VPAT Guide: How to Create an Accessibility Conformance Report

What Is a VPAT and Why It Matters for Federal Procurement

A Voluntary Product Accessibility Template (VPAT) is a structured document technology vendors use to report how their product conforms to accessibility standards. The completed document is called an Accessibility Conformance Report (ACR). Federal agencies must conduct market research on ICT accessibility before procurement, and the VPAT/ACR is the primary vehicle vendors use to supply that information.

VPAT 2.4 vs Older Versions

• VPAT 1.x mapped to original 2001 Section 508 standards — now obsolete for federal procurement
• VPAT 2.x maps to the 2017 Section 508 Refresh incorporating WCAG 2.0 AA
• Four current editions: 508, WCAG, EU (EN 301 549), and INT (combined)
• INT edition preferred for vendors selling to both US and EU governments
• VPATs should be re-evaluated whenever the product changes materially

How to Read a VPAT: Conformance Levels

Each row corresponds to a specific accessibility criterion with five conformance levels: Supports, Partially Supports, Does Not Support, Not Applicable, or Not Evaluated. Procurement officers focus on Partially Supports and Does Not Support entries to determine whether workarounds exist and whether noncompliance affects the intended use case. The Remarks and Explanations column is the most valuable — and most frequently misused — part of any VPAT.

How to Create an Accurate VPAT

• Download the current VPAT template from itic.org
• Select the correct edition (508, WCAG, EU, or INT)
• Define and document the exact product scope and exclusions
• Run automated scanning with axe-core, WAVE, or IBM Equal Access Checker
• Perform manual keyboard-only navigation testing for all user flows
• Test with JAWS and NVDA on Windows, VoiceOver on macOS and iOS
• Include evaluator name, evaluation method, and date of testing

Common VPAT Mistakes That Undermine Credibility

• Marking Supports without conducting actual testing
• Empty Remarks fields for Partially Supports entries
• Using outdated VPAT 1.x templates for federal solicitations
• Failing to define the evaluated product scope
• Not updating the VPAT after significant product changes
• Covering only happy-path flows and ignoring error states