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Do I Need a VPAT for My Business?

May 15, 2024

The Voluntary Product Accessibility Template (VPAT) is a standardized method for reporting how products and/or services conform with Section 508 of the Rehabilitation Act of 1973

If you’re marketing products or services to the US federal government, there’s a good chance that you need a VPAT — and even if you don’t currently sell to government purchasers, a VPAT may help you in the future.

In this article, we’ll explain how government offices procure information and communication technology (ICT), the layout of a typical VPAT, and whether you can write a VPAT on your own.

To discuss Section 508 compliance with an accessibility expert, send us a message. 

VPAT: An Essential Document for Government Purchasing

The VPAT, available through procurement offices, is essentially just a table that vendors use to outline their level of compliance with Section 508. Vendors may also provide comments to explain compliance issues or to detail the specific accessibility features of their product/service.

With an accurate VPAT, buyers can:

  • Compare ICT to select the most accessible option.
  • Ensure that products meet the organization’s legal requirements.
  • Plan for any necessary changes and upgrades that could bring a non-compliant product in line with Section 508.

While the VPAT isn’t a marketing document, it can be extraordinarily useful when selling to government agencies and their contractors — after all, those organizations must comply with Section 508. If a vendor provides timely, accurate information about their level of compliance, that’s quite beneficial.

Related: What Are Exceptions to Section 508 Accessibility Requirements?

Section 508 Requirements for Software and Other Digital Products

In January 2017, the US Access Board updated the accessibility requirements of Section 508 of the Rehabilitation Act of 1973. The law’s standards are now aligned with the Level A/AA standards of the Web Content Accessibility Guidelines (WCAG) version 2.0.

WCAG is a technical document that consists of pass-or-fail statements called success criteria. The guidelines cover a wide range of issues like low-contrast text, keyboard accessibility, video captions and transcripts,  missing text alternatives, and form labels

Criteria are organized into three levels of conformance: Level A (the least strict and most essential requirements), Level AA, and Level AAA (the most strict requirements). Learn about the differences between WCAG conformance levels.

Ideally, your VPAT will demonstrate your product’s full conformance with all Level A and Level AA criteria. That level of conformance indicates that your product is reasonably accessible for users with disabilities. 

Related: The 5 Most Common Website Accessibility Issues (And How To Fix Them)

Section 508 and Title II of the ADA

WCAG is an international framework for digital accessibility. It’s also the basis for many other non-discrimination laws — including Title II of the Americans with Disabilities Act (ADA), which also applies to government agencies and their contractors. 

In 2024, the Justice Department finalized a new rule establishing WCAG 2.1 Level AA as the standards for Title II compliance. WCAG 2.1 includes all of the requirements from WCAG 2.0, but adds 17 additional requirements that address mobile accessibility, vision disabilities, and cognitive disabilities.While VPAT templates focus on Section 508 — and WCAG 2.0, by extension — we recommend bringing your product into conformance with the Level AA standards of the latest version of WCAG (currently, WCAG 2.2). Full conformance ensures the best possible experience for users and the highest level of compliance with non-discrimination laws.

Related: Which WCAG Standards Do I Need to Follow?

Section 508 Compliance and VPAT Assessment

Anyone can write a VPAT. You don’t need special training or professional credentials — but to write an accurate report, you should have some experience with digital accessibility.

A standard VPAT will follow a basic structure:

  • The first pages of the report introduce the product, provide contact information, and list evaluation methods used in your accessibility audit.
  • Each WCAG conformance criteria is listed, along with the ICT product’s conformance level.
  • A “remarks" field explains any relevant exceptions. For example, if your entire website is conformant with WCAG’s color contrast requirements except for one graphic, you’d identify that graphic in the remarks field and explain why it cannot conform.

If you don’t have a working knowledge of WCAG, you may make mistakes when evaluating your level of conformance, and those mistakes could have significant repercussions for the purchaser. 

For that reason, we recommend working with an accessibility partner when building a VPAT. Ideally, your partner will get involved early in the development process; prioritizing inclusive design will help reduce the cost of remediations (and establish a higher level of accessibility).

To learn more about the basics of accessible design, download our free eBook: Developing the Accessibility Mindset. To discuss your product or your approach to your VPAT, send us a message and connect with an accessibility expert.

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