Reading a vendor's VPAT before you buy, and what to ask next
What an ACR built on the VPAT template tells a buyer, what its five conformance terms mean, the signs a report can't be relied on, what to ask in a tender, and how to reduce the risk once you buy.
In short: A VPAT is ITI's blank template; filled in for one product, it becomes that vendor's Accessibility Conformance Report (ACR), a statement by the vendor, not a test by you. Read who tested which version, how and when, and the remarks behind each term; then test your own key tasks, and put what is still missing into the contract.
01
When you need this
A library service is choosing a system for booking rooms and events. 2 vendors are on the shortlist. Vendor A sends a 14-page document headed "Accessibility Conformance Report, based on VPAT Version 2.4", for version 6.0 of its product, dated March 2024. The version on offer is 7.3. Vendor B sends a one-page letter: "Our platform is fully compliant with WCAG 2.1 AA."
The procurement lead has to say which of the 2 is the safer buy, and what the contract should ask for. Neither document was written by the library, and neither was tested on the library's own tasks.
02
What a VPAT is, and what an ACR is
The Voluntary Product Accessibility Template (VPAT) is a template published by the Information Technology Industry Council (ITI). ITI's page says that a VPAT completed for a specific product is an ACR. So the document a vendor sends is their ACR; "VPAT" is the blank form it was made from. The template's instructions say it is "the vendor's responsibility to maintain the integrity of the data in the report": it is the vendor's own statement.
As of 2 November 2026, the current template is VPAT 2.5Rev, dated April 2025, in 4 editions. Check ITI's VPAT page for a later one.
| Edition | Covers |
|---|---|
| WCAG | WCAG 2.0, 2.1 and 2.2 |
| Revised 508 | WCAG 2.0, and the Revised Section 508 standards (published 2017, corrected 2018) |
| EU | WCAG 2.0 and 2.1, and EN 301 549 V3.1.1 and V3.2.1 |
| INT | All of the above |
The EU edition of 2.5Rev covers EN 301 549 V3.1.1 and V3.2.1. ETSI published V4.1.1 in September 2026, which the 2.5Rev editions don't list, so an ACR made from them doesn't report against it.
The template lists what every ACR must contain, among them the product's name and version, the report date (month and year at least), contact information, the evaluation methods used, the standards covered, the definitions of the terms used, and an answer in the Conformance Level and Remarks and Explanations columns for each criterion. A document without these is not an ACR in the template's terms, whatever it is called. What it takes for a page to conform to WCAG explains how an ACR differs from a conformance claim.
03
The five conformance terms
Each row of an ACR gives one of these terms. These are ITI's definitions, word for word:
| Term | ITI's definition |
|---|---|
| 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. |
3 rules in the template change how a row reads:
- For Partially Supports and Does Not Support, the remarks should identify the functions or features with issues and how they fall short. A Partially Supports row with an empty remark gives you nothing to plan around.
- In the WCAG tables, a row may say Supports where nothing on the product falls under the criterion, in keeping with WCAG's own reading of conformance. So a Supports for captions on a product with no video is correct, and not a warning sign.
- A vendor may use other definitions only if the Notes section says so. Read the Terms section before the tables.
04
Reading one: who, how, when, which version
Read the header before the tables. It answers the questions that decide whether the rows mean anything:
- Which product and version. The ACR describes one version. If the version on offer is newer, the rows describe software you aren't buying.
- When. The report date, and whether the Notes explain a revision.
- How it was tested. Evaluation Methods Used should say whether the testers knew the product, which assistive technology they used, which manual and automated tools, and which published or in-house method.
- Who tested. The template doesn't require a named tester. If a third party tested the product, this is where the report would say so; if it says nothing, assume the vendor tested it.
The warning signs are plain to see:
- Every row says Supports, and no remark explains any of them.
- Evaluation Methods Used names only an automated scan. A scan can't confirm many criteria, as what automated checks miss shows.
- The product version or the report date is well behind what you are buying.
- The template version is older than the current one, or the report has none of the required parts: a one-page letter claiming compliance is not an ACR.
- The ACR covers the main application, but the product embeds third-party parts it doesn't mention, such as a support chat or a consent banner.
05
What to ask in a tender, and testing it yourself
The template says an ACR is there to help buyers make "preliminary assessments". These questions turn a preliminary assessment into one you can stand behind:
- Send the ACR for the version we would get, on the current template, with Evaluation Methods Used filled in.
- Who tested it: an internal team or a third party, and with which assistive technology?
- For each Partially Supports or Does Not Support row, what is the issue, is there a workaround, and when will it be fixed?
- Does the ACR cover the parts the product embeds from other suppliers?
- How do your users report an accessibility problem, and how long does a fix take?
- Will you fill in a self-assessment of your accessibility programme? NASCIO's Policy-Driven Adoption for Accessibility (PDAA) has a vendor self-assessment for this, built on 6 core criteria, from having a policy to making information about policy and progress available to customers.
Then test the product yourself on a trial instance, on your own key tasks: booking a room, cancelling it, finding an event. Use a keyboard alone, a screen reader and 200% zoom, and compare what you find with the rows that cover it. Test what you would deploy, embedded parts included: a support chat that never reads its replies, as in chat widgets that never announce their messages, or a consent banner that hides focus, as in cookie banners that hide keyboard focus and come last, is part of the product your users meet. If the product is itself an accessibility tool that runs on your site, such as an overlay or a monitoring dashboard, EaseWeb's accessibility vendor review sets its claims beside test results.
06
Reducing the risk once you choose
Few products support every criterion, so the choice is often the one that best meets the requirements, with the gaps written down. Each of these is a proof point in the procurement dimension of the W3C Accessibility Maturity Model, or a core criterion of PDAA:
- A roadmap for known issues: each open row with a fix date. PDAA asks vendors for a plan with dates for inaccessible ICT.
- Contract terms: the W3C model lists proof of vendor testing, warranties and remedies that include accessibility, and vendor corrective actions and remediation plans before and after deployment.
- An alternative access plan: until a gap is fixed, the alternative means people use instead, such as staff taking bookings by email or phone, written down and published, as in accessibility statements that are missing or say nothing.
- Monitoring: a defined way to take users' accessibility complaints to the vendor, and a retest of each new major version against the ACR.
- Renewals: the W3C model's Integrate level includes accessibility criteria in contract renewal negotiations. A renewal is the point at which open rows can still change the price.
A maturity model judges the organisation, not the product. The W3C model's 7 dimensions run from Communications to Support, each at 4 levels: Inactive, Launch, Integrate and Optimize. The model says it took those level names from PDAA, whose maturity model rates its 6 core criteria at Launch, Integrate and Optimize. Use the W3C model's procurement dimension to check your own buying process, and PDAA's self-assessment to compare vendors' programmes beside their ACRs.
07
Worked example
The library reads both documents against the header questions, then tests Vendor A's trial on 3 tasks: book a room, cancel it, and find an event.
| Row or header | What the ACR says | What the library found or asked |
|---|---|---|
| Product and date | Version 6.0, March 2024, VPAT 2.4 | Asked for an ACR for 7.3 on 2.5Rev; Vendor A agrees to supply one in 8 weeks |
| Evaluation Methods Used | "Automated testing tools" | Asked who tested manually and with which screen reader; the answer: nobody yet |
| 2.1.1 Keyboard | Supports, no remark | The room calendar can't be opened from the keyboard, so a keyboard user can't book |
| 1.4.10 Reflow | Partially Supports: "Calendar week view scrolls horizontally at 320 CSS pixels" | Confirmed; the day view works, so it has a workaround |
| 4.1.3 Status Messages | Supports | "Booking confirmed" appears on screen but isn't announced by NVDA |
| 1.4.6 Contrast (Enhanced) | Not Evaluated | Allowed: 1.4.6 is a Level AAA criterion |
Vendor B's letter has no version, no date, no method and no rows, so the library asks for an ACR. None arrives before the deadline.
The result: the library chooses Vendor A, with 3 known gaps written into the contract. The calendar's keyboard access and the confirmation message get fix dates within 6 months, with remedies if they slip. Until then, the library's accessibility page tells people they can book by email or phone. The updated ACR for 7.3, with manual and screen reader testing, is a condition of acceptance, and the library tests again before the renewal.
08
Common mistakes
- Treating the ACR as proof. It is the vendor's statement, with no review behind it unless the methods say so. Test your key tasks yourself, as in the steps above.
- Counting Supports. 50 Supports rows don't outweigh 1 Does Not Support row on the task your users need. Read the rows that cover your key tasks first.
- Accepting "compliant" without an ACR. A one-page claim gives no version, date, method or remarks. Ask for the report.
- Ignoring the version. An ACR for an older version says little about what you deploy. Ask for one for the version in the contract.
- Buying with the gaps unwritten. A gap known at signing and missing from the contract is hard to raise later. Put fix dates, remedies and the alternative means in it.
- Forgetting the embedded parts. The chat, the consent banner and the payment page may come from other suppliers. Test them as chat widgets that never announce their messages and cookie banners that hide keyboard focus and come last describe.
09
What the standard says
- Section 508 E202.7 (required, for US federal agencies): "Where ICT conforming to one or more requirements in the Revised 508 Standards is not commercially available, the agency shall procure the ICT that best meets the Revised 508 Standards consistent with the agency's business needs." E202.7.1 requires the agency to document the market research and the basis for its choice, and E202.7.2 requires it to "provide individuals with disabilities access to and use of information and data by an alternative means that meets identified needs".
- EN 301 549 V4.1.1 (informative parts): the Introduction says that in ICT procurement "all of the technical requirements in clauses 5 to 13, as well as the functional performance criteria in clause 4 should be considered". Annex E.4.2 asks, before choosing, "Which failed requirements are possible to compensate with other alternatives, like for example a service desk?", what that alternative would cost, and whether the failed requirements can be fixed in the next version. What EN 301 549 itself requires is in what EN 301 549 asks of a website beyond WCAG.
- VPAT 2.5Rev (a template, not a standard): the 5 terms and the required contents above. Deviating from its essential requirements bars a vendor from calling the report a VPAT.
- W3C Accessibility Maturity Model (W3C Group Note, advice): the procurement dimension's proof points, such as "warranties and remedies section includes accessibility" (3.6.2.4) and "a defined process for identifying and addressing user accessibility complaints with vendors" (3.6.2.5).
- NASCIO PDAA (2015, advice): the PDAA has 3 components, the Core Criteria, the Maturity Model and the Vendor Self-Assessment Tool. NASCIO says the self-assessment's responses can "help assess a vendor's ability to produce accessible offerings" and gauge confidence in a vendor's VPAT.
- Japan: the Ministry of Internal Affairs and Communications publishes an information accessibility self-assessment format, modelled on the US VPAT, for companies to publish how their ICT products and services meet accessibility requirements (2025 White Paper on Information and Communications). Its guidelines for public websites (2024 edition, 6.4) ask a public body ordering a website to set its JIS X 8341-3:2016 target before writing the specification, to state in it what the contractor must do, to check the accessibility of a bidder's past sites, and to accept the delivery only after checking a JIS test result.
10
Limits
This page reads a vendor's report; it doesn't test the product, and a trial on 3 tasks is not an audit. Whether a product "best meets" a law's requirements, and what a contract can require, are questions for the buyer's lawyer and procurement rules. The template and the standards change: check ITI's page for the current VPAT, and ETSI for the EN 301 549 edition your contract cites. What the criteria themselves require is in what it takes for a page to conform to WCAG.
11
Terms
- ACR
- Accessibility Conformance Report: the VPAT template filled in for one product and version, stating how well it meets each criterion.
- Partially Supports
- The VPAT term for a criterion that some of the product's functionality does not meet.
- alternative means
- Another way to give people with disabilities the information and function a product doesn't make accessible, such as staff taking a booking by email.
- maturity model
- A set of levels for judging how far an organisation has built accessibility into its policy, processes and contracts, not one product.
12
Sources and guides
- Advice VPAT 2.5Rev (ITI, April 2025): Essential Requirements for Authors; Terms; Best Practices for Authors (opens in a new tab)
- Required Section 508 (36 CFR 1194, Appendix A): E202.7 Best Meets, E202.7.2 Alternative Means (opens in a new tab)
- Advice EN 301 549 V4.1.1 (2026-09): Introduction; E.4.2 Connection between requirements and functional performance criteria (informative) (opens in a new tab)
- Advice W3C Accessibility Maturity Model (W3C Group Note, 4 November 2025): 3.6 Procurement (opens in a new tab)
- Advice Accessibility in IT Procurement: Part 2 (NASCIO, 2015): The PDAA Components (opens in a new tab)
- Advice Information accessibility self-assessment format (Ministry of Internal Affairs and Communications, Japan): Overview (opens in a new tab)
- Advice Guidelines for Operating Public Websites, 2024 edition (Ministry of Internal Affairs and Communications, Japan): 6.4 Ordering from outside contractors (opens in a new tab)
Guides that show it
- Accessibility statements that are missing or say nothing A shop has no page saying what works with assistive technology, what is known not to, or whom to tell, or has one that only claims to meet WCAG.
- Chat widgets that never announce their messages A support chat keeps its messages in a plain div, so a screen reader never reads the greeting when the panel opens, or a reply when it arrives.
- Cookie banners that hide keyboard focus and come last A cookie banner fixed over the footer hides links that take focus behind it, or, added after the footer, is the last thing Tab and screen readers reach.
This page explains a practice, with recreated examples. It is not legal advice, and it is not a finding about a named client.