As we built the AI VPAT generation feature inside Accessibility Tracker, we followed all of the rules the Information Technology Industry Council (ITI) has for filling out a VPAT.
If you’re filling out a VPAT yourself, we’ve compiled those rules below.
Note: If you’d like Tracker AI to automatically generate your VPAT (you’ll still need to manually review), sign up for a paid plan at AccessibilityTracker.com. (emphasis added)
The VPAT is a standardized document for reporting product conformance with accessibility standards. The official template, maintained by ITI, includes detailed instructions that must be followed.
Where to Get the Official Template
Download the appropriate VPAT edition from the ITI Accessibility page. The template comes in four editions: WCAG, Revised 508, EN 301 549, and International. Choose based on which standards you’re reporting against. The WCAG edition covers Web Content Accessibility Guidelines versions 2.0, 2.1, and 2.2.
Required Elements
Every VPAT-based Accessibility Conformance Report must include these elements:
- Report Title – Use the format “[Company Name] Accessibility Conformance Report”
- VPAT Heading Information – Include the template version (e.g., “Based on VPAT® Version 2.5Rev”)
- Name of Product/Version – The specific product being evaluated, including version identifier if available
- Report Date – At minimum, provide month and year. The template advises: “If a date is included, ensure it is clear ‘4 May 2025’ or ‘May 4, 2025′”
- Product Description – A brief description of what the product does
- Contact Information – Where to direct follow-up questions. “Listing an email is sufficient.”
- Notes – Any relevant details about the product or report. This section may be left blank.
- Evaluation Methods Used – Describe how testing was performed
- Applicable Standards/Guidelines – Which WCAG versions and levels the report covers
The Five Conformance Terms
The template defines specific terms you must use in the Conformance Level column. According to the instructions:
- Supports – “The functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.”
- Partially Supports – “Some functionality of the product does not meet the criterion.”
- Does Not Support – “The majority of product functionality does not meet the criterion.”
- Not Applicable – “The criterion is not relevant to the product.”
- Not Evaluated – “The product has not been evaluated against the criterion. This can only be used in WCAG Level AAA criteria.”
The instructions include an important note about “Supports” versus “Not Applicable”: “When filling in the WCAG tables, a response may use ‘Supports’ where one might otherwise be inclined to use ‘Not Applicable’. This is in keeping with WCAG 2.0 Understanding Conformance: This means that if there is no content to which a success criterion applies, the success criterion is satisfied.”
If you modify ITI’s definitions, you must disclose this in the Notes section.
Remarks and Explanations Requirements
This column requires justification for your conformance level answers. The template is explicit about what’s needed: “When the conformance level is ‘Partially Supports’ or ‘Does Not Support’, the remarks should identify: the functions or features with issues [and] how they do not fully support.”
Additional guidance: “If the criterion does not apply, explain why. If an accessible alternative is used, describe it.”
Working with WCAG Version Differences
If reporting only on WCAG 2.0, you can remove rows marked “2.1 and 2.2” or “2.2 only” from the tables. Similarly, if reporting only on WCAG 2.1, you can remove rows marked “2.2 only.”
Note the special handling for criterion 4.1.1 (Parsing): “WCAG 2.0 and 2.1 – Always answer ‘Supports’. WCAG 2.2 (obsolete and removed) – Does not apply.” This reflects the September 2023 errata updates to WCAG.
Evaluation Methods to Document
The template suggests documenting various aspects of your testing approach, including whether testers knew general product functionality beyond just accessibility, what assistive technologies were used, what manual and automated testing tools were employed, and whether you followed a published test method (provide the name, publisher, and URL) or a proprietary method.
What You Can Customize
The template allows several modifications: combining the three WCAG level tables into one, reordering tables, translating to other languages, changing the delivery format to HTML or PDF, and adding company branding. You can also add the full criterion text to cells if helpful.
What you cannot do: deviate from the Essential Requirements while still calling it a VPAT. The template states: “Deviating from these guidelines precludes vendors from referencing the template by name and/or the VPAT acronym.”
Before Publishing
The template provides a pre-publication checklist. Verify you have responses for every criterion’s Conformance Level and Remarks columns. Confirm the final document itself is accessible. Remove the instruction pages (the first nine pages of the template).
Finally: “Post your final document on your company’s web site, or make the document available to customers upon request.”
Revisions and Updates
If you update a published report, the template advises: “change the report date and explain the revision in the Notes section. Alternately, create a new report and explain in the Notes section that it supersedes an earlier version of the report.”
AI VPAT Generation
We built Tracker AI to follow all of these rules automatically. It generates your VPAT directly from your audit data—properly formatted, required fields populated, remarks written. You review, edit, and publish.
You can auto generate a VPAT using your audit report with a paid plan at AccessibilityTracker.com.
