to each criterion. Work through every applicable provision and select one of four ratings. Overstating conformance is the fastest way to lose a contract, because the buyer will eventually test the product themselves.

There are also four conformance levels of a VPAT to be aware of:

• Supports: The product meets the criterion without known defects.

• Partially Supports: Some functionality meets the criterion, but not all of it.

• Does Not Support: The product does not meet the criterion.

• Not Applicable: The criterion does not apply to the product.

There is no "pass" or "fail." Every rating below "Supports" requires an explanation in the remarks column.

5. Write meaningful remarks. For anything "Supports," explain what does not work, which users it affects, and what you are doing about it. Vague remarks are the most common weakness in published reports.

6. Publish it as an Accessibility Conformance Report. Include the evaluation date, product version, evaluation methods, and assessor contact information. The published ACR should contain only the completed template. Here's Shopify's completed ACR report as an example(opens in a new tab).

Best practices

• Make sure you, or a person filling out a VPAT on your behalf, are familiar with the accessibility standards of the template edition being completed. If you are not sure, use a third-party company that can help.

• Make sure the completed VPAT is itself accessible.

• if you update your product, remember to update your VPAT and include the date of revision and version of the product being evaluated.

For agencies and organizations that do business with the federal government and are requried to fill out VPATs, having a long-term strategy for comprehensive and ongoing accessibility monitoring and fixes is the key to success.

Elements of a VPAT Report

A standard VPAT includes a table with three columns:

1. Criteria: The first column identifies the Section 508 or WCAG standard being tested. It may include the full text of the requirement, or simply the name and number of the criterion. 

2. Conformance Level: Four conformance levels are possible: Supports (the product meets the criterion without defects), Partially Supports (some functionality meets the criterion), Does Not Support, or Not Applicable (the criterion isn’t relevant to the product). 

3. Remarks and Explanations: This section identifies features that aren’t conformant. It may also include explanations for why conformance isn’t possible, or information about steps that the vendor is taking to improve conformance.

As we discussed earlier, the VPAT should also include information about evaluation methods, along with the vendor’s contact information.

Get Expert Help with VPAT and VPAT Report

Creating a VPAT can be daunting — especially if you’re still refining your product’s features, or if certain features aren’t yet accessible.

AudioEye can help. Our experts can help you understand reporting requirements, create an accurate VPAT, and implement accessibility improvements for your website, app, or digital product. 

1. Our experts will audit your digital asset to understand how the product conforms to relevant accessibility compliance requirements. We use a combination of manual and automated tests to compare content against Section 508, WCAG, EN 301 549, or all three standards.

2. We’ll fill out your VPAT for you, noting all accessibility features and current limitations. AudioEye can also provide expert remediation guidance to help you earn, maintain, and prove digital compliance. 

3. Finally, we’ll help you update your VPAT as needed to respond to different requests from federal agencies or to accurately reflect changes to your website or product.

Our VPAT services provide your organization with accurate, relevant reporting — backed by the most widely recognized name in digital accessibility.

To get started, schedule a demo or learn more about our VPAT solutions.