Why Do You Need to Update Your VPAT^®?

Understanding Voluntary Product Accessibility Template and Accessibility Compliance Report: Key Tools for Digital Accessibility Compliance

A completed Voluntary Product Accessibility Template (VPAT) outlines a product’s conformance to digital accessibility standards. The Information Technology Industry Council (ITIC) developed the VPAT standards to ensure compliance with Section 508 standards for IT products. It details the accessibility level of information and communication technology (ICT), such as hardware, software, and electronic content. When completed, a VPAT document becomes an Accessibility Conformance Report (ACR). The VPAT is the initial template, while the ACR represents the finalized document demonstrating compliance. These tools are crucial for ensuring digital accessibility in today’s technology landscape.  To learn more about Voluntary Product Accessibility Templates (VPATs), look at our comprehensive article “VPAT: What Technology Vendors Need to Know.”.

Recent Legal Changes: ADA Title II Updates

Title II of the Americans with Disabilities Act (ADA) has recently been updated with more stringent accessibility requirements for public entities such as state and local government and public educational institutions. These changes, issued on April 24, 2024, ensure that people with disabilities have equal access to public programs, services, and activities. The updates emphasize compliance with Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. Additionally, these updates align with Section 508 of the Rehabilitation Act, which mandates that organizations, especially those dealing with the U.S. federal government, must provide Accessibility Conformance Reports (ACRs) or Voluntary Product Accessibility Templates (VPATs) to demonstrate their level of conformance with digital accessibility standards. Most affected entities must comply by April 24, 2026, for larger entities, and by April 24, 2027, for smaller entities.  We have created a curated guide to Title II if you’d like to learn more.

The Critical Need for Accurate Accessibility Conformance Reports

The recent changes to ADA Title II mean that affected entities must procure products that demonstrably comply with updated accessibility standards. For technology vendors aiming to sell to government agencies and educational institutions, providing an accurate and up-to-date Accessibility Conformance Report (ACR) is now more crucial than ever. The ACR is the primary tool for documenting and demonstrating a product’s compliance with these stringent accessibility standards, making it essential for vendors to participate in these markets. Regular report updates are vital to reflect progress and ensure ongoing compliance with modern WCAG standards.

Contracts with public entities increasingly include clauses mandating compliance with these accessibility standards. Vendors without an accurate ACR may be disqualified from consideration for product purchases. They will likely face significant complications and delays in the procurement process if considered. This can result in lost business opportunities and damage the vendor’s reputation in the market. Therefore, it is important to ensure that the ACR remains current through subsequent releases to address any changes in standards or product updates.

Benefits of Maintaining an Accurate ACR

1. Market Access and Procurement Success: An accurate and up-to-date Accessibility Conformance Report (ACR) is crucial for technology vendors, especially those selling to government agencies and educational institutions. It demonstrates compliance with accessibility standards and streamlines the procurement process. Maintaining an accurate ACR ensures that products are fully accessible to all users. Accurate ACRs open doors to new markets and customer segments where accessibility is a key consideration. Conversely, inaccurate or outdated ACRs can disqualify products from consideration or lead to cumbersome exception processes, potentially causing vendors to lose business to competitors with better documentation.
2. Competitive Positioning: In today’s competitive marketplace, up-to-date ACRs serve as a differentiator, signaling a commitment to accessibility and industry standards. This can be decisive in winning contracts, especially when competing against companies with less robust accessibility documentation. Having a VPAT for web apps is crucial to demonstrate accessibility compliance. Maintaining accurate ACR helps businesses adapt quickly to evolving standards, providing a competitive edge and helping maintain market share in an increasingly accessibility-conscious environment.
3. Customer Relationships and Satisfaction: Transparent documentation of a product’s accessibility features and limitations sets realistic expectations, prevents misunderstandings and disputes, and enhances overall client experiences.
4. Operational Efficiency and Resource Management: Proactively maintaining accurate ACR ensures compliance with evolving regulations and positions businesses to adapt quickly to new requirements. This approach is generally more cost-effective than addressing compliance issues post-procurement, which can be significantly more expensive in direct costs, diverted staff time, and potential damage to the company’s reputation.

In summary, the accuracy of ACRs has far-reaching implications for market access, competitive positioning, customer relationships, operational efficiency, and regulatory compliance. Maintaining current and accurate ACRs is not just a compliance exercise but a strategic imperative in today’s accessibility-focused business landscape.

Best Practices for ACR Management

To ensure your ACR remains effective and accurate:

1. Conduct regular reviews and updates of your ACR: Set a schedule for reviewing your ACR, ideally at least annually or whenever significant changes are made to your product. This ensures your documentation always reflects your product’s current state and compliance level. Accurately complete the Conformance Level column in the VPAT to indicate your product’s level of conformity to specific standards.
2. Update your ACR with every product change: It’s your obligation to keep your ACR current with your product’s actual state. Any time you make feature upgrades, modifications, or even minor changes that could affect accessibility, you must update your ACR accordingly. This includes:
   1. New features or functionalities
   2. Interface changes
   3. Backend modifications that might impact user interaction
   4. Bug fixes or patches that resolve or affect accessibility issues
3. Align your documentation with the latest accessibility standards: Stay informed about changes in accessibility guidelines, such as updates to WCAG. Promptly update your ACR to reflect compliance with these new standards, demonstrating your commitment to ongoing accessibility and aligning with the latest communications technology standards.
4. Provide transparent documentation of your product’s accessibility features and limitations: Be honest and thorough in your ACR. Clearly outline the accessibility features you’ve implemented and any areas where your product may fall short. This transparency builds trust with your clients and helps them make informed decisions.
5. Use your ACR as a tool for continuous improvement: Don’t just view your ACR as a static document for compliance. Use it to identify areas where your product can be improved. Regularly assess any noted limitations and work towards addressing them in future product updates.
6. Ensure cross-departmental collaboration: Involve product development, QA, and legal teams in the ACR update process. This ensures that all aspects of product changes are accurately reflected in the ACR.
7. Maintain version history: Record all ACR updates, including the date and nature of changes. This can be valuable for audits and demonstrating your ongoing commitment to accessibility.
8. Implement a consultative process: Involve stakeholders such as users with disabilities in your ACR update process. Their real-world insights into accessibility challenges and solutions can significantly enhance the accuracy and utility of your document.
9. Emphasize continuous monitoring and improvement: Go beyond just updating when changes occur. Implement a proactive approach to monitoring your product’s accessibility, ensuring you’re always ahead of compliance and market demands.

Future-Proofing Your Business: The Strategic Imperative of Accurate ACRs

Maintaining an accurate ACR is an investment in your company’s future. It prepares you for upcoming regulatory changes, ensures your products meet the highest accessibility standards, and positions you favorably in the market. By providing an accurate ACR, you demonstrate your commitment to accessibility and inclusivity, setting your business apart as a leader in this crucial area.

Web accessibility is essential for future-proofing your business, ensuring compliance with legal requirements such as the ADA, Section 508, and the EAA, and conforming to WCAG standards.

Act now to ensure your ACR is accurate and up to date. You’ll meet current requirements and position your business for long-term success in an increasingly accessibility-conscious market. Remember, an accurate ACR is not just a compliance document; it reflects your product’s true state and your company’s commitment to accessibility for all users.

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