ADA Compliance Professionals
    VPAT ACR

    VPAT ACR for Section 508 and WCAG- What you must know

    David LoPrestiBy David LoPresti
    July 14, 2025
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    A Voluntary Product Accessibility Template (VPAT®) is a standardized template used to document a product's conformance with accessibility standards.

    Once completed, this document becomes an Accessibility Conformance Report (ACR), a key resource for public procurement and compliance evaluation.

    According to the Information Technology Industry Council (2023), the VPAT is designed to support accessibility compliance for standards like Section 508, WCAG, and EN 301 549.

    What is a VPAT and Why does it matter?

    According to the U.S. General Services Administration (2023), agencies must evaluate digital tools based on accessibility during procurement.

    A properly completed ACR helps buyers understand how accessible a product is.

    A correctly filled VPAT ensures that federal agencies meet their obligations under Section 508 of the Rehabilitation Act.

    Filling out a VPAT the right way can make or break your chances of working with federal agencies.

    If you skip it or fill it inaccurately, your product may be disqualified from contracts.

    However, engaging ADACP for an expert-led audit and a professionally written ACR offers numerous benefits, including clarity, compliance, and enhanced buyer confidence.

    An expert ACR accelerates procurement approvals and demonstrates a proactive commitment to digital accessibility.

    The VPAT has four editions:

    • VPAT 2.5 508: Required for US Section 508.
    • WCAG Edition: Used when only WCAG conformance is applicable.
    • EU Edition: Aligns with EN 301 549 for European accessibility.
    • INT Edition: Covers all three standards for international use.

    Q: How do I know which VPAT edition to use?

    A: Use 508 Edition for U.S. government contracts, EU for European clients, and WCAG Edition for web-only products.

    What are Section 508, WCAG, and EN 301 549?

    Section 508 is a U.S. federal law requiring that information and communication technology (ICT) developed, procured, maintained, or used by the federal government is accessible to people with disabilities (U.S. Access Board, 2017).

    Web Content Accessibility Guidelines (WCAG), developed by the W3C, provide global standards for making web content more accessible to people with disabilities. Section 508 now aligns with WCAG 2.0 Level AA (W3C, 2018).

    EN 301 549 is the European standard for accessibility requirements suitable for public procurement of ICT products and services in Europe. This standard also maps closely to WCAG and is recognized under the European Union’s accessibility directive (European Commission, 2021).

    Why a VPAT ACR is Crucial for Government and Enterprise Buyers

    Agencies need documentation to verify accessibility, and ACRs provide that transparency.

    According to the GSA Accessibility Requirements Tool (2023), ACRs are one of the first documents reviewed during procurement evaluations.

    An ACR typically includes:

    • Product name and version
    • Evaluation methods used
    • A table detailing each requirement and level of support (e.g., "Supports," "Partially Supports")
    • Explanations and notes for each criterion

    Q: Why do agencies prioritize ACRs during procurement?

    A: An ACR offers an upfront view of your product's accessibility, saving time, reducing risk, and aiding procurement officers in quickly assessing compliance with legal accessibility standards. Without it, your bid might not be considered.

    6 steps to complete a VPAT Accessibility Conformance Report

    The U.S. General Services Administration (2023) outlines the following steps:

    Image 1: Step wise guide to completing a VPAT Accessibility Conformance Report
    Source:     https://www.adacompliancepros.com/
    1. Select the right VPAT edition based on your audience (e.g., 508 for U.S. federal buyers).
    2. Test your product using a combination of manual testing, automated tools, and assistive technology.
    3. Fill in the conformance table for each accessibility requirement.
    4. Provide remarks for each item where conformance is partial or not met.
    5. Remove instructional text before finalizing the report.
    6. Keep the ACR updated with each new version of the product to reflect any changes.

    Q: What is the difference between a VPAT and an ACR?

    A: A VPAT is the blank template. Once filled out and finalized, it becomes an ACR.

    Section 508 was updated by the U.S. Access Board in 2017 to align with WCAG 2.0 (U.S. Access Board, 2017).

    Additionally, the Office of Management and Budget issued Memorandum M-24-08 in 2023 to promote digital accessibility at federal agencies (Office of Management and Budget, 2023).

    Federal Acquisition Regulation (FAR) clauses also require considering accessibility in all ICT acquisitions, making ACRs not only a best practice but a legal necessity (GSA, 2023).

    Best Practices for ACR Completion

    To ensure your Accessibility Conformance Report stands out and meets federal expectations, follow these tips to ensure accuracy, transparency, and compliance throughout the documentation process.

    These practices are commonly reviewed by federal buyers and accessibility evaluators when considering vendors.

    Best Practices for ACR Completion

    • Be transparent: Partial support is acceptable if properly documented.
    • Use objective testing methods: Implement accepted measures for manual and automated testing.
    • Reference applicable standards clearly: Make sure users know what you conform to—Section 508, WCAG 2.1, or EN 301 549.
    • Keep your ACR updated: Version changes, new features, or updated standards require timely updates.

    Q: What happens if I don’t follow these best practices for ACR completion?

    A: Incomplete ACRs may delay procurement, raise red flags during compliance checks, or cause disqualification. Following best practices shows that you are prepared for federal scrutiny.

    Common Mistakes to Avoid

    Many organizations unintentionally reduce the credibility of their Accessibility Conformance Report by repeating some slipups.

    Table 1 outlines common mistakes and their implications:

    Mistake Why It is a Problem
    Listing “Supports” without explanation Fails to demonstrate actual testing or understanding of criteria.
    Looks like guesswork.
    Using outdated VPAT versions Shows you're not following current guidelines.
    Can lead to rejection by federal buyers.
    Failing to test all user journeys Leaves major accessibility gaps undiscovered.
    May lead to non-compliance post-purchase.
    Copy-pasting from other products’ ACRs Inaccurate data leads to misleading claims.
    Can harm your reputation & cause legal risk.

    Table1: Top ACR Mistakes and Why They Hurt Your Accessibility Compliance

    Q: Do I need to submit an ACR for each version of my product?

    A: Yes. Any changes to features or accessibility impacts should trigger a new ACR.

    Sample Public ACR

    Agencies like Login.gov publish public-facing ACRs to maintain transparency.

    Their report includes a completed VPAT 2.5 508 Edition with detailed conformance data.

    Image2: Snapshot of Page 3 of VPAT® Version 2.5Rev
    Source: https://www.login.gov/docs/2025-02-26_VPAT2.5Rev508-Identity-Authentication.pdf

    If you want to publish your own ACR on your website, ADACP can help. We offer end-to-end accessibility audits, manual testing, and remediation support.

    Once your product meets compliance standards, we will provide a professionally written, up-to-date ACR you can confidently publish.

    Conclusion

    A properly written VPAT ACR not only demonstrates compliance but also builds trust with federal buyers and global partners.

    By following official guidance, using accurate citations, and avoiding third-party competitor references, your report becomes a reliable compliance document that meets regulatory expectations.

    References