Below is a list of frequently asked questions on the Accessibility Conformance Report (ACR) and the Voluntary Product Accessibility Template (VPAT®). This information was adapted from NASA’s Demystifying Section 508: An Industry Guide to Understanding Section 508 of the Rehabilitation Act.
How do I determine if my product is compliant with Section 508?
Industry is expected to test its products against the applicable Section 508 Technical Standards and then report which standards the product supports, partially supports, or does not support. This is so that the agencies can consider accessibility when purchasing the product. This information is provided by industry in the form of an Accessibility Conformance Report (ACR). If the product supports all of the applicable Section 508 Technical Standards, the product is considered compliant with Section 508.
How do I know which version of the VPAT® to use?
The Information Technology Industry Council developed a template called the Vendor Product Accessibility Template or VPAT® which includes all the relevant Section 508 Technical Standards required by the Revised Section 508 rule (2017). ITI has several templates that apply internationally. Be sure to use the VPAT® that includes the Revised Section 508 Standards (Rev508 or RevINT Version 2.x or later). For the most recent version of the VPAT® and additional information, visit the ITI website.
I have not completed a VPAT®/ACR before. Why am I being required to complete it now? Isn’t the VPAT® voluntary?
The U.S. federal government must buy Information and Communication Technology (ICT) that is accessible per Section 508 of the Rehabilitation Act. The government asks industry to submit an Accessibility Conformance Report so that the accessibility of a product may be evaluated. Without the ACR, the government may not proceed with the purchase unless there is a special use case exception that the government – never industry – may claim in which the ACR will not be required. Industry completes the ACR so that their product may be considered for purchase.
There are several methods for completing an ACR. The VPAT®, which is a template developed by the IT Industry Council (ITI), is the most common method for completing an ACR since it provides all the relevant Section 508 Technical Standards and instructions on how to complete a report in one tool. While the use of the VPAT® itself is not required, it is not voluntary to complete an ACR if you wish the government to consider purchasing your product.
My company created an ACR for a product years ago. May I use that same ACR today?
Every time your product is changed or updated (e.g. version change, bug fix, etc.), an updated ACR may be required to address any changes in the product’s accessibility. Also, if you created an ACR using the Original Section 508 Standards from 2001, you must update your report using the Revised Section 508 Standards published in 2017.
Should I complete an ACR if my product is not fully accessible? How can having a completed ACR for my product benefit my company?
Yes. Completing an ACR is a win-win situation for industry and the government. When industry develops an ACR, it opens the door for the federal government to purchase your product. Your ACR shows customers that your company takes accessibility seriously. Even if the ACR shows that not all the applicable Section 508 Technical Standards have been met, it allows your product to be evaluated against comparable products for accessibility. If you have an ACR and a competitor’s product doesn’t, you will always be the most conformant with the Section 508 standards. Completing an ACR raises your awareness of your product’s accessibility and allows you to take steps to make your product more accessible and reach a broader customer base.
My product is not web-based. Do the WCAG 2.0 (Web Content Accessibility Guidelines) apply to my product?
In the Revised Section 508 Technical Standards, electronic content and software are required to conform to WCAG 2.0 Level A and Level AA Success Criteria and Conformance Requirements. While the WCAG standards obviously apply to web products, they also apply to all electronic content and software.
My product has support documentation, hardware, and a mobile application. Do I need to complete three separate ACRs?
No, you may complete one ACR that addresses all the relevant standards and criteria that match the functionality of your product. You may provide separate ACRs, if you desire.
My product is an add-on for an existing product from a separate company. Am I responsible for completing the ACR for my product, or will the other company create the ACR?
You are responsible for completing an ACR for the product you developed.
My product does not conform to all the relevant Section 508 Technical Standards. Will this prevent the federal government from purchasing my product?
No. Your product will still be considered for purchase even if all of the Section 508 Technical Standards are not met. Your product will be compared to other similar commercially available products for potential purchase.
What do I enter under the columns “Conformance Level” and “Remarks and Explanations”?
In the Conformance Level column, you enter terms to describe to what extent your product meets a specific standard. Conformance Level terms are: Supports, Partially Supports, Does Not Support, or Not Applicable. If your product Partially Supports or Does Not Support the standard, you should provide a comment in the Remarks and Explanations column that indicates how the standard is not met/fully met. Definitions of the terms used in the Conformance Level column are available in the Essential Requirements for Authors section of the VPAT® template.
My product contains both software and support documentation. Which sections of the VPAT® do I need to complete?
If your product contains software, there are two sets of Section 508 Technical Standards within the report that you must complete:
- WCAG 2.0, Table 1: Success Criteria Level A and Table 2: Success Criteria Level AA
- Revised Section 508, Chapter 5: Software
For electronic support documentation, complete the Revised Section 508, Chapter 6: Support Documentation and Services section.
Reviewed/Updated: June 2022
