Five Common VPAT® Questions from Our Customers, Answered

If you intend to sell a digital product to the U.S. federal government or another public-sector organization, you’ve likely been asked to provide a completed Voluntary Product Accessibility Template (VPAT)—also known as an Accessibility Conformance Report (ACR). The VPAT is the established format for documenting that your product meets accessibility standards, such as the Web Content Accessibility Guidelines (WCAG). Put simply, completing a VPAT demonstrates to buyers whether your product is accessible for people with disabilities.

Requesting this type of documentation from vendors has long been standard practice for government agencies and educational institutions. And as businesses grow increasingly aware of the legal risks associated with integrating inaccessible third-party software, it’s becoming more common in the private sector, too.

While an ACR is a critical gate to business-to-business (B2B) and business-to-government (B2G) sales, the process for completing a VPAT can be complex. We recently covered the ins and outs of this journey in our webinar, “The Value of a VPAT: How to Accelerate B2B Sales with Proof of Digital Product Accessibility.” If you’re new to VPATs and ACRs, we recommend accessing the on-demand recording to get oriented. But even organizations familiar with the VPAT format are often unsure about how to best go about documenting conformance. In this piece, we’ve compiled some of the most frequently asked VPAT questions we get from our customers—and how we answer them.

1. I need a completed VPAT right away. Can I get one?

Completing a VPAT is more complex than just taking time to answer questions on a document. Producing an accurate, reliable, and effective ACR is a multi-step process that involves identifying which WCAG standards your products must meet, testing your product against those standards, and remediating any issues that potentially render your product non-conformant.

Navigating this process takes time, particularly if you’re new to digital accessibility and want to present your buyers with an ACR that demonstrates a high level of WCAG conformance. That’s because you’ll need to implement a fix for every applicable criterion that your product doesn’t currently support. Obtaining an ACR you’re proud of can be time-consuming, so it’s best practice to initiate the process now if you think you may need an ACR in the future.

2. Is it a problem if my product only “partially supports” a criterion?

One of the most common VPAT questions we receive from customers who have completed a product evaluation is whether a designation of “partially supports” for any given WCAG criterion will be acceptable to buyers. “Partially supports” means that parts of your product meet a criterion of your target accessibility standards, but other parts do not. For example, if some video content in your product has captions, but other video content does not, you would indicate “partially supports” for WCAG success criterion 1.2.2 – Captions (Pre-Recorded).

You’ll make the best impression on buyers by demonstrating full conformance with your targeted set of standards, meaning your product fully supports all applicable criteria. However, if you don’t have the resources to achieve full conformance by the time your buyer requires an ACR, you may choose to leave instances of “partially supports” in this documentation.

If that’s the case, it’s important that you have a plan in place for addressing the issues that prevent you from fully meeting these criteria, and that you communicate this plan to buyers. Some buyers may request a documented roadmap for when you plan to address any non-conformant issues, including your specific timeline for implementing fixes. They may also request information about any workarounds that are currently available to users for navigating these issues, so they can understand these errors’ impact.

3. Does an ACR need to cover the accessibility of third-party plugins?

Established accessibility standards, including WCAG and Section 508 of the Rehabilitation Act of 1973, do not include exemptions for technology from third parties. That means that if your product includes plugins or other integrations from a third-party vendor, this functionality needs to be included in your ACR.

You likely won’t have access to the source code of a third-party plugin to implement fixes yourself—so finding accessibility barriers in technology you’ve purchased can be frustrating. And these issues can impact your ability to sell your own product. We typically advise customers in this situation to work directly with their vendor to address barriers, or to switch to an accessible vendor.

Note: Before you implement a third-party plugin or other software as part of your own product, request an ACR from the vendor to understand this technology’s state of accessibility.

4. Can I qualify for an exception from any of the criteria in a VPAT?

The answer to this VPAT question is typically “no, you cannot quality for an exemption from any criteria.”

Often, organizations request exceptions because they’re unable to resolve an accessibility barrier in a third-party plugin or framework. While this situation is challenging, accessibility issues with third-party software won’t be given an exception, because they can be resolved through work with the vendor.

Other times, organizations want an exception for aspects of their own product’s functionality that are difficult, but not impossible, for developers to make accessible—for example, drag-and-drop functionality. If you’re in a position where your own development team is struggling to implement fixes, consider engaging an experienced third-party for support.

In very rare cases, a product may qualify for an exception from certain criteria. In general, however, if there is a way to address an accessibility issue with a product, an exception will not be granted.

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5. Do I need to complete a VPAT for my website?

The VPAT format is designed specifically to support digital product procurement. If your product is a web application, you may need to complete a VPAT to demonstrate its accessibility to potential buyers. However, you likely won’t need an ACR for a public-facing website that’s primarily used for marketing and not a product you’re trying to sell.

If you want to document the accessibility of your public website, the best way to accomplish this is through an accessibility statement. A web accessibility statement is similar to an ACR in that it outlines the specific accessibility standards that a digital experience conforms with, and how well it meets those standards. But while an ACR communicates a specific product’s level of accessibility conformance to buyers, a web accessibility statement provides information about your website’s accessibility to general users.

Unlock sales opportunities with an expert partner

The VPAT process can feel complex, and you may have more questions than answers, which is why you shouldn’t navigate it on your own. A third-party expert can provide you with the resources and support you need to confidently document your product’s accessibility. Additionally, validation from an objective, reputable third party will boost your ACR’s credibility to buyers.

With more than 25 years of experience, Level Access has worked with hundreds of digital product vendors to produce reliable, accurate ACRs. Our team of experts will answer your VPAT questions and guide you through every step of the process, from identifying target standards to remediating issues surfaced in our evaluation, so you can obtain an ACR that gives you a competitive edge. Contact a member of our team today to get started.