Audits, VPATs, and ACRs
Accessibility audits can be useful and sometimes required. Here's what you need to know.
Introduction
You may have heard the terms Voluntary Product Accessibility Template® (VPAT) and Accessibility Conformance Report (ACR) used in the context of website accessibility. You may have been told you need to have an ACR as part of your organization’s compliance requirement or to do business with another organization.
This guide explains these artifacts, why you might need them, and how to produce them.
What’s a VPAT, what’s an ACR?
These terms are sometimes used interchangeably but, while closely related, are different. Essentially, an ACR is the result of completing a VPAT.
VPAT
A VPAT, or Voluntary Product Accessibility Template®, is a template that, when filled out, can be used to document how accessible your product or service is according to various accessibility criteria. By completing a VPAT, you create an ACR.
ACR
An ACR, or Accessibility Conformance Report, is an itemized report that documents how a product or service meets a set of accessibility criteria.
The VPAT has become the de facto standard for creating ACRs, particularly as part of a government or enterprise procurement process. Still, there could be rare cases where an ACR is produced using another template. For this guide, we assume you will use a VPAT.
Is an ACR required?
The “V” in VPAT stands for voluntary but in the US some public bodies, government agencies, and other institutions that receive US federal funding are required to have an ACR on record.
Typically, for private businesses and organizations, an ACR is indeed voluntary. However, you may be asked to produce an ACR as part of a procurement process, meaning that if you want to do business with such an organization, you must create an ACR.
Even when an ACR is not required, having one available is a good way to show your commitment to accessibility and legal compliance, which could improve your chances of securing potential contracts.
How to get started
Unless you are asked to use a different template, we recommend that you start with one of the official VPAT templates provided by the Information Technology Industry Council (ITI). You can download these templates (in DOCX format, MS Word compatible) for free from their website.
Let’s walk through the steps of how to select and work with a VPAT:
Choose a VPAT edition
The latest version of VPAT is 2.5, released November 01, 2023. Several editions of the template are available, each based on a different set of accessibility criteria. The one you choose typically depends on the client to whom you provide your ACR.
- VPAT 508: Based on Section 508 of the US Rehabilitation Act. This is a suitable choice if you’re providing a product or service to the US federal government or are subject to regulations based on Section 508.
- VPAT EU: This is based on EN 301 549, European criteria for digital accessibility, which includes WCAG 2.1. Use it if you’re primarily targeting the European Union market or are subject to EU accessibility regulations.
- VPAT WCAG: Based on WCAG 2.0 (ISO/IEC 40500 equivalent), WCAG2.1, and WCAG 2.2. This is a good way to demonstrate general compliance with WCAG guidelines, regardless of your target market.
- VPAT INT: This is an international edition incorporating all three criteria above. It is a good choice if you’re targeting a global market and want a comprehensive assessment of your product’s accessibility.
If in doubt, the WCAG-based edition is a good all-around choice. The following sections assume you are completing the WCAG edition, but you should follow the instructions for whichever VPAT you select.
Choose a version of WCAG
The WCAG edition of the VPAT will ask you to identify which version of WCAG you are evaluating your website against. You may be given the target version as part of the requirements or choose one yourself.
Version 2.2 is a safe and future-proof target since it is the most recent and extends version 2.0 and 2.1.
The different versions are briefly explained below:
- WCAG 2.0: Published in 2008, this version comprises 61 success criteria covering the basic web accessibility principles.
- WCAG 2.1: Published in 2018, this version builds on WCAG 2.0, adding 17 new success criteria (for a total of 78). For example, this version introduced criteria related to mobile accessibility and cognitive disabilities.
- WCAG 2.2: Published in 2023, this is the latest version. It builds on version 2.1 by adding nine more success criteria (for a total of 87). It improves some accessibility criteria related to users with cognitive disabilities and on mobile devices, and removes one defunct criterion (SC 4.1.1 Parsing).
Learn more about WCAG basics in our What is WCAG? Guide.
Choose a conformance level
The WCAG edition of the VPAT will also ask you to identify which conformance level you are evaluating your website against. You may be given the conformance level as part of the requirements or choose one yourself.
There are three different WCAG levels to choose from:
- A: Level A is the minimum level of WCAG conformance.
- AA: Level AA is an enhanced level of WCAG conformance; it includes all of Level A criteria plus many additional or stricter criteria. Level AA is an appropriate and reasonable target for most websites.
- AAA: Level AAA is the highest conformance level; it includes all of Level AA plus many additional or stricter criteria. This level may not be practical or realistic for every website to meet.
Even if you use level A or AA as your baseline goal, you may still aim to implement a higher level in some circumstances. For example, you may meet level AA everywhere at a minimum, but sometimes you may achieve the highest AAA level, too.
Each level builds on the preceding levels, so delivering level AA includes achieving level A, too.
Decide on an evaluation method
As part of the VPAT, you will be asked to describe the evaluation method used. It may be impractical to audit every page of a large website, so start by considering what to test.
Identify critical pages and user journeys
Sampling a manageable number of web pages that provide a good representation of the whole may be required for large websites. Here’s how to choose which pages to test:
Key pages
- High Traffic Pages: Include pages that receive the most visitors, such as the homepage or the most popular pages.
- Key functionality: Include pages that are essential for the website’s core functions, such as search, login, or checkout.
- Interactive features: Include pages with significant interactive features, such as navigation menus, calculators, and surveys.
- Representative samples: Include a sample of pages that cover the basic templates and content types used on your website, such as an article, a contact page, and a blog post.
User journeys
- Navigation: Include a navigation journey, such as using the main site menu to find and open a particular subpage.
- Form completion: Include the steps for filling out and submitting forms, exercising any validation, and reporting errors.
- Content access: Include a journey that includes accessing and reading content on various pages.
- Interaction: Interactive components like menus, dialogs, and accordions are likely sources of barriers for users; include these in the journeys you test.
- Multi-media: Include a journey that requires watching videos, if there are any. Assume the user needs captions and audio descriptions.
Identify tools and techniques
When describing the evaluation method used, include a variety of tools and techniques. Below are some examples.
- Automated scans: Tools like WAVE, Axe, or Lighthouse can quickly find simple accessibility bugs. However, automated testing alone is never adequate since most accessibility issues are only exposed with manual testing. Note any warnings or failures flagged by the automated tool.
- Keyboard testing: Using only a keyboard, ensure all content, interactive elements, and media are accessible and usable. Note any places where access was confusing, difficult, or impossible.
- Testing with assistive technologies: Complete each user journey using a screen reader such as JAWS, NVDA, or VoiceOver. In addition, try accessing and using pages with screen magnifiers, voice recognition, and a high-contrast display mode. Note any places where access was confusing, difficult, or impossible.
- Responsive to accessibility preferences: Finally, enable various accessibility preferences in the operating system or web browser, for example, large text sizes, reduced motion preference, or forced color mode. Note where the application of these preferences interfered with the usability of the page or where the preference was ignored.
If you use proprietary tools or techniques specific to your application, describe them in the VPAT as well.
Complete the checks and record the results
The WCAG edition of the VPAT includes tables with columns for criteria, conformance level, and remarks and explanations.
- Criteria: Each row cites a WCAG success criterion, for example, “1.1.1 Non-text Content (Level A).” To evaluate your webpage against this criterion, you should check that appropriate alternative text is provided for non-text content, like images and graphics.
- Conformance level: Based on the criteria and your evaluation, you would enter either supports, partially supports, does not support, or not applicable in the conformance column.
- Remarks and explanations: This column is where you should add any additional information. For example, if a criterion is not supported, you could describe the specific reason, such as, “On mobile devices, the navigation menu cannot be focused with a screen reader.”
What does each of the possible conformance levels mean?
- Supports: The website provides at least one method of access that fully meets that accessibility criteria.
- Partially supports: Some, but not all, of the website’s features meet that accessibility criteria.
- Does not support: Most of the website’s features fail to meet that accessibility criteria.
- Not applicable: That accessibility criterion doesn’t apply to this website. For example, a criterion related to video captions wouldn’t apply to a website without any video content.
Now you have an ACR
The VPAT you completed essentially becomes your ACR. While it is only a snapshot of your website’s accessibility health, you should treat it as valuable documentation of the work you’ve accomplished and what you still have left to do.
Regularly review and update your ACR to ensure it reflects any changes or improvements in your website’s accessibility.
Can I complete a VPAT myself?
There is no official standard for who is qualified to complete a VPAT. You could complete a VPAT yourself, but the job will require you to have a good understanding of accessibility standards and the ability to use the various testing tools and techniques to evaluate your website.
If you’re not confident in your ability to perform an accessibility audit and create these documents, consider employing a specialist. It is not uncommon for third-party auditors or accessibility consultants to complete VPATs on behalf of vendors.
The cost of this kind of service can vary significantly depending on several factors. Expect it to rise with the website’s complexity and size, the auditor’s experience and qualifications, the depth of analysis required (for example, whether remediation recommendations are included), and the turnaround time.