VPAT to ACR: The Complete Product Accessibility Documentation Guide

Updated: August 21, 2025

VPATs and ACRs may seem complex, but in this guide we’ll simplify everything you need to know about product accessibility documentation.

The demand for accessible products and services has skyrocketed because of a rapidly advancing private marketplace and regulatory updates that include the new ADA Title II web accessibility rule and the updated HHS Section 504 regulation that includes a section on digital accessibility that mirrors ADA Title II requirements.

This accessibility demand represents a huge growth opportunity for product vendors as buyers must purchase only WCAG 2.1 AA conformant products to ensure access to people with disabilities and for compliance and legal risk mitigation. But both buyers and sellers must understand how VPATs and ACRs work because glossing over the details can cause serious damage.

Note: VPATs can be filled out for products or services, but we’ll use “products” throughout this guide for simplicity.

Quick Start Guide

Need answers fast? Go directly to the section you need:

• Need an ACR in under 2 weeks? → Read How to Get a VPAT/ACR
• Evaluating an ACR right now? → Go to Guide for Buyers
• Which edition should you get? → See VPAT Editions
• Want to know if it’s worth the investment? → Visit Do You Need a VPAT/ACR?
• Checking if an ACR is legitimate? → Review What Makes a Good ACR?
• Have a specific question? → Check Frequently Asked Questions

What is a VPAT?

A Voluntary Product Accessibility Template (VPAT) is a standardized document template used to provide an accounting of a product’s accessibility against a technical standard.

A VPAT is the document we fill in to create an ACR.

Think of a VPAT as a blank report card that a teacher fills in. Only this report card is specifically for accessibility and the student is your product or service.

What is an ACR?

An Accessibility Conformance Report (ACR) is the resulting documentation after a VPAT is filled in and completed.

The ACR consists of two sections: important details (administrative information like product name and version) and an accessibility table (where we find out how the digital asset grades against the criteria for a standard).

What is the Meaning of VPAT?

The meaning of VPAT in the marketplace is ACR or Accessibility Conformance Report (ACR). Even though technically, buyers are asking for an ACR, many times they ask vendors to provide a VPAT. This usage is common in the marketplace and the meaning of the VPAT request is understood within context.

As you know, technically the meaning of VPAT is different: a VPAT is a templated document that provides for an accounting of a product or service. However, in the marketplace, VPAT is the term that is pervasive.

Purpose of VPATs and ACRs

The primary purpose is to assist in the procurement process by providing a standardized format for reporting product accessibility. Buyers can easily:

• Determine the accessibility of a product or service
• Compare the accessibility of digital assets against one another
• Make informed procurement decisions
• Ensure compliance with their accessibility requirements

What’s the Difference Between VPAT and ACR?

The difference is a VPAT (Voluntary Product Accessibility Template) is a template and ACR (Accessibility Conformance Report) is the completed template.

A VPAT is a standardized document that allows us to document accessibility in a uniform way. When we fill in and complete the VPAT, the result is an ACR.

Think of an ACR as an accounting of your product or service’s accessibility. Whatever the current state of accessibility for your product is, that’s what’s going to be reflected in the ACR.

Another analogy is that an ACR is like a report card of your product or service’s accessibility.

Some people think an ACR is certification – and it could be construed that way if your product is fully conformant with WCAG or another technical standard, but a better way to think of an ACR is as a mirror.

The ACR mirrors and documents whatever the current state of accessibility is when the digital accessibility company audits your product or service.

While the terms are often used interchangeably in the marketplace, VPAT and ACR are technically different. When procurement agents ask for a “VPAT,” they’re really asking for an ACR – the completed document showing how accessible your product actually is.

While the technical distinction is straightforward – VPAT is the template, ACR is the completed report – the practical implications run deeper. A VPAT by itself is just potential documentation. It represents the framework for assessment but provides no actual information about accessibility.

An ACR, on the other hand, contains:

• Detailed conformance levels for each accessibility criterion
• Remarks and explanations for any partial or non-conformance
• Specific information about testing methodologies used
• Contact information for follow-up questions
• Evaluation methods employed during assessment

This completed documentation is what buyers actually need to make informed decisions about procurement.

VPAT Editions

There are four different VPAT editions available, each serving different markets and compliance requirements. Choosing the right edition is critical – using the wrong one can result in rejection during procurement, even if your product is fully accessible. Each edition builds on similar accessibility principles but includes unique requirements specific to different regulatory frameworks and geographic regions.

The editions aren’t interchangeable. A Section 508 ACR won’t satisfy European procurement requirements, and a WCAG-only ACR won’t meet U.S. federal agency needs. Understanding these distinctions upfront saves time, money, and prevents lost contracts due to documentation mismatches.

Which Edition Should You Choose?

Our clients usually select the WCAG edition unless there’s a specific requirement for another standard.

How to Fill in a VPAT in 3 Steps

Step 1: Discard the Instructions

The first 10 pages of a VPAT template are instructions. Remove these for the final ACR – they’re just there to guide you through completion.

Step 2: Fill in the Details Section

Your finalized ACR must include:

• Report Title – Format: “[Company Name] Accessibility Conformance Report”
• VPAT Version – Template version being used
• Product Name/Version – Including version identifier if applicable
• Report Date – Date of publication
• Product Description – Brief description of what the product does
• Contact Information – For follow-up questions
• Evaluation Methods – Detailed breakdown of testing methodologies:
  • Screen reader testing
  • Keyboard-only interaction
  • Code inspection
  • Visual inspection
  • Browser zoom (200% and 400%)
  • Color contrast analysis
  • Automated accessibility scanning
• Applicable Standards – Which standards the report covers
• Legal Disclaimer (Optional) – Company disclaimer if desired

Step 3: Complete the Accessibility Table

This is where we document the actual accessibility status. For every criterion in your chosen VPAT edition, fill out:

Conformance Level Options:

• Supports: Functionality meets the criterion without known defects
• Partially Supports: Some functionality doesn’t meet the criterion
• Does Not Support: Majority of functionality doesn’t meet the criterion
• Not Applicable: Criterion isn’t relevant to the product
• Not Evaluated: Only allowed for WCAG Level AAA criteria

Remarks and Explanations:

• Required when marking “Partially Supports” or “Does Not Support”
• Recommended for “Supports” to provide context
• Include specific details about limitations and workarounds
• Never leave this column completely empty – it’s a red flag

Practical Example Entry

1.2.1 Audio-only and Video-only (Prerecorded)

• Conformance Level: Partially Supports
• Remarks and Explanations: The application provides transcripts for prerecorded audio content but lacks captions for video content. Plans are in place to implement captions in the next update.

The WCAG Edition of the VPAT (VPAT 2.5 WCAG)

The WCAG edition is based on the Web Content Accessibility Guidelines and is the most commonly used VPAT template. It focuses strictly on WCAG 2.1 criteria without additional hardware or telecommunications requirements. This edition is ideal for web-based products, software applications, and digital services that don’t have specialized hardware components. Organizations typically choose this edition unless they have specific regulatory requirements for Section 508 or European standards.

What Is WCAG?

WCAG (Web Content Accessibility Guidelines) are technical standards for web accessibility developed by the W3C. The guidelines follow four main principles (POUR):

1. Perceivable: Information must be presentable in ways users can perceive
2. Operable: Interface components and navigation must be operable
3. Understandable: Information and UI operation must be understandable
4. Robust: Content must work with various user agents and assistive technologies

WCAG Versions and Conformance Levels

Versions:

• WCAG 2.0 (2008)
• WCAG 2.1 (2018) – Most commonly required
• WCAG 2.2 (2023)

Conformance Levels:

• Level A: Foundational accessibility
• Level AA: Comprehensive accessibility (industry standard)
• Level AAA: Extreme level (rarely required)

The Section 508 VPAT Edition (VPAT 2.5 508)

The Section 508 edition is specifically designed for U.S. federal procurement and incorporates the revised Section 508 standards from 2018. While it includes WCAG 2.0 Level A and AA as its foundation, it adds specific requirements for hardware, software, support documentation, and authoring tools. This edition is mandatory when selling to U.S. federal agencies and includes additional criteria for closed functionality, biometrics, and telecommunications that aren’t found in the basic WCAG edition.

When Do You Need Section 508?

Section 508 is required when selling to U.S. federal agencies. It incorporates WCAG 2.0 Level A and AA criteria with additional requirements for:

• Hardware components
• Software applications
• Support documentation and services
• Authoring tools

Key Section 508 Components

Always Apply:

• Documentation and Support Services (602.2-602.4)
• Support Services accommodations (603.2-603.3)

Hardware Specific:

• Biometrics, Display Screens, Color Coding
• Operable Parts, Status Indicators
• Two-Way Communications capabilities

Software Specific:

• Non-web software requirements
• Platform products
• Authoring tools
• Assistive technology compatibility

The EN 301 549 VPAT Edition (VPAT 2.5 Rev EU)

The EU edition aligns with EN 301 549, the European standard for ICT accessibility. This edition is required for public sector procurement in the European Union, United Kingdom, Australia, and other countries that have adopted EN 301 549. It incorporates WCAG 2.1 Level AA as its web standard but includes additional requirements for hardware, two-way communication systems, video capabilities, and emergency services. The EU edition also has specific functional performance statements and slightly different applications of certain WCAG criteria.

When Do You Need EN 301 549?

Required for European Union public sector procurement, British, Australian, and other international markets. Based on WCAG 2.1 AA with additional ICT-specific requirements.

Key EN 301 549 Components

The standard contains 13 clauses, with clauses 5-13 covering technical requirements:

• Clause 5: General requirements for all ICT
• Clause 6: Two-way voice communication
• Clause 7: Video capabilities
• Clause 8: Hardware requirements
• Clause 11: Software requirements
• Clause 12: Documentation and support
• Clause 13: Relay and emergency services

The International (INT) VPAT Edition (VPAT 2.5 INT)

The INT edition is the most comprehensive VPAT template, combining all standards from the other three editions into a single document. This edition includes WCAG 2.1, Section 508, and EN 301 549 requirements, making it suitable for products marketed globally or when you need to demonstrate conformance to multiple standards simultaneously. While it requires the most extensive evaluation, it eliminates the need to maintain multiple ACRs for different markets. Organizations selling internationally or to diverse markets often choose this edition for maximum coverage.

When Do You Need INT?

The INT edition is necessary when your product needs to demonstrate conformance to multiple accessibility standards simultaneously. Choose this edition when:

• Selling to both U.S. federal agencies and European public sector organizations
• Marketing your product globally across different regulatory environments
• Responding to RFPs that reference multiple standards (WCAG, 508, and EN 301 549)
• Maintaining a single ACR for all markets rather than multiple regional versions
• Dealing with multinational corporations that require comprehensive accessibility documentation
• Your product is used in countries with varying accessibility requirements

Key INT Components

The INT edition combines all requirements from the other three editions, making it the most comprehensive but also the most complex to complete:

Standards Included:

• WCAG 2.1 Level A and AA criteria (full coverage)
• Section 508 requirements including hardware, software, and support documentation
• EN 301 549 requirements including all 13 clauses
• Functional performance criteria from both U.S. and EU standards

Unique Aspects:

• Three separate conformance tables (WCAG, Section 508, EN 301 549)
• Must address overlapping criteria across different standards
• Includes both WCAG 2.0 and 2.1 requirements to satisfy different standards
• Hardware criteria from both Section 508 and EN 301 549
• Documentation and support requirements from all standards
• Most extensive remarks and explanations needed due to multiple frameworks

Evaluation Complexity: The INT edition requires testing against the broadest set of criteria, including specialized requirements for telecommunications, emergency services, authoring tools, and platform-specific features. This makes it the most time-intensive ACR to complete but provides maximum market coverage with a single document.

What Makes a Good ACR?

A good ACR accurately reflects your product’s accessibility status through comprehensive testing and clear documentation. The difference between a valuable ACR and one that gets dismissed comes down to completeness, accuracy, and credibility. Here are the specific indicators buyers look for:

Complete Details Section

Every field in the details section should be filled out completely. This isn’t just administrative busywork – it shows attention to detail and professionalism:

• All administrative fields filled out including product name, version, and date
• Clear product description that explains functionality
• Full contact information for follow-up questions
• Evaluation methods section listing multiple testing approaches

Comprehensive Evaluation Methods

The evaluation methods section reveals whether real accessibility testing occurred or if someone just ran an automated scan. Professional ACRs explicitly document:

• Screen reader testing explicitly mentioned
• Keyboard navigation testing documented
• Multiple methodologies listed (manual testing, code inspection, visual inspection)
• Browser zoom testing at 200% and 400% included
• Color contrast analysis documented
• Automated scanning tools identified

Accurate Conformance Reporting

Using the correct terminology and applying it consistently demonstrates understanding of accessibility standards:

• All conformance levels properly filled out using correct terminology
• Terms used are “Supports,” “Partially Supports,” “Does Not Support,” or “Not Applicable”
• No empty cells in the conformance level column
• “Not Evaluated” only used for WCAG Level AAA criteria

Detailed Remarks and Explanations

This column separates professional ACRs from checkbox exercises. Good documentation provides context that helps buyers understand exactly what works and what doesn’t:

• Required entries for all “Partially Supports” and “Does Not Support” levels
• Sufficient information to understand how a product fails criteria
• Known workarounds documented where available
• Supporting context provided even for “Supports” levels where helpful
• Specific rather than vague descriptions of issues

What are VPAT Red Flags?

Procurement agents quickly identify problematic ACRs through common mistakes that suggest rushed or inexperienced evaluation:

Documentation Issues

These gaps indicate the ACR wasn’t taken seriously or was completed without proper testing:

• Empty remarks and explanations column throughout the document
• Missing or incomplete evaluation methods section
• No mention of manual testing with assistive technologies
• Vague descriptions that don’t explain actual functionality

Technical Errors

Using incorrect terminology or misapplying conformance levels shows lack of accessibility expertise:

• Incorrect conformance level terms like “Passes,” “Fails,” or “Minor Exceptions”
• “Not Applicable” used when “Does Not Support” is correct
• “Not Evaluated” used for Level A or AA criteria
• Inconsistent application of conformance levels

Credibility Concerns

These issues make buyers question whether the ACR accurately represents the product’s accessibility:

• No screen reader or keyboard testing mentioned in evaluation methods
• Marketing language instead of technical documentation
• Overly optimistic conformance levels without supporting details
• Internal assessment without third-party validation
• Altered or modified ACR after initial issuance

Should You Have a Third-Party Issue Your ACR?

Why Third-Party Evaluation Is Important

While anyone can technically fill in a VPAT, independent third-party assessments carry much more weight because:

• Eliminates bias: Internal assessments tend to underreport issues
• Ensures expertise: Accessibility requires specialized knowledge
• Increases credibility: Buyers trust independent verification
• Provides accuracy: Professional evaluators use proper methodologies

What Service Providers Offer

Professional accessibility companies provide:

• Comprehensive accessibility audit
• Accurate VPAT completion
• “Pause-and-fix” options (remediate before ACR issuance)
• Expert validation of fixes
• Ongoing support for questions

Do You Need a VPAT/ACR?

Yes, when you are selling into certain markets, a VPAT/ACR will be required to be considered for purchase. This can be the case even if you’re the only seller. ACR documentation has become mandatory in many sectors and this mandate is spreading across the globe.

The need for an ACR has evolved from a federal requirement to a market expectation across multiple sectors. Under Section 508 of the Rehabilitation Act, U.S. federal agencies are legally required to procure accessible ICT products and services, making ACRs mandatory for federal contracts. This requirement has created a ripple effect throughout the procurement ecosystem across the world. Sellers inside the United States, European Union, and many other countries and territories now must provide documentation of accessibility.

You generally need an ACR when selling to:

• Federal agencies (mandatory under Section 508)
• State and local governments
• Educational institutions
• Healthcare organizations
• Large enterprises with accessibility policies

Market Reality in 2025

Without an ACR, you’re essentially locked out of many markets. Organizations increasingly require this documentation as a baseline for consideration, regardless of your product’s actual accessibility or other merits.

How to Get a VPAT/ACR?

For audit, remediation, consultation, or ACR creation services, contact a reputable digital accessibility company that:

• Has proven expertise in accessibility testing
• Doesn’t sell or recommend overlay widgets
• Provides detailed audit methodologies
• Offers education alongside services

Timeline Expectations

From initial contact to ACR delivery, you can have an ACR delivered in as soon as a week as long as you don’t want to remediate your digital asset.

1. Initial scoping (1-2 days)
2. Proposal and agreement (2-3 days)
3. Accessibility audit (1-2 weeks)
4. VPAT completion (1-2 days)
5. Review and delivery (1 day)

Total timeline: 10-20 days typical, rush service available

Information You’ll Need to Provide

• VPAT edition required
• WCAG version needed
• Scope preferences
• Testing environments (mobile/desktop)
• Product version
• Test credentials
• Contact information

VPATs for Buyers

As a buyer or procurement agent, you need to quickly assess whether an ACR accurately represents a product’s accessibility. A well-documented ACR helps you make informed decisions, while a poor one could lead to purchasing inaccessible products that create legal risk and exclude users with disabilities. This guide will help you evaluate ACRs effectively.

How to Evaluate an ACR

Follow these eight steps to systematically review any ACR you receive. Each step builds on the previous one to give you a complete picture of the product’s accessibility status and the reliability of the documentation:

1. Verify the correct VPAT edition was used
2. Confirm current product version is documented
3. Review evaluation methods for completeness
4. Check who conducted the testing (internal vs. third-party)
5. Verify all product components are covered
6. Review conformance levels for critical criteria
7. Examine remarks for sufficient detail
8. Spot-check accuracy if possible

What to Look For

Beyond the systematic review, certain indicators quickly reveal whether an ACR represents genuine accessibility testing or just a compliance checkbox exercise. Prioritize vendors whose ACRs demonstrate:

• Evidence of manual testing with assistive technologies
• Detailed explanations for any non-conformance
• Clear workarounds documented
• Recent evaluation date
• Professional third-party assessment
• Reputable provider (not an overlay widget seller)

Frequently Asked Questions (FAQ)

Is a VPAT a Certification?

No, a VPAT is not certification. An ACR isn’t certification of accessibility either. They’re documentation of accessibility status – an accounting that can show various levels of conformance from 0% to 100%. Many product owners and procurement agents mistakenly believe that merely having an ACR means a product is accessible, when it simply documents whatever level of accessibility exists, good or bad.

Do Websites Need VPATs?

Generally, no. Websites usually use conformance statements or certifications. However, an ACR may be needed if the website or some web pages are part of the product or service. For example, if product instructions are hosted on your website or the product refers back to web pages for functionality.

Can We Alter an ACR After Issuance?

No. ACRs can have legal implications and should never be altered after issuance. If your product changes, get a new ACR. This is why timing matters – if you’re about to release a new version, wait for that release before starting the VPAT process.

What If We Have Accessibility Issues?

Having some accessibility issues doesn’t necessarily preclude your product or service from purchase. Complete transparency with lighter issues can work in your favor. Remember, procurement agents are scrutinizing ACRs and one that admits some issues can be viewed as credible. Moreover, competing sellers may have products with more accessibility issues present than yours. However, if accessibility is severely lacking, you won’t be seriously considered unless the buyer isn’t prioritizing accessibility.

Who Should Fill Out Our VPAT?

While anyone can technically complete a VPAT, discerning buyers will ask who issued your ACR. Independent third-party assessments from reputable accessibility companies carry significantly more weight than self-assessments due to eliminated bias and specialized expertise.

Do We Need to Include Every Product Component?

Yes. If users cannot distinguish a third-party component from your product, include its accessibility information in your ACR. If it’s clearly a separate product, note this and provide a URL for its accessibility information if available.

What If We’re Using an Overlay Widget?

Overlay widget vendors often sell VPAT services, but overlay vendors are viewed very negatively in the accessibility industry, and procurement agents are usually aware of this reputation. Choose a reputable provider who doesn’t sell widgets and focuses on legitimate accessibility practices.

How Current Does Our ACR Need to Be?

ACRs should reflect the current version of your product. Using an outdated ACR for a newer product version can raise credibility concerns and may not accurately represent your product’s current accessibility status.

Can We Just Run an Automated Scan?

No. You can’t accurately fill out a VPAT without a comprehensive audit. Real audits require manual evaluation using diverse, manual methodologies. Automated scans should only be used as a secondary review. Nothing automated should be featured as the primary evaluation method.

Is Having an ACR Enough to Win Contracts?

It can be. Sometimes the only requirement is that you check the ACR box, so to speak. However, merely having an ACR isn’t close to a lock. Buyers compare ACRs across competing products, looking at conformance levels, quality of documentation, and who conducted the assessment. The ACR gets you in the door, but the actual accessibility it documents determines competitiveness.

Conclusion

VPATs and ACRs have become essential business documents that determine whether you can compete in major markets. The fundamentals are straightforward: choose the right VPAT edition for your market, conduct a thorough accessibility audit, document findings accurately, and have a reputable third-party issue your ACR when possible.

For vendors, having a quality ACR means access to federal contracts, educational institutions, healthcare systems, and enterprise clients. For buyers, understanding how to evaluate ACRs ensures you’re purchasing genuinely accessible products that minimize legal risk and serve all users. The investment in proper accessibility documentation pays for itself through expanded market opportunities and reduced compliance risk.

Next steps depend on where you stand today. If you need your first ACR, start by identifying which edition matches your buyers’ requirements. If you have an existing ACR, verify it meets the quality standards outlined in this guide. Remember that accessibility documentation must be updated when your product changes significantly.

If you need help with audit, remediation, consultation, or ACR creation services, Accessible.org offers all of the digital accessibility services you need for accessibility and documentation. Contact us to inquire about your project.

VPAT Resources

Accessible.org offers excellent VPAT services to help you get a complete and accurate ACR as soon as possible.

To learn more about VPATs and ACRs, we highly recommend the following resources which we used in the creation of this comprehensive guide.

• Information Technology Industry Council (ITIC) current VPAT editions and information
• VPAT training modules on YouTube
• Section 508 ACR/VPAT FAQ

Accessibility Training

Accessibility training is paramount for all digital teams. We can help your team learn WCAG 2.1 AA and WCAG 2.2 AA. Learn more about our on-demand training programs.