VPAT vs ACR: what buyers actually ask for
Not legal advice. This guide is technical information about web accessibility. It does not tell you whether a law applies to your business and does not guarantee compliance.
A university or public agency asks your company for “a VPAT”. What they almost always want is a completed Accessibility Conformance Report for the exact product and version they are buying. This guide explains the difference, the editions and the terms, and how buyers read the document.
The template and the report
The Voluntary Product Accessibility Template, VPAT®, is published by the Information Technology Industry Council (ITI) and is free to use. ITI explains that a version of the VPAT completed for a specific product is an ACR. ITI also states that there is no submission process: nobody files, approves or stamps your report. Its value depends entirely on how carefully it was written and whether a buyer can trust it.
The US government describes an ACR as a document that explains how ICT products such as software, electronic content and support documentation meet the accessibility standards; see Section508.gov.
Which edition do you need?
As of 2026-11-09 the current template is VPAT 2.5Rev, released by ITI in April 2025, in four editions:
- WCAG edition: reports against the W3C Web Content Accessibility Guidelines. It includes WCAG 2.0, 2.1 and 2.2 criteria; you list only the versions you actually evaluated.
- 508 edition: the revised US Section 508 standards, used for US federal procurement.
- EU edition: EN 301 549, the European standard used in public procurement of ICT.
- INT edition: all three combined, for vendors selling into several markets.
The conformance terms
Each criterion gets one conformance level and a remark. The ITI template recommends these terms:
- Supports: the functionality meets the criterion without known defects, or meets it with equivalent facilitation.
- Partially Supports: some functionality does not meet the criterion.
- Does Not Support: the majority of the functionality does not meet the criterion.
- Not Applicable: the criterion is not relevant to the product.
- Not Evaluated: the product was not evaluated against the criterion. In a final report ITI allows this only for Level AAA criteria.
Why a draft has many open rows
Automated testing can decide only part of WCAG. A tool can see that an image has no alt attribute; it cannot tell whether the alt text that exists is accurate, whether the focus order makes sense, or whether captions match the audio. A draft that is honest about this will leave many Level A and AA rows open for a person to decide.
In our software-assisted ACR drafts those rows read “Not Evaluated — manual review required”, together with a note on what has to be checked. That is deliberately a draft state. Before you send the report to a buyer, your team replaces every such row with Supports, Partially Supports, Does Not Support or Not Applicable, based on its own testing. You can see how that looks in our sample ACR for this website.
How a buyer reads it
Public universities often review the ACR before a contract is signed. The University of Arizona, for example, asks vendors for a VPAT or ACR that reports against WCAG 2.1 Level AA, matches the version being bought and is less than two years old. Its accessibility team returns a risk level, and approved contracts can require the vendor to deliver a remediation plan within 30 days when defects are found.
Reviewers look for specific remarks rather than a column of “Supports”. A remark like “Product images on the search results page are missing alt text; fix scheduled for version 4.2” is more credible than a claim of full support with no detail.
Why the request is becoming more common
The 2024 Department of Justice rule under ADA Title II adopted WCAG 2.1 Level AA as the technical standard for the web content and mobile apps of state and local governments. An interim final rule of 20 April 2026 moved the compliance dates to 26 April 2027 for entities serving 50,000 people or more, and to 26 April 2028 for smaller entities and special district governments. The standard itself did not change, so public buyers keep asking their software vendors how their products measure up against it.
Check your own pages
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Related guides
Related tools
Sources
- ITI: VPAT® (Voluntary Product Accessibility Template): https://www.itic.org/policy/accessibility/vpat
- Section508.gov: Accessibility Conformance Report (ACR): https://www.section508.gov/sell/acr/
- Federal Register, 2026-04-20: extension of ADA Title II web and mobile app compliance dates: https://www.govinfo.gov/content/pkg/FR-2026-04-20/html/2026-07663.htm
- University of Arizona: Accessible procurement process: https://accessibility.arizona.edu/procurement/accessible-procurement-process