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: WCAG Edition version. For an overview of the overall goals of the VPAT updates, refer to Part One of the series.

VPAT 2.3: WCAG Edition

The VPAT 2.3 WAG Edition template is widely requested by purchasers in state government, private and public universities, and the public sector. In short, purchasers who do not fall under Section 508 of the Rehabilitation Act of 1973 or require compliance with European EN 301 549 accessibility standards, frequently request the WCAG edition. The following are features that make the WCAG edition unique and attractive to these procurement offices.

Applicable Standards/Guidelines

The Applicable Standards/Guidelines allow the vendor to document the accessibility guidelines used to evaluate the product or service. As there is no federal guidance outside of Section 508, purchasers are free to specify compliance with either the Web Content Accessibility Guidelines (WCAG) version 2.0 or versions 2.1.

Purchaser Best Practice: As of the time of this writing, the best practice for purchasers is to request WCAG 2.0 Level AA compliance unless there is a specific need. Keeping to the 2.0 level AA standard keeps in-line with the widely adopted federal Section 508 requirements. Vendors who prioritize accessibility may not move to achieve WCAG 2.1 level AA compliance until federal legislation changes. As such, purchasers who mandate 2.1 compliance may exclude viable products and services and have fewer options to evaluate.

Purchaser Exception: One of the primary differences between WCAG 2.0 and WCAG 2.1are the eight mobile-specific success criteria. If the solicitation is for a mobile app or mobile web product, then the purchaser may be justified in requesting the more stringent 2.1 standards knowing that fewer vendors may respond.

Vendor Best Practice: It is widely held that vendors should make plans to adopt WCAG 2.1 as their internal development accessibility guideline. The WCAG 2.1 guideline reached a W3C Recommendation status on June 05, 2018. As such, it is recommended that vendors whose products are currently WCAG 2.1 level AA compliant mark both the Web Content Accessibility Guidelines 2.0 Level A and Level AA as ‘Yes’ in addition to marking both the Web Content Accessibility Guidelines 2.1 Level A and Level AA as ‘Yes’. For vendors who have not substantially met the WCAG 2.1 guidelines should only complete the 2.0 section. Table 1 shows an example of the Applicable Guidelines and Standards table in the report.

Table 1. Example of Applicable Standards/Guideline table from WCAG Edition

Completed Applicable Standards/Guidelines for WCAG 2.0 and WCAG 2.1 Level AA compliance.

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) Level AA (Yes) Level AAA (No )
Web Content Accessibility Guidelines 2.1	Level A (Yes) Level AA (Yes) Level AAA (No )

Procurement Trap: At this time, Level A and Level AA recognized by the accessibility industry as being achievable both in terms of technology and cost. Level AAA has therefore been designated as a level that documents aspirational success criteria. These AAA success criteria provide guidance where future standards may go as the technology evolves and costs decrease. Unless the vendor product has a special need for AAA success criteria, the vendor should mark Level AAA as ‘No.’ Marking Level AAA as ‘Yes’ is a credibility flag for purchasers as it indicates the vendor may not understand the Web Content Accessibility Guidelines and will greatly diminish the perceived accuracy of the attestation. This is true for all four VPAT templates.

Web Content Accessibility Guideline Success Criteria

The bulk of the attestation is completing the Web Content Accessibility Guideline, Success Criteria sections. This is achieved by completing three sections:

Table 1: Success Criteria, Level A
Table 2: Success Criteria, Level AA
Table 3: Success Criteria, Level AAA

The WCAG Edition has a simple layout that asks the evaluator to report on each WCAG success criteria. Each success criteria table has three columns: Criteria, Conformance Level and Remarks and Explanations.

Criteria:

As the name implies, the criteria section contains the WCAG Success Criteria. Vendors should not adjust or change this column.

Conformance Level:

ITI recommends that the evaluator use the standard definitions for reporting compliance levels:

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 in WCAG 2.x Level AAA.

Remarks and Explanations

All three editions contain a Remarks and Explanations column. At a minimum, the evaluator is required to document the defects to the degree that a purchaser can understand the scope and severity of the non-compliance. Failure to adequately describe a defect will result in the purchaser reaching out to the vendor for more information, which will slow the procurement process.

As a best practice, the evaluator should always right something in the Remarks and Explanations even when the criteria achieves a Supports status. This demonstrates the evaluator’s understanding of the requirement and commitment to completing an accurate attestation.

Also as a best practice, the evaluator should work with the product development team to document an alternate method of access (accommodation) for any defect marked as partially support or does not support. By providing a reasonable accommodation, a purchaser can make an informed decision based on the document which will keep the procurement time to a minimum. See Table 2 for an example of a completed success criteria description.

Table 2. Example Success Criteria, Level AA, WCAG Edition

Criteria	Conformance Level	Remarks and Explanations

1.1.1 Non-text Content (Level A)

Supports

{Example Supports Statement}

All no-text content to include graphics has alternate text.

1.2.2 Captions (Prerecorded) (Level A)

Does Not Support

{Example Does Not Support Statement}

Training videos do not have captions.

{Example Accommodation – Vendor Supplied}
Transcripts of videos can be provided upon request.

{Example Accommodation – Customer Supplied}

Customers may include the video in a third party player which will facilitate captions.

1.2.3 Audio Description or Media Alternative (Prerecorded) (Level A)

<End of table>

Note: Download the full article for tables and examples of variations across each VPAT version (Accessible PDF format).
Up next: In Part Three, Hiram outlines the elements of the VPAT 2.3 Section 508 Edition.

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.