VPAT

The information presented within this glossary entry is aimed at website owners seeking to learn the ropes of web accessibility. Technical elements are described in layman’s terms, and, as a rule, all topics pertaining to the legalities of web accessibility are presented in as simplified a manner as possible. This guide has no legal bearing, and cannot be relied on in the case of litigation.

VPAT, which stands for Voluntary Product Accessibility Template, is a document that explains how information and communication technology (ICT) conforms to the accessibility standards outlined by Section 508 of the Rehabilitation Act. Information and communication technology (ICT) includes websites, online documents, videos, podcasts, and various other software.

Organizations that must comply with Section 508 need to fill out a VPAT. Said organizations can fill one out themselves or rely on expert service providers to do so for them.

History of VPATs

The VPAT was initially developed in 2001, when the Information Technology Industry Council (ITI) partnered with the U.S. government's central procurement office, the General Services Administration. The latter bodies sought to properly address how organizations falling under Section 508’s requirements can document their efforts to render their ICT accessible to people with disabilities. These efforts culminated in the creation of the Voluntary Product Accessibility Template, a standardized template that technology vendors could use to report on the accessibility of their products.

In 2017, the ITI introduced VPAT 2. An updated version of the original VPAT, VPAT 2 integrated the modified requirements of the newly revised Section 508 standards, (commonly known as the Section 508 Refresh). VPAT 2 also incorporates elements of the Web Content Accessibility Guidelines (WCAG) 2.0 and the European accessibility standard, EN 301 549.

VPAT 2.4 was published by the ITI in February 2020. This includes provisions from the EN 301 549 V3.1.1, and is the most current, up-to-date VPAT version.

It’s important to note that VPAT is available in four editions: 

  1. WCAG edition - aimed at reporting conformance with WCAG 2.0 or 2.1
  2. 508 edition - aimed at reporting compliance with the Revised Section 508 requirements, in addition to WCAG
  3. EU edition - Specifically tailored for reporting compliance with the EN 301 549, in addition to WCAG
  4. INT edition - An international edition that enables reporting compliance with all three aforementioned standards

Organizations required to fill out a VPAT

Organizations that fall under the scope of Section 508, either directly or indirectly, must complete an updated VPAT. These include:

  • All U.S. federal agencies, including the Department of Defense, Department of State, Environmental Protection Agency, and the Department of Health and Human Services
  • State, county, and municipal jurisdictions that receive financial aid from the U.S. federal government, such as public schools, state transportation departments, and local police departments
  • Companies that offer digital products or services to organizations receiving federal financial assistance must also fill in a VPAT, such as software development companies providing content management systems to public universities, or contractors designing websites for state government agencies

The process of filling in a VPAT

Filling in a VPAT requires a keen understanding of the ICT in question, along with intimate knowledge of accessibility requirements and testing processes. Many organizations choose to enlist the help of specialized service providers, such as accessServices, to complete the VPAT for them. Regardless, VPATs should be filled in after an ICT asset is launched, or during the testing phase leading up to a product or platform’s launch.

The process of filling in a VPAT generally involves the following steps:

  1. Assessment of conformance: The VPAT's structure requires organizations to evaluate their product or service's conformance with specific provisions relevant to accessibility. For the most part, the set of web accessibility guidelines that various ICT must conform to under Section 508 is WCAG 2.0 Level AA. Those filling in the VPAT must then select one of four conformance levels to indicate a given ICT asset’s degree of conformance to WCAG 2.0 Level AA: Supports, Partially Supports, Does Not Support, or Not Applicable
  2. Creation of an Accessibility Conformance Report (ACR): Upon completion, the VPAT document becomes an Accessibility Conformance Report, or ACR, which should only contain the filled-in template. This report serves as a record of the organization's commitment to accessibility and their conformance with the necessary standards
  3. Regular updates and renewals: To maintain accuracy and relevance, organizations should update their VPAT whenever significant changes occur (such as a website redesign or the addition of substantial new content). In the absence of major changes, they should renew the VPAT annually

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