Title II Alert

Public sector organizations under ADA Title II jurisdiction must purchase WCAG 2.1 Level AA products starting April 24, 2026. Vendors supplying products and services to states, cities, public institutions of higher education, and other covered entities should take time to assess risk and develop a strategy. Our ADA policy teams are available to discuss your organization’s concerns regarding the new Title II changes. We have created a curated resource page for Digital Accessibility Under ADA Title II that is periodically updated with new information.

What is a VPAT? What is an ACR?

What does VPAT® stand for? VPAT stands for Voluntary Product Accessibility Template.

A VPAT is a document template used to create a report on how accessible an information and communication technology (ICT) product is. ICT products include software, mobile applications, websites, documentation, or hardware. The generated report helps the procurement community assess the level of accessibility conformance during the market research and proposal evaluation stages.

Once the VPAT is complete, it becomes an Accessibility Conformance Report (called an ACR). The Accessibility Conformance Report is used by federal and state agency contracting officials, buyers at educational institutions, and private sector buyers to assess ICT for accessibility. It is intended to help buyers make a preliminary assessment of a technology product’s conformance based on the reported accessibility standards and guidelines.

In summary:

ACR = compliance report documenting accessibility features and deficiencies of a product
VPAT = blank template for generating an ACR

Why is having a VPAT and ACR important?

Creating a Voluntary Product Accessibility Template (VPAT) is essential for vendors aiming to market their Information and Communications Technology (ICT) products to federal government agencies, state governments, or educational institutions. Section 508 of the Rehabilitation Act requires U.S. Federal government agencies to ensure that any ICT they develop, procure, maintain, or use meets specific accessibility standards. Many state governments and educational institutions have also adopted these standards.

The VPAT and the accompanying Accessibility Conformance Report (ACR) are important beyond federal mandates. With recent updates to Title II of the Americans with Disabilities Act (ADA), VPATs have become crucial for vendors engaging with state and local governments and educational institutions. These documents are key to demonstrating compliance with the Department of Justice’s expanded accessibility requirements, ensuring that digital products are accessible to all users and meet legal standards across various levels of government.

The Information Technology Industry Council (ITI) is the industry group that maintains the VPAT. As indicated by its title, a VPAT is a voluntary attestation made available by vendors to purchasers. While a company has no legal mandate to create an ACR, purchasers must ask for one under federal and many state laws. A vendor not wishing to complete an ACR will be required to provide an ACR attestation or choose not to respond to the solicitation.

Accessibility Conformance Reports focus on the standards relevant to specific laws and organization requirements. These standards include:

Section 508 Amendment of the Rehabilitation Act of 1973
Web Content Accessibility Guidelines (WCAG) versions 2.0/2.1 – The most commonly recognized accessibility guidelines in the United States.
EN 201 549 – the European Union’s “Accessibility requirements suitable for public procurement of ICT products and services in Europe.”

Which VPAT edition should I use?

Last updated in Fall 2023, the four available template editions include:

VPAT 2.5 508: Based on revised Section 508 standards and includes WCAG 2.0 plus individual Section 508 chapters
VPAT 2.5 WCAG 2.2: for reporting conformance based on the recently released Web Content Accessibility Guidelines 2.2 or 2.1 and 2.0.
VPAT 2.5 EU: for reporting based on EN 301 549 requirements (versions 3.3.1 and 3.2.1) and including WCAG 2.0 or 2.1 or ISO/IEC 40500
VPAT INT 2.5: Incorporate all three of the above standards

Your customers’ requirements will drive the decision on which VPAT edition to use. When preparing a VPAT for your product, here are some points to consider:

Is your primary market the U.S. Federal Government? The VPAT template initially began out of Federal agencies need to evaluate how digital content conforms to Section 508 requirements, so federal contracts often require the 508 edition for creating an ACR. It is interesting to note that the 508 edition is directly tied to the Section 508 Amendment of the Rehabilitation Act of 1973. This piece of legislation currently mandates the use of WCAG 2.0 Level AA and identified chapters.

Does your product include hardware or non-web software? If so, then the Section 508 template is for you. Only the 508 edition has specific chapters for hardware, software, and support documentation and services.

How important is mobile to your customers? Market sectors such as Higher Education are particularly interested in mobile web, and mobile app accessibility, since students rely heavily on mobile devices. These customers will likely ask for the VPAT WCAG edition and request conformance reporting to the WCAG 2.1 Level AA guidelines.

Do you sell internationally? Companies that sell internationally may prefer to use the INT edition because it includes all three main international standards in a single template.

As you can see, selecting a VPAT edition can be a challenge. Accordingly, many vendors are electing to fill out multiple versions such as the 508 edition, WCAG edition, or just relevant sections of the International edition. Whichever editions you use, be aware that each edition comes with its own unique instructions.

What does a VPAT look like?

The VPAT document is provided as a Microsoft Word file that can be used as-is or reproduced in other formats. The VPAT® includes two major sections. The first section includes extensive instructions for completing the VPAT, including essential requirements, best practices, posting instructions, etc.

The second section, the VPAT Template, which you will complete and make available to buyers, as the Accessibility Conformance Report (ACR). The ACR is what is made available as documentation of a product’s conformance to accessibility requirements.

The second section of the VPAT Template provides more detailed views of criteria for various platforms. Within the template:

Column one describes the accessibility criteria.
Column two describes the conformance level.
The last column contains any additional remarks and explanations regarding the testing methodology and/or conformance.

Data within the second column includes the status of the ICT with regard to each of the accessibility criteria. The conformance levels are as follows:

Supports: The functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.
Partially Supports: Some functionality of the product does not meet the criterion.
Does Not Support: The majority of product functionality does not meet the criterion.
Not Applicable: The criterion is not relevant to the product.
Not Evaluated: The product has not been evaluated against the criterion. This can only be used within Level AAA criteria.

The answers need to be clear with respect to what individual criterion the answer applies to. It is possible to either use a summary, selecting the worst case for the criteria, or to have separate answers or even tables for software, support documentation, authoring tools, etc., so long as the methodology used is made clear.

It might seem obvious, but when you create an ACR, make sure you make it accessible if you transform it into another format, such as Adobe PDF.

How do customers use the ACR?

One of the most common misconceptions is how a customer evaluates accessibility during the procurement process. An ACR and other accessibility attestations are used to facilitate conversations within the organization. These conversations center around risk and usage.

In general, the Request for Purchase (RFP) process will follow a general pattern:

Your ACR is reviewed by an in-house team member or outside consultant with expertise in technology and accessibility.
If the ACR reports defects or the team discovers defects during the evaluation, the results are shared with the requestor.
If there are defects, the requestor has the option of utilizing an exception process. The exception process generally includes a Corrective Action Plan or similar vehicle that outlines how the requestor or organization will handle defects. There may be no perfectly accessible product to meet a given business need, however with proper research and/or modifications to configurations and settings, users with disabilities may still be able to utilize it effectively.
These exception processes usually have several options. For example, the requestor can take ownership of the necessary remediation tasks. The exception process can be the basis for engaging the vendor who will commit to remediate the product or ask for an exception or exemption from the accessibility policy.
It is important to note that an ACR with defects is not an automatic disqualifier. Having an accurate ACR allows the organization to make an informed decision.

What are some of the limitations of the VPAT?

A VPAT can only attest to products. A VPAT is not appropriate for services such as creating a website or soft deliverables such as a study.

A VPAT is only as credible as the person who completed it. Historically VPATs were completed by salespeople or other non-technical staff. This led to highly inaccurate VPATs. The task was then moved to the development groups who were creating the product. This led to an issue where the teams who created the defects could not subsequently identify them. In short, a VPAT must be completed by someone who understands the WCAG and Section 508 requirements.

Why is an accurate VPAT important?

In the United States, a product without a VPAT is excluded from solicitations by the federal government, many state and local government entities, and a majority of institutions of higher education. Increasingly diversity, equity and inclusion efforts have private organizations prioritizing accessibility to promote hiring and inclusion of people with disabilities. Thus, more and more companies require their suppliers certify accessibility as part of the purchasing and product development life cycle.

Procuring accessible products for both product development and internal use is the best way for your customers to avoid litigation and promote an inclusive environment.

And finally, an incomplete or inaccurate ACR can put you at contractual risk. Your customers rely on you to self-evaluate and report levels of accessibility compliance on your ACR. Because ACRs are provided as part of an official procurement contract, they represent your formal claim regarding your products and services’ accessibility. Organizations increasingly hold vendors responsible for accessibility claims made in their ACR.

How do I complete the VPAT?

Completing a Voluntary Product Accessibility Template (VPAT) generally starts with a Section 508 audit by experts familiar with accessibility concepts, guidelines, and testing methodologies. While it’s possible to train internal teams to undertake this task, many organizations lack the necessary domain knowledge to create an accurate VPAT internally.

Initially, many organizations researched Section 508 to handle all VPAT creation activities in-house. However, after fully understanding the challenges involved in Section 508 testing, they often hire knowledgeable consultants to create their VPATs. To ensure the integrity and credibility of VPAT assessments, it is advisable to involve a third-party auditor, especially when internal capabilities might present conflicts of interest. This approach enhances the impartiality and reliability of the Accessibility Conformance Report (ACR), making the VPAT more trustworthy for all stakeholders involved.

Once the product’s accessibility is evaluated, a person who understands the specific rules and guidelines of the VPAT template completes it. If you do not have trained accessibility experts in-house, hiring a consultant to guide you through the VPAT process is advisable.

When preparing a VPAT, it is now crucial to ensure that your technology meets the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. This update aligns with the Department of Justice’s recent mandate for digital accessibility, specifically for state and local governments and public educational institutions.

Your VPAT should thoroughly document how your product adheres to accessibility standards, providing clear evidence of compliance. Detailed attention to each Web Content Accessibility Guidelines (WCAG) 2.1 Level AA criterion is essential to meet legal requirements and enhance the user experience for individuals with disabilities.

When preparing the Accessibility Conformance Report (ACR), providing detailed explanations for each WCAG criterion is crucial. This reporting should clarify the extent of your product’s support for each standard, offering stakeholders a clear and accurate view of its accessibility capabilities. Such transparency is vital for compliance and helps users who rely on these accessibility features to understand exactly what the product offers and any potential limitations. Ensure your documentation is thorough and reflects all necessary adjustments to meet the latest accessibility standards.

Who Should Complete a VPAT?

The responsibility for completing a Voluntary Product Accessibility Template (VPAT) typically falls to the Original Equipment Manufacturer (OEM), as they are best positioned to conduct the necessary testing. However, the solution vendor or resellers may also complete the VPAT. It is advisable to consult with the OEM or vendor to determine who should provide this crucial accessibility information, ensuring that the most knowledgeable and appropriate party is responsible for its accuracy.

How do I get a VPAT from Microassist?

To create a VPAT, Microassist audits your application to determine compliance with accessibility standards and acquire the data needed to create a VPAT. Your needs will determine the scope and timeline of the audit. This ensures a proper compliance baseline is established with all applicable portions of the Section 508 standards.

For web-based products, this audit can take as little as one week and as long as several months. Audits require auditors with expertise in manual and automated accessibility testing. The auditing task becomes even more complicated when a product includes custom hardware or desktop software.

Each audit report identifies and prioritizes all accessibility errors within the product or application, defines the method for addressing the issues, and documents its overall compliance with Section 508 and WCAG. Our audit team shares the initial audit report with you. Your team can use the results of the audit to improve the compliance of your product.

Once you are satisfied with the accessibility state of your product, our team conducts a final re-audit. We use that final re-audit results to fill out the VPAT and create an accessibility compliance report for your product. Your organization can use the ACR for RFP’s and reporting purposes in the event of legal inquiries or complaints against your customers in the future.

A caution, a vendor starting the VPAT process after an RFP has been issued will likely not have enough time to complete the template before the solicitation due date.

For more information on having Microassist create a VPAT for your product, contact our accessibility evaluation services team today and see how we can help.

How often do you update an ACR?

There is no set timeline, but you need to update the ACR every 12 to 16 months or when significant features are released or if the user interface has changed substantially. Your obligation is to provide an accessibility compliance report that your VPAT accurately reflects your product’s current level of compliance.

How will ADA Title II Changes Affect an ACR?

Starting April 24, 2026, and extending to April 24, 2027, state governments, local governments, public education systems, and other covered entities covered under Title II of the Americans with Disabilities Act (ADA) will require vendors to provide products and services that comply with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA and Effective Communication.
Here are a few helpful tips for vendors seeking to comply with Title II of the ADA.

VPAT/ACR: Have a current, up-to-date Accessibility Conformance Report (ACR) based on the Voluntary Product Accessibility Template (VAPAT) 2.5 (or higher) INT or WCAG edition.
WCAG 2.1 Requirements: Ensure your ACR attests to the WCAG 2.1(or higher) Level A/AA Sections.
Noncompliant Success Criteria: Have a roadmap to remediate Success Criteria with “Does Not Support” or “Partially Supports” compliance. Any success criteria with less than “Supports” may be required to go through a procurement exception process.
Provide Accurate and Descriptive Remarks and Explanations: Ensure success criteria marked as “Partially Supports” and “Does Not Support” have sufficient information in the Remarks and Explanations area to determine severity. Minor areas of noncompliance may still be permissible under Title II.

Product Development

Ensure product development teams know customer accessibility compliance changes under Title II – WCAG 2.1 Level AA, Effective Communication – by April 24, 2026/2027.
Develop a roadmap for remediation of success criteria marked as “Does Not Support” and/or “Partially Supports.”

Final thoughts

The VPAT was developed to provide a standard reporting format and facilitate conversations between procurement departments regarding your product’s accessibility.

Not having an ACR (completed VPAT) will exclude you from many solicitations in both the public and private sectors. Having an ACR with noted defects does not disqualify you from consideration.

An accurate ACR allows the purchaser to compare your product to the competition and pursue a variety of actions, including deciding to purchase your product, undergoing an exception process, or working with you to remediate the product so that it meets requirements.

An inaccurate or misleading ACR represents a significant contract risk.

And finally, you should realize that the VPAT is one component of a robust internal accessibility program that will involve in-depth conversations with your third-party vendors, testing with assistive technology users, testing by accessibility experts, and regular reviews to make sure the information provided is up to date.

Recommended Resources: VPAT and Digital Accessibility

Last updated 1/24/2024

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VPAT: What Technology Vendors Need to Know