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Reporting Accessibility with VPAT 2: A Guide for Vendors

Written by: Kim Phillips

Presentation Date: November 5, 2019

Accessibility standards and guidelines have changed quite a bit since the original Voluntary Product Accessibility Template (VPAT) was created in 2001. The new VPAT 2 format offers multiple templates, allowing vendors to document conformance with several common standards including the refreshed Section 508, WCAG 2.1, and EN 301 549 for vendors who sell into Europe or Australia.

As the demand for accessible technology grows, so does the demand for product manufacturers and vendors to formally document their product’s or service’s conformance with accessibility standards. A VPAT is often a procurement requirement, but even when it’s not, having a well written VPAT can be a compelling competitive differentiator for vendors who want to show potential buyers that they’re actively evaluating and building accessibility into the products and services they deliver.

Join Chief Accessibility Officer Jonathan Avila discussed:

    • An overview of the Voluntary Product Accessibility Template (VPAT) format
    • Accessibility standards covered and relation to international regulations
    • Creating an accessibility conformance report using the VPAT 2 format
    • How to use the VPAT 2 with different product types
    • Best practices for maintaining and updating your VPAT annually
    • The benefits of having a 3rd party create your VPAT vs. doing it in house

Webinar Questions

Q: What versions are tied to HigherEd? WCAG or 508?

A: It depends on the state and University.  Many have adopted “section 508 like” standards.  To be safe we would recommend following the 508 standards which include WCAG 2.0 A and AA and also include the 12 additional WCAG 2.1  A and AA criteria as we have seen a number of Universities start to request this.  For the exact standards you should check with the organization directly.

 

Q: Is it okay to ignore WCAG AAA (since we don’t test for this level of conformance?)

A: Generally this is acceptable as most every organization does not ask for these.  A few organizations may ask for a few specific AAA requirements but that is rare.

 

Q: My companies product is aimed at universities all around the world. I feel that universities in the UK (where we are based) do not have to meet “EN 301 549”.

A: The way the transposed requirements are written “schools” have exceptions in the EU and so because of this there is a lack of clarity.  For most education institutions in the UK we are hearing WCAG 2.1 being used.

 

Q: Would European universities have to? Are universities in the USA bound by law to provide an accessible website?

A: In the EU  the EU Directive on Accessibility of Public Sector Websites and Mobile apps limits what is required for “schools” to administrative sites.  However, we have seen Educational institutions asking for WCAG conformance.  Education institutions have a requirement to be accessible – the lack of specific standards called out by regulations is a challenge.  In the US most educational institutions are bound to Federal anti-discrimination laws as well but the specific technical requirements aren’t called out by law.  Most states and higher education institutions have adopted Section 508 like procurement laws though.  So at a minimum WCAG 2.0 A and AA is generally indicated – with some requiring WCAG 2.1 or Section 508 conformance depending on the institution and state.

 

Q: You mentioned an awesome point on 508 standards for software. Is it possible/acceptable to do a VPAT using WCAG for Level AA AND only the “software” component of 508?  So kind of like including a partial 508 report in the VPAT?

A: For Section 508 if the software contained product functions like authoring capabilities you would need to fill out Chapter 504.  If you have product support and documentation and it’s not covered by another ACR you would want to cover this as well from a 508 standpoint.

 

Q: To confirm: creating a VPAT for native mobile apps (non-web) requires WCAG A, AA, and Section 508 Chapter 5. Is this all that’s required?

A: From a Section 508 perspective, if you have product support and documentation and it’s not covered by another ACR you would want to cover this as well.

 

Q: We create customized products for each client. Is a VPAT required for each product? Or can our company create a VPAT for the standards of all the products we create?

A: You could create one ACR with the standard template results and capabilities documented.    Depending on the customer and what was configured and who configured it you may need to provide a more specific ACR in certain situations on demand.

 

Q: What happens with things that might not technically be accessible according to these standards, but help make the work environment more accessible to our end-users? For example, we have products on screens that are used in very dark rooms, and products on screens that are used in very bright rooms. In the dark areas we work in, like a mine for example, our workers might be holding a tablet in a very dark environment and the colors used on the interface are ideal for low-light conditions…but may not satisfy the correct/accessible contrast ratio. Does this question make sense?

A: If you provide different options you can meet the requirements by providing options to make those changes.   Many sites have a slider to change the colors to meet contrast requirements.

 

Q: Is it appropriate to for a company to request a roadmap for compliance of any defects or partially supported items, along with the VPAT?

A: Yes, you should ask.

 

Q: When you audit apps, the WCAG does not have official guidelines and I don’t believe that 508 does either, how do you evaluate and report for apps

A: WCAG can and should be applied to mobile apps.  While it’s written for web content the criteria apply.  In addition, you can look to other standards and guidelines such as the BBC Mobile Standards and Guidelines as well as information from Apple and Google on testing and creating accessible apps.

 

Q: You mentioned that additional sections apply for Authoring tools and that authoring tools are anything that the user can use to create content shared with anyone else. I was wondering for our case our product has the ability for users to create content for a dashboard which is visible to all users. The tools used for this creation are provided by a third party but embedding in our product. Is this an example of an authoring tool and should we be evaluating this.

A: If you are talking about just rearranging widgets I would probably not consider that authored content.  But if you can edit text and links and do some level of formatting then I’d likely consider that authored content.   This is an area that there is not a lot of formal guidance on making a determination of what is and isn’t authored content.

About the Speaker

Jonathan AvilaJonathan Avila – Chief Accessibility Officer

With 20 years of experience in digital accessibility and his own personal experience as a person with a visual impairment, Jonathan brings unparalleled industry knowledge and a unique perspective to access solutions for technology with an extensive knowledge of Web Content Accessibility Guidelines (WCAG 2), Section 508, and other accessibility standards and guidelines for the web, software, mobile technology, and hardware. He actively works with major industry development platform and assistive technology vendors, regulatory agencies and public-sector organizations to consistently update understanding of the proper level of accessibility for clients. Sought out as a thought leader in the industry, Jonathan has developed training for Federal agencies, presents webinars throughout the year on a variety of digital accessibility topics, speaks at conferences and other industry events, and is a regular contributor to the Level Access blog.