VPAT Overview

What is a VPAT Definition

A VPAT is an overview of the accessibility compliance of a product. It is often owned and assessed by the product’s vendor – though that’s not necessarily a good idea. It is required by the Section 508 Refresh and almost all Federal solicitations.

What a VPAT is not

A VPAT is not an accessibility audit report of a product – although, it is necessary to conduct an accessibility audit of the product to write an accurate VPAT. Without an accessibility audit, a VPAT is just a guess about the product’s accessibility compliance.

Interestingly, VPATs are not just for government. A lot of organizations are now asking for them, as they are really the only way to get an accurate sense of the accessibility compliance of a product. It’s also not just for web products – a VPAT can also be provided for desktop applications (for example, Word), hardware (for example, a smartphone) and equipment (for example, a photocopier).

VPATs only cover the accessibility compliance of the output of a product. Therefore, if you are looking at a product that has some authoring components (such as a Content Management System or video player) you will need to determine if the product allows for authoring accessible content (outputting valid code in the case of a CMS, or having a feature for audio descriptions in the case of a video player).

Do not assume that a VPAT is accurate, especially in the case where a VPAT has been written by the product’s vendor. However, there are cases where an external agency has written the VPAT, and it is still inaccurate.

Sections of a VPAT

A VPAT has the following sections:

• Title: “[Company Name] Accessibility Conformance Report”
• Name of product and version
• Product description
• Report date
• Contact information
• Notes
• Evaluation Methods Used
• Report information
• Terms
• Tables for each standard or guideline

How to tell if a VPAT is reasonable in ten minutes or less

Red flags (possible inaccuracy indicators)

• Cells without content in the table section: Each cell should have content. If a product meets a requirement, there must be a description on how this is achieved. If it does not meet or partially meets, that must be described in detail.
• Terminology such as “Passes” and “Fails”: Standard VPAT terminology is “Supports,” “Partially Supports” and “Does Not Support.” Other terms suggest the author may not be an accessibility specialist.
• A lot of “NA”: “Not Applicable” should only be used when a feature truly doesn’t exist. If a product has the feature, “NA” is a red flag.
• All “Supports”: Unlikely to be fully accessible, especially if other red flags exist.
• One VPAT for multiple products: Typically there should be one VPAT per product/version.
• An inaccurate or unclear product description: Often indicates the author doesn’t understand the product, so the assessment may be flawed.
• Notes exclude essential features: e.g., excluding registration flow, WYSIWYG editor, or key transaction steps.
• Dated more than 12 months ago: May not reflect the current product.
• Missing Evaluation Methods Used details: This section is a strong signal of expertise and whether real testing occurred.
• Only automated testing listed: Automated tools find only a portion of issues; manual + assistive tech testing is needed.
• Missing/inaccurate contact information: Suggests accessibility is not prioritized.
• “Not evaluated” in Level A or AA: Often means it wasn’t tested; treat it like “Does Not Support.”

Contacting the vendor

If you have identified red flags then it is essential that you contact the vendor. Example questions are:

• “Why is this dated 14 months ago? Has the product not been updated in 14 months?”
• “Why did you say this section is NA when the product has this feature?”
• “What kind of testing did you do to ensure compliance?”
• “Why did you decide to fill out this VPAT internally?”
• “Why does the description omit essential features of the product?”
• “Why did you decide to test with only one screen reader?”

Tip: Evaluate how the vendor responds. A thoughtful, specific answer with evidence often indicates a mature accessibility program even if the VPAT needs updating.

What does a good VPAT look like?

A good VPAT has the following characteristics:

• Has explanations for all criteria
• Uses conventional wording such as “Supports,” “Partially Supports,” “Does Not Support” and “Not applicable”
• Stands up to questioning
• Has been written by someone other than the product vendor
• Has a clear description of the product, including associated features
• Refers to existing accessibility testing tools in the testing undertaken

How do you assess the accuracy of a VPAT?

1) Read through the VPAT

• Does the VPAT reference known accessibility issues with the product?
  If you don’t know the product, research it. Search “XYZ accessibility” (XYZ = product name). Check known community discussions.
• Does the VPAT accurately describe the product?
  Verify the description matches real features and doesn’t exclude critical flows.
• Does the VPAT include reasonable Evaluation Methods?
  Look for manual testing + assistive tech testing, not just automation. Ask for outputs/evidence if tools are named.
• Does the VPAT use correct terminology?
  Confirm “Supports,” “Partially Supports,” “Does Not Support,” “Not Applicable.”
• Are tables completed accurately?
  Watch for “Not Applicable” on features the product clearly has. Ensure each requirement has a meaningful comment.

2) Test the VPAT (quick checks)

The following requirements are easy to test quickly:

• 2.1: Keyboard
  Can you access all items? Is focus visible? Can you open menus, popups, and submit forms?
• 2.2: Pause, Stop, Hide
  Any movement? Can it be paused (mouse, keyboard, touch) or does it stop within 5 seconds?
• 2.4.1: Bypass Blocks
  Is there a skip link and is it the first focusable link?
• 3.3.1: Error Identification
  Submit an empty/incorrect form. Are errors described clearly? Do they include suggestions?

If you answered “No” to any quick check, compare it to the relevant VPAT cell. If the VPAT does not describe the issue, treat the VPAT as inaccurate and require clarification or further assessment.