Procurement officers and employees responsible for purchasing products for a company may request an Accessibility Conformance Report (ACR) based on the ITI Voluntary Product Accessibility Template (VPAT).
The reason why these reports are needed is that organizations want to purchase the most accessible version of a product to ensure it will work for people with disabilities. The VPAT or ACR is the tool to understand whether a product has evaluated and improved access for people with disabilities.
In reality, many people say VPAT and don’t mention ACR. Though technically incorrect, people treat VPAT and ACR as interchangeable. It’s simple once you spell it out.
- VPAT is a template.
- ACR is a filled-out template.
Everyone should request a completed VPAT or ACR. This document shows how well or not the product conforms to each of the criteria for the standard. It is important to know whether a company’s product conforms to accessibility standards.
Who Uses Voluntary Product Accessibility Template (VPAT)?
If a company selling digital products or services wants to do business with the U.S. Federal government, then they need to provide an Accessibility Conformance Report. This conformance report is an essential part of the selection process when the government needs new technology.
Who needs to complete the VPAT?
- Companies that want to do business with the U.S. Federal government.
- Companies selling information and communications technology (ICT) products and services.
- Manufacturers and suppliers.
- Educational institutions.
On the buyer side, purchasing companies that prioritize accessibility require an ACR from potential vendors. They have learned from experience that many companies have not done the work to build an accessible product. These companies have learned the hard way when their employees with disabilities could not use the product they bought.
Even consumers review ACRs. For example, an end user wants to buy from companies that build accessible products. They want to reward them for making accessibility part of their business. The ACR helps them understand what the company has done to make their products accessible.
The way this may work is that a user wants Bluetooth headphones. They would research brands to narrow the list. Then, they’ll go look to see if these companies have completed a VPAT, which is known as the Accessibility Conformance Report. In reviewing the ACRs, it’ll be easier to compare the similarities and differences between products.
Voluntary Product Accessibility Template (VPAT) Editions
There are multiple editions of the VPAT. The correct one depends on what the organization follows. If an American company wants to sell its product to an EU member state, then it will need to use the EN 301 549 edition of the VPAT. If it wants to sell to the U.S. Federal government, it will also need to use the Section 508 edition of the VPAT.
Per Section 508 of the Rehabilitation Act of 1973, the U.S. Federal government’s technologies must be accessible to people with disabilities, both employees and customers. State and local governments must comply with the Americans with Disability Act (ADA) Title II. It requires them to give people with disabilities an equal opportunity to benefit from programs, services, and activities.
Then, there’s EN 301 549, a European standard for digital accessibility. The standard applies to all information and communication technology (ICT) purchased by EU governments. It’s followed by all 28 European Union member states, three EFTA countries including Iceland, Norway, and Switzerland, and two EU candidate countries (Turkey and the former Yugoslav Republic of Macedonia).
Many companies choose to conform to Web Content Accessibility Guidelines (WCAG) v2.1 Level AA. The specific use cases will determine the need to use a specific edition of the VPAT.
The VPAT editions include the following:
- WCAG: Contains only WCAG 2.1 criteria and works in general cases.
- 508: Contains Section 508 criteria, which includes WCAG 2.0 Level AA, and works for the U.S. government.
- EU: Contains EN 301 549 criteria, which includes WCAG 2.1 Level AA and works for the EU government.
- INT: Contains all of the above, and will work as a document globally.
A company that wants to conform with WCAG, Section 508, and EN 301 549 can use the INT edition because it contains all of them. They can put all of them in one Accessibility Conformance Report or three separate ones.
This chart clarifies which to use.
|Location and sector||WCAG||508||EU||INT|
|U.S. Public Sector||X||X|
|European Union (EU)||X||X|
|U.S. Private Sector||X||X||X|
|EU Private Sector||X||X||X|
Comparing Products with a Completed VPAT
The purpose of the VPAT is to make it easier to compare products. Let’s say your company requests an Accessibility Conformance Report for a specific product. You get submissions from 10 vendors who sell the product. If they all do their own reporting without a template, it is harder to compare the products.
Since they’re using the VPAT from ITI, the frame of the document will look the same. The only thing that’s different is the information added to the template. It simplifies the comparison.
A VPAT contains three columns.
- Criteria: This references a specific criterion in the WCAG, Section 508, or EN 301 549.
- Conformance level: Indicates the conformance level using these terms as defined by ITI, the creator of VPAT:
- Supports: The functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.
- Partially Supports: Some functionality of the product does not meet the criterion.
- Does Not Support: The majority of product functionality does not meet the criterion.
- Not Applicable: The criterion is not relevant to the product.
- Not Evaluated: The product has not been evaluated against the criterion. This can only be used in WCAG 2.x Level AAA.
- Remarks: If the conformance level Is “Partially supports” or “Does not support,” then it requires remarks to identify the function or feature with issues and how they do not fully support it. If it’s “Not Applicable,” then explain why.
Evaluating a Completed Voluntary Product Accessibility Template (VPAT)
It is essential to avoid trusting the accessibility conformance report as gospel or 100% accurate. The person creating the ACR may embellish it to show they conform with the standards. Of course, it may not be intentional as they may not understand the requirement. WCAG isn’t easy to interpret. These guidelines contain many pages of information and people get confused. Do your due diligence.
The way to check is to use the product. Here’s a simple example. You’re looking to use a video platform with captions. It needs to conform with WCAG 2.1. 1.2.4 Captions (Live), which states the following:
“1.2.4 Captions are provided for all live audio content in synchronized media. (Level AA)”
Here’s a look at three video platforms used for virtual meetings, webinars, and other real-time events. The VPAT makes it easy to compare the products.
Google Meet’s ACR is dated 2020. (As of publishing this post.) It shows 1.2.4 Captions (Live) are not applicable with a remark stating “The Google Meet web application does not have audio or video content.”
This was true at the time as it was from before Google Meet added video calls. Someone reviewing this ACR when purchasing a product for an organization that needs accessible communication must remove Google Meet from their list.
This is the challenge with completed VPATs. They’re a snapshot at a point in time. Companies need to keep them updated. Hence, buyers should contact companies to request an update when they find inaccurate, outdated, or incomplete information.
Google Meet’s ACR indicates it does not have audio and video content. In this case, the buyer should reach out to Google to request an updated ACR.
Microsoft Team has multiple Accessibility Conformance Reports. It has one for every platform including Android, iOS, Mac, Web, and Win32. The reviewer selects the correct platform. This example uses Win32.
Microsoft Teams ACR for Win32 says it “Supports” 1.2.4. Captions work properly in Microsoft Teams. The reviewer opens Microsoft Teams for Win32 and confirms this is accurate.
The Zoom Desktop Client v5.14.0 (Windows) ACR [PDF] 1.2.2 Captions (Prerecorded), Zoom’s ACR states the following:
“The product supports open and closed captioning for its recorded meetings. Users can assign a dedicated participant to type in closed captioning, add a 3rd party closed captioning provider, or use automatic transcriptions.
“The product does not provide pre-recorded media. Meeting participants may share pre-recorded audio-only content during a meeting and provide the necessary captioning using in-meeting file transfer.”
This is confusing. Open captions are captions glued on the screen. They cannot be turned off and on. It’s not clear why “open caption” is mentioned in the ACR. Zoom does not do open captions on live events. The only way to have open captions on Zoom is to use an app to add open captions onto a video recording shown during the live event. Hence, open captions aren’t a Zoom functionality.
The second paragraph indicates the product does not provide pre-recorded media. Well, it depends on how you look at it. You can turn a meeting into pre-recorded media. It also saves the captions from the meeting.
What will confuse the reader is “using in-meeting file transfer.” Even if they know what file transfer is, it won’t make sense how to have an in-meeting file transfer to provide captions.
Zoom’s ACR for 1.2.4 Captions (Live) shows “Supports” with an explanation: “The product supports closed captioning for its meetings. Meeting hosts can assign a dedicated participant to type closed captioning, use a 3rd party closed captioning provider, or use automated captioning.”
This might’ve been the case when they created the ACR. It’s important to not take the vendor’s word for it. The person reviewing Zoom’s completed VPAT can ask an employee who uses captions for their input.
If that employee happened to be me, I’d tell the buyer that Zoom’s conformance level with 1.2.4 Captions (Live) is actually “Partially Supports.” Here’s why. For more than a year, Zoom captions don’t always come on when the audio starts. Sometimes they take five minutes to show up. Sometimes longer. In fact, in a Zoom meeting about this article, the captions kept disappearing.
The buyer should reach out to Zoom to ask them about this. The company may reply that it’s a known issue. In this case, ask them for an estimated timeframe for resolution and any other information to stay posted on it. If the company says it has not heard about it, then ask about submitting a bug report and tracking it.
In other words, if the buyer gets a report of a contradiction in the ACR, they should bring it to the company’s attention.
Things to Know About a Completed VPAT
Some companies may hire an external company to fill out the VPAT. They do this to prevent bias. Plus, some of the accessibility guidelines can be confusing for people who aren’t knowledgeable about accessibility and the guidelines. An external company that specializes in accessibility knows how to confirm all criteria. They’re more likely to get through the VPAT to fill it out quickly and correctly.
The important thing to remember about a completed VPAT or ACR is that it’s a snapshot. Things change as the product gets updated and things break. Refer back to the point that Zoom’s captions don’t always show up. Maybe when they wrote the VPAT, the captions were consistently available. Google Meet’s ACR is outdated as it states it does not support video and audio.
If you find a criterion that doesn’t match what’s in the ACR, it may not be an untruth or exaggeration. It could simply be something that changed after creating the ACR. Procurement officers, buyers, and decision-makers should contact the company and ask about it. Remember, accessibility is a journey.
Does your website or technology need an accessibility audit or VPAT?
Equal Entry has a rigorous process for identifying the most important issues your company needs to address. The process will help you address those quickly. We also help companies create their conformance reports often referred to as VPAT so they can sell to the government or provide it to potential clients who require them. If you’d like to learn more about our services for auditing and creating VPAT conformance reports, please contact us.