In my daily work in digital accessibility, I have seen a concerning trend with the Voluntary Product Accessibility Template (VPAT) being viewed as a straightforward compliance tool.
However, this misconception can be costly for software vendors and their clients procuring their software.
When treated merely as a checkbox to satisfy procurement requirements, the VPAT fails to serve its intended purpose, documenting how accessible your product really is.
More importantly, it should guide you in making meaningful accessibility improvements on a regular basis. The VPAT’s real output is an actionable Accessibility Conformance Report (ACR), and its effectiveness depends entirely on how thoroughly your product has been assessed.
Some Myths Regarding VPATs
Let me quickly dispel a few myths and a strong concern I have seen in our industry over the past few months with increased procurement requirements based on U.S. and global regulations for software companies to set up the reasoning for writing this article.
- You cannot obtain a VPAT in 2-3 business days that you should feel comfortable providing in RFP or contract submissions, and if a business offers this, it should be a major red flag.
- A business providing you with a completed VPAT without a robust ACR and Audit Report that allows your team to improve your product and show a more accessible product on future VPAT ACRs is wasting your team’s resources.
This article is meant to guide you through why a VPAT is far more than a checkbox for your sales team and how to ensure your ACR is a living document that drives accessibility improvements for your product team, mitigates legal risks, and serves as a competitive differentiator in the marketplace.
Your VPAT Is Not a Box-Check
For many businesses, the temptation to treat a VPAT as a quick checklist is hard to resist.
After all, many procurement processes and contracts have historically required the submission of a “Completed VPAT” to meet accessibility requirements.
However, this can be a superficial approach that ultimately undermines the VPAT’s core intent: to provide transparency and accuracy about the accessibility of a product or service.
By rushing through the process or using boilerplate responses, companies risk producing an inaccurate ACR that satisfies immediate procurement demands but does nothing to enhance the product’s accessibility genuinely.
The real legal risk, however, lies in the fact that such an approach can expose your company to legal challenges if customers or regulators find that your product does not meet the accessibility expectations you claimed.
A properly executed VPAT, on the other hand, provides an authentic foundation for improving the user experience, particularly for individuals with disabilities, and creates a roadmap for ongoing enhancements.
The Critical Role of a Thorough Vendor Assessment
The quality of your VPAT and ACR output depends largely on the vendor you select to conduct your accessibility audit.
Let’s also start with the simple fact that a VPAT ACR is not a static document; it must reflect your product’s actual accessibility status in real-world usage.
This means it cannot be completed accurately without a thorough and rigorous assessment of how your product will be used by your clients and their end-users (consumers or internal employees).
I also feel it is important to note that a VPAT itself is a blank template created by the Information Technology Industry Council (ITIC), designed to provide a detailed analysis of a product’s accessibility conformance to the chosen WCAG Standard (2.0, 2.1, or 2.2). Without substantial testing from trained accessibility engineers, this template is just a shell.
A vendor must possess not only technical knowledge of WCAG 2.2 success criteria but also practical experience in how users, particularly those with disabilities, interact with and leverage your product in order to complete the VPAT and provide your team with an ACR output.
Full stop: vendors that rely solely on automated tools or neglect live-user testing will provide an incomplete ACR.
These “audits” won’t capture the full scope of accessibility issues and leave you with an unreliable picture of your product’s real-world usability.
The key to a successful VPAT process is selecting a vendor who combines automated, manual, and live-user testing by people with disabilities to provide a comprehensive and actionable report.
Allyant, for example, specializes in paired auditing with sighted and blind accessibility engineers, ensuring the full spectrum of accessibility issues are identified.
The VPAT Template: A Blank Form vs. An Actionable Roadmap
Understanding the VPAT structure and overarching goals of this template is crucial to crafting a meaningful ACR. While the VPAT itself is merely a template, an Accessibility Conformance Report (ACR) is where the real value lies for your organization.
The most critical section in the VPAT template is the “Remarks and Explanations” field.
Here, your vendor must provide clear, detailed explanations for each conformance level, such as “Supports,” “Partially Supports,” “Does Not Support,” or “Not Applicable.”
For a robust ACR, this section should contain:
- Descriptions of Test Cases: These are used to evaluate each WCAG success criterion.
- Explanations of Partial Conformance: outlines which aspects of the criteria are met and which are not so you can have an informed conversation with procuring entities.
- Remediation Guidance: recommends steps for improving areas that do not currently meet accessibility standards. Otherwise, your product will simply remain inaccessible, which is not helping anyone.
This depth of analysis not only helps make your product accessible but also instills confidence in your customers, regulators, and partners. A generic or superficial VPAT offers no actionable insights and may fail to address critical accessibility gaps for both your clients and your product development team, which we will break down in the next section.
Generic VPATs Do Not Lead to Accessibility Improvements
A common pitfall is obtaining a generic VPAT and treating it as a one-time effort—or a yearly exercise that you will rinse and repeat next year and not worry about accessibility in between.
Many companies believe this will suffice to meet accessibility requirements.
However, accessibility is not static; it is an ongoing process. An ACR must evolve as your product evolves—whether through feature updates, design changes, or compliance with new accessibility standards such as WCAG 2.2.
For a VPAT to be truly actionable, the ACR output must be treated as a living document. Like any strong accessibility roadmap, your software product must be revisited regularly to ensure continuous improvement.
When clients or partners conduct accessibility reviews during procurement or renewal processes, they should see tangible improvements based on the ACR’s previous recommendations and your current state of compliance.
At Allyant, we support our clients with up-to-date conformance reports and progress on remediation of identified issues through ongoing QA testing exported directly from our Allyant HUB platform.
This ensures our software clients can not only provide highly accurate VPAT ACRs reflective of the current state of their product but also go above and beyond the VPAT checkbox and show their clients real and sustained accessibility progress to exceed contract requirements around accessibility conformance.
Failing to update your ACR regularly means missing out on opportunities to enhance both accessibility and user experience. More importantly, it shows that your commitment to accessibility is ongoing, not a one-time exercise.
The Audit Behind the ACR: Why It’s the Most Critical Step
A VPAT ACR is only as good as the audit conducted to support it. Without a rigorous accessibility audit, the ACR is just another document with no roadmap for improving the product. A thorough audit involves:
- Manual Testing: Done by accessibility experts who fully understand the nuances of the WCAG success criteria. Our team performs all audits to WCAG 2.2 to support global accessibility regulations for our clients.
- Live-user Testing: People with disabilities ensure that the product is not only accessible with WCAG but usable in real-world conditions. This is also documented in the testing methodology for all ACRs we deliver to our clients.
- Automated Testing: A supplemental tool, but it is not the primary means of evaluation.
The most valuable ACRs not only provide a snapshot of your product’s current accessibility status but also offer your product and development team a detailed action plan for remediation.
This makes the ACR an indispensable tool for both your development team, which can improve accessibility barriers within your product, and business decision-makers, who will have the peace of mind that your team is committed to ongoing accessibility conformance.
Live-User Testing: The Human Element in Accessibility Audits
Live-user testing is one of the most critical components of a robust accessibility audit. Automated testing tools are helpful in identifying a certain percentage of WCAG violations, but they can only go so far in driving usability, specifically in complex software applications. True accessibility requires human interaction from assistive technology users with disabilities.
A thorough ACR will include insights from live-user testing, specifying:
- Who participated in the testing (e.g., users with vision, mobility, hearing, or cognitive disabilities).
- What real-world scenarios were tested to simulate actual use.
- What insights were gained, and how they informed the audit’s findings.
Incorporating live-user feedback ensures that your product is accessible not just in theory but in practice. Think about education software that will be deployed in K-12 schools.
If a student is asked to learn course material through this application but leverages a screen reader or has a physical disability that requires them to access through keyboard navigation — failing to replicate these scenarios while outlining WCAG conformance on your VPAT ACR can prevent a school from providing accessible accommodations to a student if the software vendor does not accurately represent the current access barriers in their software.
Treating Your ACR as a Living Document
Accessibility is an ongoing process, whether focusing on a simple website, mobile application, or complex software application, and as your product evolves, so must your ACR. Updating your ACR regularly through ongoing accessibility testing ensures that:
- New features or updates are consistently evaluated for accessibility, and your ACR reflects the current state of your product.
- Your product meets or exceeds the latest WCAG guidelines or regulatory requirements as global regulations evolve.
- You can demonstrate clear, measurable progress to clients, customers, and regulators, arguably the most important aspect of procurement and meeting contract requirements regarding accessibility.
There is currently no legal requirement for how often to update your VPAT ACR, but there are industry best practices we can outline.
Generally, I inform any software vendor that their first VPAT ACR will be their worst—following a thorough accessibility audit for the first time. This is natural, and this is also OK!
A strong ACR and audit report are a health assessment on how to roadmap improving your product’s accessibility.
As your team works through initial accessibility remediation, we closely track a ‘virtual ACR’ in our Allyant HUB Platform to help our clients make informed decisions about updating their VPAT ACR to reflect your team’s hard work and accessibility improvement.
In most cases, this can occur anywhere between 3 and 9 months from issuing the initial VPAT ACR, but these updates also only take a few hours if you are working with a transparent vendor. So, we can easily update your VPAT ACR one time or ten times at a very minimal cost as your product improves!
Once your team has an established accessibility roadmap and strong ongoing testing practices in place, we strongly encourage our software clients to update their VPAT ACR every 12 months.
This ensures that the dates within the completed product remain relevant and as outlined above, the output matches the current state and version of the product they are selling in the marketplace.
A Solid VPAT ACR: Your Secret Weapon for Sales and Competitive Differentiation!
A well-executed VPAT ACR can be far more than just a compliance tool—it can serve as a powerful sales asset and a key differentiator in the marketplace.
As accessibility becomes a priority for both public and enterprise clients, a robust ACR demonstrates your commitment to delivering inclusive digital experiences and allows you to proactively represent this commitment, unlike competitors, whether it is a strict RFP requirement or not.
Working with a reputable vendor like Allyant not only provides you with a reliable ACR but also positions your business as a leader in accessibility.
Allyant goes beyond just producing a document; our team acts as an extension of your sales and marketing team, providing ongoing support in responding to RFPs and RFIs, answering accessibility-related questions, and even joining client calls to explain your product’s conformance, and progress and ongoing accessibility testing practices to ensure your clients are confident in the current and future state of your product.
In this way, a solid ACR and working with the Allyant team to obtain these from an industry-leading third party do more than satisfy procurement requirements—they become a competitive advantage, helping you secure contracts and maintain long-term relationships with clients who prioritize accessibility or require it based on their vertical and legal requirements.
Software vendors who rely on “box-checking” VPATs cannot offer the same level of assurance, leaving you with an inferior product and at risk of losing business to competitors who take accessibility and have a vendor in their corner that sets them apart in honest and actionable responses upon request.
Beware of the ‘Quick VPAT’
Obtaining a comprehensive, accurate VPAT ACR is time-consuming, and any vendor that promises to deliver one in 1-2 weeks is either not honest in their testing process or will provide you with a lackluster VPAT ACR output. A legitimate audit process to complete a thorough VPAT template and provide a detailed ACR output takes time to complete because it involves multiple steps:
- Manual and automated testing to evaluate the product’s compliance with WCAG 2.2 guidelines.
- A live-user audit to ensure that real-world users can interact with the product.
- The findings are compiled into a detailed ACR, complete with a prioritization of issues based on their usability impact and specific recommendations for remediation.
When selecting a vendor, be cautious of those who claim they can deliver a VPAT ACR in an unrealistic timeframe. As I outlined in a recent article, an in-depth accessibility audit will take 4+ weeks, perhaps more for complex products.
If this thorough assessment of all core product features has not been conducted, no accessibility company can provide your team with an accurate VPAT ACR that includes your software’s level of conformance to every WCAG success criteria and a detailed explanation when a success criterion Partially Supports, Does Not Support or is Not Applicable.
If your team or vendor cannot explain in detail the output and next steps relative to the VPAT ACR they are providing, you should not feel confident providing this to your clients in their procurement process for the legal risks outlined above.
By jumping for the cheapest vendor or trying to rush to obtain a box-checking “quick VPAT”, your team may instead end up with an incomplete, inaccurate, or not actionable document—ultimately costing you more time and money in the long run.
The Legal Risks of Inaccurate VPATs
An inaccurate or incomplete VPAT can expose your company to significant legal risks. Government agencies and large enterprises increasingly rely on VPAT ACRs when making procurement decisions. If your ACR misrepresents your product’s accessibility, you could face some obvious contract consequences, including:
- RFP Elimination if the client procuring your software runs a lightweight assessment on the product to validate the accuracy of your VPAT, such as through our ProcureEnsure service. Many federal, state, education, and even private sector businesses are building out accessible procurement processes and ensuring products are tested prior to acquisition. If your VPAT ACR does not reflect the product’s actual state, your team will likely be eliminated from consideration quickly.
- Contract Cancellations if your product fails to meet the expected level of accessibility after being deployed by your client. For example, say a public entity procures your product based on a VPAT ACR that does not accurately reflect the current state of accessibility and then immediately receives a consumer or employee complaint that the product is inaccessible.
As regulations such as the DOJ ADA Title II recommend accessible procurement, the updated HHS accessibility requirements, and international laws like the European Accessibility Act (EAA) continue to drive demand for product accessibility, the importance of an accurate and actionable VPAT has never been greater.
Your ACR should protect your business from legal action and ensure that your product is accessible to the people who need it most.
Why an Actionable VPAT ACR is Essential for Long-Term Success
To recap, if your team is assessing accessibility for the first time because a client or prospect just asked you for your product’s VPAT, it is critical to consider this is far more than just a procurement requirement.
Your team should take pride in your VPAT ACR, which is a tool for achieving true digital accessibility.
A meaningful ACR helps you understand your product’s current state of accessibility, guides future improvements, and minimizes legal risks. Most importantly, it positions you as a leader who provides inclusive experiences for all users.
I would also close with the honest fact that no software product in existence is 100% accessible.
Therefore, no client or prospect should require you to provide a VPAT ACR that shows you “support in full every WCAG success criterion.” Most mature accessibility organizations would actually view this as a red flag and likely assume you obtained a box-checking VPAT!
In fact, if a client requires you to show a 100% perfect VPAT ACR, I would be happy to chat with the client and support your team; reach out below!
To ensure that your VPAT is actionable and not just a checklist, I strongly encourage your team to choose a reputable vendor with vast procurement support experience, such as our team here at Allyant.
Our extensive experience provides a thorough, detailed audit conducted by experts specializing in accessibility and live-user testing. Our reports are comprehensive and actionable, helping you not only meet current standards but also drive long-term improvements in accessibility.
If you’re ready to take your VPAT beyond an accessibility checkbox and start leveraging it as a competitive tool, reach out below. Our team of experts will work with you to provide an in-depth, actionable ACR that satisfies procurement requirements and enhances your product’s accessibility and usability.
Reach out now to schedule a consultation or audit, and let us help you make accessibility a key differentiator for your business!
