In the world of digital accessibility, there are many ways to show whether an organization’s “information and communication technologies” (ICT) are accessible. One of the most well-known and widely used formats is the Voluntary Product Accessibility Template (VPAT), also referred to as the Accessibility Conformance Report (ACR) or Government Product Accessibility Template (GPAT).
Organizations need VPATs for a variety of reasons. Some may be familiar due to government acquisitions. Others may be facing litigation because of violations from the Americans with Disabilities Act (ADA). If you are unfamiliar with the VPAT/ACR, this article will answer some of your questions.
Table of Contents
What is a Voluntary Product Accessibility Template (VPAT)?
The VPAT is a document developed by the Information Technology Industry Council (ITIC). It describes how ICT products and services conform to digital accessibility guidelines. Examples of ICT include software, hardware, electronic content, and support documentation.
A completed VPAT report details:
-
Accessibility requirements applicable to a product
-
A product's level of conformance with each guideline
-
How the product meets each guideline (if it does)
Who needs a VPAT?
Generally, if you need to verify your accessibility, you will most likely have to fill out a VPAT. After completion, a VPAT can be used for an accessibility conformance report (ACR).
When companies do business with the government, they may need an ACR or a VPAT that evaluates the accessibility of their information and communication technology products.
Similar to Section 508, Section 504 bars entities receiving federal financial assistance from discriminating against individuals with disabilities. Meaning that ICTs need to be accessible as part of federal procurement efforts. This includes the procurement of state, local, tribal, territorial, and public educational institutions.
In fact, some states have their own laws mandating the accessibility of ICTs. Take California for example. The state’s Unruh Civil Rights Act includes the following guideline.
“All persons within the jurisdiction of this state are free and equal, and no matter what their sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, or immigration status are entitled to the full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind whatsoever.”
When is a VPAT required?
A VPAT is required when a Federal government agency requests one. This request likely comes from a contracting official or government buyer.
In order for your organization to contract with the federal government, you must first comply with Section 508 by completing a VPAT. Below are some of the requirements that need to be met by agencies, as stated in Section 508.
“When developing, procuring, maintaining, or using electronic and information technology, each Federal department or agency, including the United States Postal Service, shall ensure, unless an undue burden would be imposed on the department or agency, that the electronic and information technology allows, regardless of the type of medium of the technology”.
We commonly see the VPAT used to demonstrate accessibility compliance of ICTs in federal procurement efforts. However, you should always request guidance from the contracting officer for the procurement. Depending on the agency, they may have their own reporting requirements and/or standards (e.g., Department of Homeland Security). Some agencies may also require documentation in addition to the VPAT.
Is VPAT a certification?
The VPAT report confirms or certifies a product’s accessibility when completed correctly.
Need help with a VPAT?
No matter the reason – for a judge or government buyer
Other reasons to complete a VPAT
Comply with the American's Disability Act (ADA)
The ADA, as amended, prohibits discrimination based on disability in the areas of employment, public accommodation, public services, transportation and telecommunications.
Title III of the ADA may require your company’s online presence to be accessible, as it would be classified as a “place of public accommodation”. A recent example where Title III of the ADA was viewed as applicable in such a manner was a recent legal case brought to the Supreme Court by Dominos.
Conform to Web Content Accessibility Guidelines (WCAG)
W3C’s “Web Content Accessibility Guidelines” provides universal accessibility guidance that certain organizations are required to follow. For example, those in Ontario, CA are required by AODA compliance to follow WCAG. You can assess your product for WCAG 2.0 compliance with a VPAT.
Follow EN 301 549
Businesses in Europe need to make sure their website complies with EN 301 549. An European law, EN 301 549 is the standard to follow for digital and web accessibility.
Why companies use VPATs
Be accessible to more people
As more organizations recognize the importance of accessibility, they are devoting significant resources to making their products accessible to people with impairments. Leaving disabled individuals behind is a violation of basic human rights. Accessibility is not only the moral thing to do; it’s also a wise business decision.
Some of the largest companies in the world use VPATs. Companies like Microsoft, Apple, and Google all have VPATs for their products. They understand that by having proper documentation, it is easier to procure their products and know precisely how accessible said products are.
Avoid litigation
Conducting an accessibility audit on your ICT product and generating a VPAT can help reduce the risk of litigation under existing federal and state laws. An accessibility audit identifies potential barriers to people with disabilities using your product. A VPAT provides detailed information about those barriers and how to remove them.
Maintain compliance
Failure to comply with established accessibility standards increases your company’s exposure and risk of a lawsuit under the American with Disabilities Act. The consequences of such a lawsuit may result in expenses exceeding tens or hundreds of thousands of dollars, to potentially include an award of attorney’s fees to the plaintiff. In addition to penalties under the ADA, some states (e.g., California) allow for an award of damages. Not to mention the damages caused to your brand and image.
Ways to get a VPAT report
From an accessibility expert
The best way to create an accurate and helpful VPAT is to have an accessibility expert fill it out. This will avoid common problems, such as lack of experience testing for accessibility compliance, incorrect information, or too much detail.
Too often these documents get filled out by a companies marketing team to try and make their accessibility seem better than it actually is.
Do it yourself
You can try filling one out yourself. Here’s a training course that helps you write an accessibility conformance report using the VPAT. It also explains how to evaluate a VPAT report. The training is broken into modules that cover popular accessibility standards.
While VPAT 2.0 is likely the most widely known version, VPAT 2.4 is the most recent version. The most up-to-date VPAT templates can be downloaded from the Information Technology Industry Council’s website.
Our Recommendation: Get a trusted report from TestPros
Make an informed decision for your accessibility needs with TestPros. Using an independent expert ensures your VPAT is accurate, requirements are met, and the language used in the document is reflective of the level of conformance of the application.
TestPros offers full life-cycle services for accessibility compliance, including:
- Baseline accessibility assessments / gap analyses
- Accessibility regression testing
- Integration of automated testing solutions in CI/CD pipelines
- Remediation of non-compliant software
- Programmatic support/development
- Training
Government and commercial customers have trusted us for over 30 years. Get support by contacting our team today.
