How to Create an ACR with a VPAT

A Voluntary Product Accessibility Template (VPAT) is a document that provides a detailed analysis of how a product or service conforms to established accessibility standards. This document is essential for vendors, especially those in the technology sector, seeking to demonstrate their compliance with accessibility standards such as WCAG 2.1, Section 508, and the European EN 301 549. It’s a critical part of selling to government agencies or other entities requiring accessibility documentation.

What is an ACR, and How is it Different from a VPAT?

A VPAT is a blank template used to assess and document a product’s accessibility features and gaps. It is a guideline that helps structure an evaluation of accessibility compliance according to standards like WCAG, Section 508, and EN 301 549.

An ACR is a finished, finalized document that summarizes the accessibility evaluation based on the VPAT template. In other words, while the VPAT is a framework for conducting the assessment, the ACR is the end result, containing the product’s actual accessibility compliance data.

Key Differences Between VPAT and ACR:

• VPAT: A guideline and template for assessing accessibility. It's a working document during the evaluation phase.
• ACR: A formal report that results from filling out a VPAT template with findings. It is a static, published document that companies provide to stakeholders or customers.
• Purpose: VPAT is for assessment; ACR is for reporting.
• Audience: VPAT may be an internal document during development; ACR is intended for external stakeholders, such as potential clients, procurement officers, or government agencies.

The term VPAT is often used interchangeably to refer to both the template and the final report, leading to some confusion. This dual use arises because the VPAT (Voluntary Product Accessibility Template) itself serves as the structure for conducting the accessibility assessment, but many organizations also label the completed, filled-out version—the actual Accessibility Conformance Report (ACR)—as a "VPAT."

How to Create an Accessibility Conformance Report (ACR)

Creating an Accessibility Conformance Report (ACR) involves several steps, each requiring technical accuracy and a clear understanding of accessibility standards.

1. Conduct an Accessibility Assessment Using a VPAT: Choose the appropriate VPAT edition based on the target market. Conduct a detailed accessibility evaluation using a combination of automated testing tools, manual assessments, and assistive technologies. Document each criterion with compliance levels like "Supports," "Partially Supports," or "Does Not Support."
2. Compile the Findings: Transfer the detailed assessment data into the ACR. Include product information, such as name and version. Clearly define the assessment scope. Summarize overall compliance with accessibility standards and list detailed findings for each criterion. Identify any non-compliant areas, along with workarounds or plans for remediation.
3. Review and Validate: Perform an internal review to ensure accuracy and clarity. Validation by external consultants is optional but recommended for complex products. Simplify technical language where possible for a broader audience, while maintaining clarity on compliance statuses.
4. Finalize and Publish: Format the ACR for readability, ensuring clear headings and a logical structure. Make the document accessible, following accessibility guidelines. Publish the ACR on your website or make it available upon request, and keep it updated as the product evolves.

What Types of Products or Services Require a VPAT?

Any ICT product or service, including software, web applications, hardware, e-learning tools, mobile apps, and digital content, may require a VPAT. The scope will vary depending on your product and the target market’s accessibility requirements.

What are the Differences Between the Various VPAT Editions?

The VPAT is available in several editions:

• WCAG Edition: Focuses on web content and software using the WCAG 2.0 or 2.1 guidelines.
• Section 508 Edition: Relevant for U.S. federal accessibility standards, including electronic and information technology.
• EN 301 549 Edition: Covers European accessibility requirements.
• International Edition: Combines aspects of all editions for a global approach.

Choosing the right edition is crucial depending on your market and compliance goals.

How Often Should a VPAT Be Updated or Reviewed?

A VPAT should be reviewed:

• Annually: To align with evolving accessibility standards.
• After a Major Update: Any significant product changes require an update to ensure compliance is accurately reflected.
• Upon Customer Request: In some cases, clients may require a specific, up-to-date VPAT for a procurement process.

Regular updates maintain transparency and ensure your compliance claims remain current.\

Can I Create a VPAT for Specific Features, Components, or Modules?

Yes, VPATs can be scoped narrowly to specific product versions, features, components, or modules. A partial VPAT is often necessary if you have a complex product with distinct functionalities that vary in their level of accessibility compliance. Be clear in the scope section about what is covered to prevent any misunderstandings.

How Long Does It Typically Take to Complete a VPAT?

The timeline for a VPAT can vary based on:

• Product Complexity: Simple websites may take a few days, while complex enterprise software could take weeks.
• Available Documentation: If accessibility testing data is already available, the process will be faster.
• Resource Availability: Dedicated accessibility experts can speed up the process compared to teams without specialized skills.

What Information Do I Need to Provide to Create a VPAT?

Accurate VPAT creation relies on detailed data:

• Product Specifications: Include platform versions, browser support, and system requirements.
• Testing Methodology: Indicate the tools and methods used, such as automated testing tools or manual checks.
• Known Accessibility Issues: Describe any non-compliant areas and provide alternatives or planned fixes.

Clear documentation is very important for accurate reporting.

What Are the Typical Steps Involved in Conducting a VPAT Assessment?

1. Identify Applicable Standards: Choose the relevant VPAT edition(s) based on the target audience and region.
2. Accessibility Testing: Conduct thorough testing using a mix of automated tools, manual checks, and assistive technologies. Includia’s accessibility platform, for instance, is a tool that can assist in automated and manual audits.
3. Create a Draft VPAT: Document findings, detailing compliance levels for each criterion (e.g., “Supports,” “Partially Supports,” “Does Not Support”).
4. Review and Revise: Validate the draft for accuracy, address unclear sections, and revise non-compliant items.
5. Finalize and Publish: Approve the VPAT for public use and make it available to customers.

Can My Internal Team Complete a VPAT, or Do I Need to Hire an External Consultant?

If your team includes certified accessibility professionals with expertise in WCAG, Section 508, or EN 301 549, they can perform VPAT assessments. However, external consultants are recommended for complex products or if you need a third-party verification for credibility.

What Are the Risks if My VPAT Isn’t Accurate or Comprehensive?

An inaccurate VPAT can lead to:

• Legal Risks: Incomplete or false claims may trigger lawsuits, especially if targeting government clients.
• Loss of Trust: Potential customers may lose confidence if accessibility issues are later discovered.
• Missed Sales Opportunities: Some procurements require an accurate VPAT for eligibility, and non-compliance may result in lost bids.

What Happens if a Product Doesn’t Fully Meet Accessibility Standards?

It’s common for products to have some accessibility gaps. In such cases:

• Be Transparent: Clearly indicate non-compliance and reasons in the VPAT.
• Provide Workarounds: Suggest alternative ways to access information where gaps exist.
• Commit to Remediation: Indicate future updates or a timeline for addressing known issues.

What Kind of Evidence or Documentation Should I Maintain to Back Up the Claims in My VPAT?

To substantiate your VPAT:

• Test Reports: Detailed accessibility testing reports.
• User Feedback: Reports from real users, especially those with disabilities.
• Remediation Logs: Records of accessibility fixes and updates.
• Audit Logs: Documentation of tools and methods used during testing.

Keeping comprehensive documentation will help in case of disputes or legal inquiries.

How Can I Make My VPAT More Useful or Transparent for Potential Clients or Government Agencies?

• Use Plain Language: Avoid jargon to make the VPAT understandable.
• Include Accessibility Features: Highlight what your product does well.
• Provide Workarounds: Offer alternative methods for any non-compliant areas.

How Should I Handle ACR Requests from Clients If My Product Is Still Under Development?

For ongoing development:

• Create a Preliminary VPAT/ACR: Document compliance for existing features.
• Specify Development Phases: Indicate what is compliant now and what will be addressed later.
• Regularly Update: As new features are developed, update the VPAT and ACR accordingly.

Conclusion

Creating a VPAT is not merely a documentation task but an ongoing commitment to accessibility. A thorough VPAT requires careful planning, honest reporting, and continuous updates to reflect your product’s compliance journey. Creating a well-documented ACR based on a thorough VPAT assessment can enhance your product's credibility, help you meet compliance needs, and establish trust with potential clients who prioritize accessibility.