A VPAT or Voluntary Product Accessibility Template is a document used to report on the accessibility of ICT products and services. A VPAT is not a legal document, but it can have legal implications.
The best illustration of this is the primary use of the classic buyer-seller engagement during the procurement process where the buyer asks for a VPAT/ACR to inspect the accessibility of the product or service. By providing an Accessibility Conformance Report (ACR), the seller is essentially warranting that the ACR is accurate and complete and represents the product or service’s state of accessibility.
The terms VPAT and ACR are often used interchangeably, but it the VPAT is the template and the ACR is the resulting report once the template is filled in and completed.
If the seller provides an ACR that misrepresents the accessibility status, there can be contractual issues that arise because the seller has supplied the buyer with material false information.
Beyond contractual concerns, an inaccurate ACR could expose organizations to liability under accessibility laws like Section 508, the ADA, or the European Accessibility Act. If a buyer relies on your ACR to meet their own compliance obligations and later discovers the documentation was misleading, the consequences extend beyond a single transaction.
This is why thorough accessibility audits matter before filling in the VPAT. The audit findings directly inform the conformance levels and remarks in the accessibility table. When an independent digital accessibility company conducts the evaluation and issues the ACR, buyers have greater confidence that the documentation reflects reality.
Organizations should treat ACR accuracy with the same care they would apply to any business representation that could affect purchasing decisions. The WCAG conformance levels reported in your ACR become part of the procurement record, and discrepancies between documentation and actual product accessibility can surface during implementation.
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