When to Update Your ACR: The Best Time to Start Filling In a New VPAT

2025 has arrived which got us thinking about timing: if you already have an ACR (Accessibility Conformance Report), when do you need to update your documentation with a new VPAT?

Before we start with the 6 times to start filling in a new VPAT, remember that a VPAT (Voluntary Product Accessibility Template) is simply templated document that we fill in. Once we complete the template, it becomes an ACR.

The terms VPAT and ACR are used interchangeably, but just know the ACR is what you’re after.

Here are the six times when you need to update your ACR.

Major Product/Service Updates

Anytime your product or service undergoes a significant change or update, it’s a great time to re-evaluate the accessibility. Here are some examples:

  • New features are added
  • New version release
  • Redesign
  • Improved user experience

Accessibility Improvements or Fixes

A kind of corporate Christmas eve is when you get a new ACR (and have your digital asset audited) after you’ve remediated existing accessibility issues.

This means you’ll now hold a cleaner ACR which means it will be easier to win contracts. This also demonstrates a commitment to accessibility because you’ve obviously worked on it.

Procurement Requests

Sometimes you’ll receive a request for a new ACR from a client or government agency. The request may not have any motivation behind it other than it’s necessary for policy compliance.

For example, “We require all sellers to produce a new ACR annually, before the contract renews.”

In these circumstances, it’s the date of issuance that reigns supreme.

Regulatory or Standards Updates

Let’s say your contract requires that you update your ACR to reflect the latest version of the Web Content Accessibility Guidelines (WCAG). In this case, when WCAG 2.2 was released in 2023, you would have needed to have a new VPAT filled in that accounted for the additional success criteria in 2.2.

The same could be said when there are updates to regulations or the law.

For example, Section 508 is still working under WCAG 2.0 AA as the standard. At some point – possibly 2025 or 2026, this is likely to be updated to 2.1 AA or 2.2 AA and then you’ll need to refresh your ACR.

Time-Based Refresh

After a certain amount of time passes, it’s best practice to update your ACR even if your product or service hasn’t undergone any significant updates.

One reason why is procurement agents are going to be leery of an ACR issued from years past.

Another reason is you may have made a collection of minor changes over the years and cumulatively they add up to enough to call for a new audit.

A good timeline to start with a fresh VPAT is between 1 and 2.5 years.

We’d recommend one year at the earliest and 2.5 years at the latest.

Fresh ACRs just work better during the procurement process because that’s one less area of doubt for the buyer. However, if zero edits/changes have been made, you could always inform the buyer that the ACR is as accurate now as when it was issued.

Independently Issued

Another reason to start with a fresh VPAT is if your previous ACR was issued in-house. Buyers are extremely skeptical of internally produced ACRs and some disregard them altogether. This is becoming more common as accessibility requirements have become more strict in the private marketplace.

Accuracy and completeness are essential when it comes to an ACR so buyers much prefer independently issued ACRs from third-party digital accessibility companies.

Summary

There are several scenarios where it makes sense to have a new ACR issued. The good news is being able to produce an updated ACR automatically returns value because it increases your likelihood of having your product purchased.

If you need help with VPAT services, we’re happy to help. Just send us a message and we’ll take it from there.

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Kris Rivenburgh

Kris Rivenburgh

Kris Rivenburgh is the founder of Accessible.org, LLC. Kris is an attorney and the author of The ADA Book, the first book on ADA compliance for digital assets. With seven years of experience in digital accessibility and ADA Compliance, Kris advises clients ranging from small businesses to public entities and Fortune 500 companies.