What Is a VPAT? Tips for Filling Out a VPAT

Originally Posted on May 3, 2023

All U.S. federal agencies — as well as any organization that works with them — are required to comply with Section 508 of the Rehabilitation Act, which mandates that all information and communications technology (ICT) is accessible to people with disabilities.

To know if they are compliant with Section 508, public and private agencies alike must complete a Voluntary Product Accessibility Template (VPAT), a self-assessment tool that analyzes if the products they use — such as software, hardware, electronic content, and documentation — conform to Section 508 standards.

In this post, we provide an overview of VPAT objectives, break down the different types of VPATs, and share tips and resources on how to fill out a VPAT.

What is a Voluntary Product Accessibility Template (VPAT)?

A VPAT provides a comprehensive analysis of conformance with Section 508. While there are standard formats for the VPAT (which we’ll discuss in a moment), those formats may be modified to fit an organization’s needs.

For example, Section 508 compliance requires conformance with the Web Content Accessibility Guidelines (WCAG) version 2.0. Some forward-thinking organizations may prefer to use a newer version of the standards, so they might include all of the success criteria from later versions like WCAG 2.1 (the de facto standards for ADA compliance) or WCAG 2.2 (the current official recommendation).

In general, a VPAT will include the following information:

• The name, version, and description of the product being evaluated. 
• The accessibility standards (such as WCAG 2.0 or WCAG 2.2) used for evaluation. 
• The level of conformance claimed by the product. 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 report will also include the date of the evaluation, contact information for the assessor (usually, this is someone within the vendor’s organization or a qualified third-party auditor), and other pertinent info.

What is an Accessibility Conformance Report (ACR)?

An Accessibility Conformance Report is another type of report that documents how well a product or service meets accessibility standards. It’s based off of a completed VPAT and it’s largely the same, but may include more details that are relevant to 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.”

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 an employee or a member 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. Although 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.

What Are Different Types of VPAT?

The Information Technology Industry Council (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, enabling agencies, manufacturers, and vendors to focus on the standards relevant to their specific markets and contract requirements:

• Revised Section 508 standards: the U.S. Federal accessibility standard.
• EN 301 549: 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 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 to help fill out a VPAT document.

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. 

The basic structure of a VPAT prompts respondents to assess their conformance to specific provisions relevant to a product or service and select their degree of conformance, using one of four conformance levels: supports; partially supports; does not support; or not applicable.

Here are some best practices that should be followed when completing the assessment:

• 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 who can help.
• The accessibility criteria in a VPAT are not pass/fail assessment, so  you must provide detailed information about what your product can and cannot do.
• 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. 

Once completed, the VPAT document can be published as an Accessibility Conformance Report (ACR), which should only include the completed template. Here’s Shopify’s completed ACR report as an example 

For agencies and organizations that do business with the federal government and are required to fill out VPATs, having a long-term strategy for comprehensive and ongoing accessibility monitoring and remediation is the key to success. will better position them to receive much-needed federal assistance.  

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.