This post adapted from the article, “VPAT 2.X, The Evolution of the Accessibility Conformance Report,” originally published in the November 2019 issue of Mealey’s™ Litigation Report: Cyber Tech & E-Commerce. Mealey’s is a subscription-based information provider and a division of LexisNexis. In subsequent weeks we will cover variations across the four VPAT versions explored in the full article. This post provides an outline of the process and element updates included in the VPAT 2.3: EU and INT versions. For an overview of the overall goals of the VPAT updates, refer to Part One of the series.
VPAT 2.3 EU: EN 301 549
The VPAT 2.3 EU: EN 301 549 edition largely mirrors the VPAT Section 508 edition in structure with a few exceptions.
Applicable Standards/Guidelines
The EN 301 549 edition allows for both Web Content Accessibility Guidelines 2.0 Level A/AA/AA, Web Content Accessibility Guidelines 2.1 Level A/AA/AA, and EN 301 549 Accessibility requirements suitable for public procurement of ICT products and services in Europe, – V2.1.2 (2018-08). (Table 7)
Table 7. Standard/Guideline Table from EU:EN 301 549 Edition
This report covers the degree of conformance for the following accessibility standard/guidelines:
Standard/Guideline |
Included In Report |
Web Content Accessibility Guidelines 2.0 | Level A (Yes / No )
Level AA (Yes / No ) Level AAA (Yes / No ) |
Web Content Accessibility Guidelines 2.1 | Level A (Yes / No )
Level AA (Yes / No ) Level AAA (Yes / No ) |
EN 301 549 Accessibility requirements suitable for public procurement of ICT products and services in Europe, – V2.1.2 (2018-08)17 | (Yes / No ) |
Success Criteria
As with the Section 508 Edition, the EN 301 549 Edition maps the specific EN 301 549 criteria to the Web Content Accessibility Guideline. The citations are more detailed in the European standards and will, therefore, vary in the success criteria.
Example of Standards Variation
Criteria
1.1.1 Non-text Content (Level A)
Also applies to:
EN 301 549 Criteria
- 1.1.1 (Web)
- 1.1.1 (Non-web document)
- 1.1.1.1 (Open Functionality Software)
- 1.1.1.2 (Closed Functionality Software)
- 8.2 (Authoring Tool)
- 1.2 (Product Docs)
- 2.4 (Support Docs)
1.2.1 Audio-only and Video-only (Prerecorded) (Level A)
Also applies to:
EN 301 549 Criteria
- 1.2.1 (Web)
- 1.2.1 (Non-web document)
- 1.2.1.1 (Open Functionality Software)
- 1.2.1.2.1 and 11.1.2.1.2.2 (Closed Software)
- 8.2 (Authoring Tool)
- 1.2 (Product Docs)
- 2.4 (Support Docs)
Additional Requirements:
As with the Section 508 Edition, the EN 301 549 Edition incorporates chapters that have reporting requirements that cannot be satisfied in the WCAG Success Criteria sections. These include:
- Chapter 4: Functional Performance Statements (FPS)
- Chapter 5: Generic Requirements
- Chapter 6: ICT with Two-Way Voice Communication
- Chapter 7: ICT with Video Capabilities
- Chapter 8: Hardware
- Chapter 10: Non-web Documents
- Chapter 11: Software
- Chapter 12: Documentation and Support Services
- Chapter 13: ICT Providing Relay or Emergency Service Access
VPAT 2.3 INT: Incorporate all three of the above standards
As the name implies, the VPAT 2.3 INT, international edition incorporates all of the standards into one document. It does not attempt to combine redundant reporting requirements, but rather combines the attestations into one convenient document.
Conclusion
In closing, the ongoing evolution of VPAT® 2.x updates, help maintain its relevance and position as a powerful tool for vendors and purchasers to have more meaningful and direct conversations during the procurement process, while also stressing accountability for product owners. Increasingly, the best practices outlined in the various VPAT and ACR updates, create potential benefits for procurements across both public and private organizations. However, the end-result of increased promotion and development of products that reduce or eliminate barriers to employment and self-sufficiency for people with vision, hearing, mobility, and cognitive challenges may present the greatest opportunity as these processes continue to evolve.
Note: Download the full article for tables and examples of variations across each VPAT version (Accessible PDF format).
Coming soon: In the series final installment, Hiram outlines the elements of the VPAT 2.3 EU and VPAT 2.3 INT versions.
About the author
Hiram Kuykendall, Chief Technology Officer is the chief technology officer for Microassist, an Austin, Texas-based learning, development, and accessibility consulting firm. He has more than 22 years of experience in custom application development and over 12 years of accessibility remediation for custom application development, eLearning, and instructor-led training. In addition, Hiram advocates through public speaking and volunteer work specifically focused on the technical aspects of web accessibility. Hiram can be reached at [email protected].
Learn more about Accessibility Solutions
VPAT Evaluation and Authoring Services: The Voluntary Product Accessibility Template®, or VPAT®, is a tool provided by the accessibility policy and standard organization, ITI. The VPAT is used to document how well a product conforms with Section 508 accessibility standards. Many federal, state, and local government and institutions of higher education use or are required to use a VPAT to assess commercial IT products and services with features that support accessibility.
Recommended articles
VPAT 2.X, The Evolution of the Accessibility Conformance Report | Part One: An Overview
Revisit part one of this series on recent updates to the VPAT® process, including an overview of the consistent elements across the multiple versions used globally.
“Website Accessibility: The Legal Landscape” from The Banking Law Journal
An in-depth look at key legal cases and website accessibility litigation decisions, the reasoning behind each decision among the different courts, an introduction to website accessibility standards, and a checklist for litigation-wary organizations who want to minimize their risk. (Co-authored by Hiram Kuykendall, with Paul Trahan and Nathan Damweber, attorneys at Norton Rose Fulbright US LLP)
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