For most companies producing a VPAT, WCAG 2.1 Level AA is the version to reference. It is the most widely recognized standard among procurement teams, aligns with current U.S. and international regulations, and matches what buyers expect to see in an Accessibility Conformance Report. WCAG 2.2 AA is gaining ground and is the right choice when a buyer requests it or when your product was evaluated against the newer version. WCAG 2.0 AA is outdated for most use cases. The version selected must match the audit standard, since the ACR documents conformance to a specific set of criteria.
| WCAG Version | When to Use It |
|---|---|
| WCAG 2.1 AA | Default for most SaaS and digital products. Recognized across U.S. federal procurement, ADA Title II, and most enterprise buyers. |
| WCAG 2.2 AA | Use when a buyer requests it, when EAA conformance is in scope, or when the audit was conducted against 2.2 criteria. |
| WCAG 2.0 AA | Rarely appropriate today. Only relevant for legacy contracts that explicitly require it. |
Why WCAG 2.1 AA Is the Default
WCAG 2.1 AA has become the working standard for digital accessibility across most industries. It is referenced in ADA Title II regulations for state and local government web content, and it is the version most enterprise procurement teams ask about by name.
When a SaaS company produces a VPAT for the first time, WCAG 2.1 AA is almost always the right starting point. It captures the technical criteria buyers expect, and it pairs cleanly with the WCAG edition of the VPAT template, which is the most common edition used for commercial products.
The ACR itself documents conformance to a specific version. Selecting 2.1 AA means the audit evaluated the product against those success criteria, and the report reflects that evaluation.
When Does WCAG 2.2 AA Make Sense?
WCAG 2.2 AA is the newer version and is appropriate in three situations. The first is when a buyer specifically requests it during procurement. The second is when the European Accessibility Act is in scope, since the EAA references the harmonized European standard EN 301 549, which has been updated to align with 2.2.
The third situation is when the company wants to demonstrate currency. A VPAT referencing 2.2 AA signals that the product was evaluated against the most recent stable version of WCAG, which can be a competitive factor in enterprise sales.
The decision is not about which version is better. Both are valid. The decision is about which version matches buyer expectations and audit scope.
What About WCAG 2.0 AA and Section 508?
WCAG 2.0 AA is the original version of the standard and is rarely the right choice for a new VPAT. Some legacy contracts still reference it, and some federal procurement language has lagged behind, but for most companies producing a VPAT in 2025 or later, 2.1 AA or 2.2 AA is more appropriate.
Section 508 is a separate edition of the VPAT template, not a WCAG version. The Revised Section 508 standards incorporate WCAG 2.0 AA by reference for federal agencies. If a federal buyer requests a Section 508 VPAT, the underlying technical criteria still trace back to WCAG, but the template structure is different. Most commercial buyers want the WCAG edition, not the Section 508 edition.
How Does the Audit Connect to the VPAT Version?
The ACR is only as accurate as the audit behind it. A manual accessibility audit identifies issues against a specific version of WCAG. If the audit evaluated the product against 2.1 AA, the ACR documents conformance to 2.1 AA. The two cannot be mismatched.
This is why version selection happens before the audit, not after. The auditor needs to know which criteria to evaluate against. Scans cannot determine conformance, since they only flag approximately 25% of issues, so the version decision drives the manual evaluation work.
Accessible.org audits are conducted by experienced auditors against the version the client selects. The resulting ACR reflects that scope.
What If a Buyer Asks for Multiple Versions?
Occasionally a buyer will ask for both 2.1 AA and 2.2 AA conformance documentation. The cleanest path is a single audit against 2.2 AA, since 2.2 includes all of 2.1 plus additional criteria. The ACR can then reference 2.2 AA, and the buyer has the higher bar covered.
If the buyer specifically wants two separate ACRs, that is also possible, but it is less common and adds cost. Most procurement teams accept a 2.2 AA ACR as evidence of 2.1 AA conformance by extension.
Frequently Asked Questions
Which WCAG version should a SaaS company use for its first VPAT?
WCAG 2.1 AA is the default for most SaaS companies producing a first VPAT. It matches what enterprise buyers expect and aligns with current U.S. regulatory frameworks. If buyers in your market are already asking for 2.2 AA, start there instead.
Does the EAA require WCAG 2.2 AA in a VPAT?
The EAA references EN 301 549, which has been updated to align with WCAG 2.2 criteria. Companies selling into the European market should evaluate against 2.2 AA and reference the EN 301 549 edition of the VPAT, or include EN 301 549 alongside the WCAG edition.
Can a VPAT reference WCAG 2.2 AAA?
Technically yes, but Level AAA is rarely the target for commercial products. AAA includes criteria that are not feasible for all content types. Almost every VPAT in commercial use references Level AA, not AAA.
How long is a VPAT valid for a given WCAG version?
An ACR does not have a formal expiration. It reflects the state of the product at the time of the audit. Companies should update the ACR after significant product changes or when a newer WCAG version becomes the buyer expectation in their market.
Selecting the right WCAG version is a procurement decision as much as a technical one. Match the version to what buyers ask for, confirm the audit scope reflects that version, and the ACR will do its job in the sales cycle.
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