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VPATs & ACRs for Compliance Reporting

David Gibson

In our rapidly advancing digital era, the call for inclusive and legally compliant websites, mobile apps, and SaaS/web applications has become more pressing than ever. This urgency is not just fueled by legal mandates; it's amplified by DEI champions, discerning consumers, dedicated employees, potential buyers, and increasingly vigilant federal and state agencies. And we can't overlook the mounting legal actions from plaintiffs fighting what they would call digital discrimination. With regulations like Sections 508 and 504 of the Rehabilitation Act, the Americans with Disabilities Act, and an increasing number of state and even city ordinances, the message is unmistakable: our digital spaces must be inclusive to all.

But how does one know if a website or other digital property is “accessible”?

What are the standards of web accessibility, and how is that measured and reported?

In the US and abroad, the Web Content Accessibility Guidelines (WCAG) is universally considered the “standard” for digital accessibility. And in the US, the Volunteer Product Accessibility Template (VPAT) and subsequent Accessibility Conformance Report (ACR) are the standards for reporting.

Understanding WCAG: A Quick Dive

The WCAG is a set of guidelines aimed at ensuring all digital content is accessible to everyone, including those with disabilities. It’s been developed and maintained by the W3C - the international standards body for the Web. The WCAG is currently in version 2.1 although version 2.2 continue to be expected to be released “soon”. WCAG 3.0 is still a distance off.

WCAG is divided into three levels of conformance, offering a progressive approach:

  • Level A - This is the most basic level, outlining the absolute must-have accessibility features. Without these, some users would find it impossible to access the digital content.
  • Level AA - Adopting this level means that the digital content meets both Level A and Level AA criteria. It addresses the most common barriers for disabled users. Most organizations, especially in the public sector, aim to meet this level.
  • Level AAA - This is the gold standard of accessibility. However, it's also the most complex to achieve. While it's ideal, it's not always possible for all content to meet this level, especially complex web applications. That said, specific sections of a website could be at this level.

It's also worth noting that the guidelines are organized around four principles, often remembered with the acronym "POUR":

  • Perceivable - Users must be able to perceive the information being presented.
  • Operable - Users must be able to operate the interface.
  • Understandable - Users must be able to understand both the information and the operation of the interface.
  • Robust - The content must be robust enough to be reliably interpreted by a wide variety of user agents, including assistive technologies.

This set of guidelines offers a comprehensive framework to ensure digital content is accessible to all users, including those with disabilities and seniors. While originally designed for web content, its principles have expanded to encompass various digital mediums, emphasizing its universal application.

In the US, the intertwining of the WCAG, the 508 Rehabilitation Act, and the ADA has created a harmonious synergy aiming for a more inclusive digital world. While the 508 Rehabilitation Act initially mandated federal agencies to make their electronic and information technology accessible to people with disabilities, the ADA's broad scope encompasses private, non-profit, and commercial entities.

What's striking is how both the 508 Rehabilitation Act and ADA lean on the WCAG for assessing digital accessibility. This convergence has led to the elevation of the VPAT as a cornerstone tool for reporting digital accessibility compliance.


Diving Deeper into VPATs and ACRs

The VPAT itself has evolved in tandem with the growing demands of the digital landscape. Designed to provide a clear record of how a product aligns with accessibility standards, it’s a valuable tool for both vendors and consumers. Vendors gain insights into their product's accessibility strengths and areas needing improvement, while consumers, especially those in decision-making capacities like CMOs and marketing directors, are armed with critical information to make informed purchasing decisions.

There are currently four types of VPATs:

  • VPAT 508: Tailored specifically to meet the standards of the U.S. Federal 508 Rehabilitation Act.
  • VPAT EU: Aligned with the European EN 301 549 Accessibility requirements.
  • VPAT WCAG: Focuses solely on the WCAG guidelines and criteria.
  • VPAT INT: A comprehensive template incorporating all three aforementioned VPATs, offering a global perspective on a product's accessibility status.

What's the Difference Between a VPAT and ACR?

Once the VPAT is completed, it becomes known as an Accessibility Conformance Report (ACR). In practice, the two terms are used interchangeably but an ACR may add additional summaries or commentary to make it more user-friendly. 

ACRs & VPATs Evolution Beyond Government Procurement

Historically, the VPAT was a necessary requirement of government agencies and businesses eager to procure contracts with the federal government. Today, its relevance has permeated the commercial sphere, especially for entities aiming to show their conformance with federal and state laws, as well as their own DEI commitments.. Businesses now use VPAT/ACRs not just as a stamp of approval for government contracts but as a standardized assessment to demonstrate their commitment to accessibility conformance.

Whether you're a SaaS company, a mobile app developer, or a website owner, the importance of having a VPAT extends beyond mere compliance. It serves as a testament to your brand's commitment to inclusivity. 

While this piece primarily hones in on websites, it's pivotal to understand that the principles and importance of VPATs also resonate profoundly with web apps, SaaS platforms, and mobile apps.


The Art and Science of Authoring a VPAT

Crafting a VPAT isn't a task undertaken lightly; it's both an art and a science. Before even embarking on the process of authoring a VPAT, a meticulous accessibility audit of the digital product is imperative. And when we talk about a proper audit, we're emphasizing a thorough evaluation that combines both automated testing tools and the irreplaceable touch of human testing.

Automated tools, though efficient, have their limitations. While they can scan for apparent issues and provide a broad overview, they can only detect a fraction of potential WCAG violations, often missing more nuanced accessibility barriers that could hinder user experiences. Relying solely on these tools is akin to admiring the tip of an iceberg.

This is where experienced human auditors step in, bridging the gap left by automated tools. They meticulously analyze user experiences, especially from the perspective of those with disabilities. This involves diving deep into elements like user interface components, keyboard navigations, and assistive technology interactions. A seasoned auditor also understands the code that underpins digital platforms, thus allowing them to provide technical guidance for remediation.

Only after this comprehensive audit, which marries technology with the insights of human experience, can the process of authoring a VPAT truly begin. The document then stands as a testament to the digital product's accessibility.


Choosing the Right VPAT Provider

The creation of a VPAT isn’t a mere box-checking exercise. It requires a keen understanding of web accessibility coupled with intricate knowledge about website construction. Outsourcing VPATs to seasoned professionals is not just a smart move, but often a necessary one.

A credible VPAT provider combines expertise in web accessibility with technical acumen. They dig deeper than automated tools, leveraging human testers to offer a holistic view of a website or product’s accessibility. This combination of tech-savviness and a human touch ensures that the VPAT isn’t just a document but a genuine reflection of a product's inclusivity quotient.


VPATs and the Future of Accessibility Reporting

With WCAG 3.0 on the horizon, the world of digital accessibility is bracing for another evolution. The introduction of a more nuanced scoring system promises to offer greater insights into a website or product's accessibility. However, the place of VPAT in this new ecosystem remains rock-solid. While WCAG 3.0 might offer new tools and parameters, the VPAT, especially in its commercial application, will continue to be a beacon of transparency and commitment to digital inclusivity.


The Accessibility.Works team provides best-practice auditing and VPAT authoring services for website, SaaS, and mobile apps.