If you don’t have a VPAT/ACR in 2025, you’re not going to win contracts. We have our fingers right on the pulse of the private marketplace and clients continually tell us they must have a VPAT to have their product or service considered for purchase.
Note: A VPAT is the standardized template we fill in. Once it’s filled in, an ACR or Accessibility Conformance Report is created.
But is a VPAT actually required by law? No, not unless you’re selling to the U.S. federal government and, even then, it’s not so much your requirement as it is theirs. Here’s the language straight from the horse’s mouth (Section508.gov):
I have not completed a VPAT®/ACR before. Why am I being required to complete it now? Isn’t the VPAT® voluntary?
The U.S. federal government must buy Information and Communication Technology (ICT) that is accessible per Section 508 of the Rehabilitation Act. The government asks industry to submit an Accessibility Conformance Report so that the accessibility of a product may be evaluated. Without the ACR, the government may not proceed with the purchase unless there is a special use case exception that the government… may claim in which the ACR will not be required.
…While the use of the VPAT® itself is not required, it is not voluntary to complete an ACR if you wish the government to consider purchasing your product.
Otherwise, is a VPAT a legal requirement?
No, not unless there’s a directive or regulation you’re subject to that requires it.
But, ACRs are absolutely required in many other circumstances and you can also see them implicitly required when certain documentation provisions are set out.
For example, many universities will have procurement requirements specifically set as a result of their accessibility policy that require vendors produce a VPAT in order to be eligible to submit their product or service for consideration.
And, yes, you can fill in your own VPAT, but that’s not working out well in 2025. The market is much more educated on accessibility and many entities are not accepting self-issued ACRs.
That’s it. If you need help with VPAT services, we’d love to help.
Just send us a message and we’ll be right with you.