Most issues with a completed VPAT trace back to the same handful of errors: filling it out without an audit, choosing the wrong edition, marking criteria as Supports when they aren’t, leaving the Remarks column thin, and confusing the template with the finished report. A VPAT is the blank document. The Accessibility Conformance Report (ACR) is what the buyer actually wants. The quality of that ACR depends on accurate evaluation, careful conformance language, and detail that procurement teams can verify.
| Mistake | Why it matters |
|---|---|
| Skipping the audit | The ACR has no factual basis without evaluation against WCAG criteria. |
| Wrong VPAT edition | Section 508, EN 301 549, and INT each carry different obligations. The wrong edition can disqualify a vendor. |
| Overstating conformance | Marking Supports when issues exist creates legal and procurement risk. |
| Empty or vague Remarks | Buyers cannot verify claims without specific notes per criterion. |
| Self-issued without expertise | Independently issued ACRs carry more weight in procurement. |
Filling Out the VPAT Without an Audit
This is the error that undermines everything else. The VPAT is a reporting template. It is not an evaluation. The conformance claims inside an ACR must come from a manual accessibility audit that identifies issues against the relevant WCAG criteria.
Without that evaluation, every Supports, Partially Supports, and Does Not Support marking is a guess. Procurement teams know this. So do the legal teams reviewing vendor documentation.
Scans cannot substitute. Scans only flag approximately 25% of issues, which means a VPAT built on automated output misses most of what matters.
Choosing the Wrong VPAT Edition
The VPAT comes in four editions: WCAG, Section 508, EN 301 549, and INT. Each has a different scope.
The WCAG edition is the most common choice for SaaS companies selling to private-sector buyers. Section 508 is required when selling to U.S. federal agencies. EN 301 549 covers procurement in the European Union. INT combines all three.
Picking the wrong edition wastes effort and can disqualify a response to an RFP. If the buyer asks for a Section 508 ACR and receives a WCAG-only report, the document does not meet the request.
Marking Supports When Issues Exist
Supports means the criterion is fully met. If the audit identified any issue under that success criterion, the correct marking is Partially Supports or Does Not Support.
Inflating conformance claims creates two problems. First, it misrepresents the product to a buyer who will eventually find the issues during their own review. Second, it creates a written record that can be used against the vendor in a dispute.
Honest reporting is more valuable than perfect reporting. Buyers expect Partially Supports markings. They are skeptical of an ACR that claims full conformance across every criterion.
Leaving the Remarks Column Thin
The Remarks and Explanations column is where the ACR earns its credibility. A criterion marked Partially Supports without explanation tells the buyer nothing. A criterion marked Supports without context invites the same skepticism.
Strong remarks describe what was evaluated, what works, and what issues exist. Specificity here is what separates a useful ACR from a checkbox exercise.
Confusing the VPAT With the ACR
The VPAT is the blank template published by ITI. The ACR is the completed report a vendor delivers to buyers. Vendors sometimes use the terms interchangeably and end up sending an incomplete document or missing required sections.
An ACR includes the product name, version, evaluation methods, contact information, and the full criteria table with conformance levels and remarks. A VPAT without these populated fields is not yet an ACR.
Self-Issuing Without Accessibility Expertise
A vendor can complete its own VPAT. Many do. The problem is that self-issued ACRs without independent evaluation carry less weight in procurement, especially with sophisticated buyers.
An independently issued ACR, backed by a manual audit conducted by an accessibility company, signals that the conformance claims are grounded in qualified evaluation. That credibility shortens procurement cycles.
How is a VPAT Different From an ACR in Practice?
The VPAT is the form. The ACR is the form filled in correctly. A vendor who downloads the VPAT, types the product name in the header, and sends it to a buyer has not delivered an ACR. The criteria table needs conformance markings tied to evidence, the remarks need to explain those markings, and the document needs to identify the evaluator and the methods used.
VPAT details are discussed further here.
What a Strong Completed VPAT Looks Like
A strong ACR reads like a careful product disclosure. Conformance levels match what an audit identified. Remarks are written per criterion, not copied across rows. Partially Supports is used where it belongs. The edition matches what the buyer requested. The evaluator and methods section is populated with real detail.
That document is what wins procurement reviews.
FAQs
Should we get an audit before completing the VPAT?
Yes. The conformance claims in the ACR are only credible when they come from an evaluation against WCAG criteria. Without an audit, the markings are guesses, and procurement teams treat them that way.
Can we mark every criterion as Supports if we believe the product is accessible?
No. Supports is reserved for criteria that are fully met. If any issue exists under a criterion, the correct marking is Partially Supports or Does Not Support. Inflated claims damage credibility once buyers verify.
Which VPAT edition should most SaaS companies use?
The WCAG edition fits most private-sector procurement requests. Section 508 applies when selling to U.S. federal agencies. EN 301 549 applies in the EU. INT covers all three when buyers operate across regions.
Does an ACR expire?
There is no formal expiration. The recommendation is to update the ACR after significant product changes so the document reflects the current state of the product.
Who should write the remarks for each criterion?
The person or team that conducted the audit. They have the evidence to describe what works, what doesn’t, and what the conformance level reflects. Remarks written without that evaluation tend to read as filler.
A completed VPAT is only as strong as the evaluation behind it. The errors above are avoidable when the audit comes first and the report is written with care.
Contact Accessible.org to request a VPAT/ACR quote.
