The European Accessibility Act (EAA) doesn’t explicitly mention anything about VPATs or ACRs and yet, we just suggested a client use our VPAT service to complement our audit (that they’re purchasing in furtherance of EAA compliance). Here’s what’s going on in 70 seconds.
First, a VPAT or Voluntary Product Accessibility Template is simply a standardized template that accounts for the accessibility of a product or service. An ACR or Accessibility Conformance Report is the resulting document after the VPAT is filled-in and completed. And we need to audit an asset to accurately and completely fill in the VPAT and issue the ACR.
Here’s how an ACR could be valuable for EAA compliance:
Documentation and Transparency
The EAA requires manufacturers to establish technical documentation that demonstrates conformity with accessibility requirements. A VPAT/ACR could serve as part of this technical documentation by providing a structured way to document how a product meets the specific accessibility requirements outlined in Annex I of the EAA.
Compliance Assessment Support
The EAA establishes a conformity assessment procedure where manufacturers must demonstrate that their products satisfy the accessibility requirements. A VPAT/ACR provides a standardized format to:
- Document which accessibility requirements are met
- Identify any areas where Article 14 exceptions (fundamental alteration or disproportionate burden) might apply
- Support the EU Declaration of Conformity process
Market Transparency
While the EAA requires that accessibility information be made available to users via multiple sensory channels and in understandable formats, a VPAT/ACR could help manufacturers communicate their accessibility features more effectively to:
- Procurement teams evaluating accessibility compliance
- End users with disabilities
- Market surveillance authorities
Procurement Alignment
The EAA specifically states that its accessibility requirements “shall constitute mandatory accessibility requirements” for public procurement under EU Directives 2014/24/EU and 2014/25/EU. Since many procurement processes already use VPATs/ACRs for accessibility evaluation, maintaining this documentation format could streamline both EAA compliance and procurement processes.
Risk Management
Given that the EAA includes penalties for non-compliance and requires manufacturers to maintain conformity documentation for five years, a VPAT/ACR could serve as evidence of due diligence in accessibility assessment.
While not mandated by the EAA itself, a VPAT/ACR could be a practical tool for organizing and presenting the accessibility compliance information that the EAA does require.
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