VPATs: Why Are They Important

Increasingly, businesses are requesting information about VPATs and having accessibility experts audit and create them. But why has this become such a critical business requirement? While accessibility lawsuits have certainly created awareness, the primary driver is straightforward: any business, foreign or domestic, that wishes to work with the U.S. Federal Government needs a VPAT (or several). Understanding that this document is vital if your business, institution, or organization receives funding from the U.S. government — it’s simply required.

The VPAT process might seem like one of those mystifying hurdles that appear too complicated to tackle. It’s not. With a solid understanding of why VPATs matter and what they accomplish, you can approach them strategically, or work with accessibility professionals who handle them every day. To truly grasp the document’s importance to your business and the disability community, you need to understand the laws and compliance landscape behind it.

What Is a VPAT?

The Voluntary Product Accessibility Template, or VPAT, has become an essential business document and is now standard for most organizations wanting to conduct business with government agencies. This comprehensive document explains in detail how your Information and Communication Technology (ICT) conforms to the accessibility standards set by the Revised 508 Standards of the Rehabilitation Act of 1973.

The VPAT process analyzes ICTs, including electronic content, hardware, software, and mobile applications, providing detailed documentation about how accessible these technologies are to persons with disabilities. It’s increasingly required by a growing number of businesses, buyers, contractors, and all federal organizations before purchasing or implementing any ICTs — especially if those entities conduct business with government agencies themselves.

The Business Purpose of a VPAT

From a business leadership perspective, a VPAT serves multiple strategic purposes beyond simple compliance. It helps buyers and contractors of ICTs make informed decisions before purchasing, while providing your organization with several competitive advantages:

Comprehensive Compliance Analysis: A VPAT provides a thorough analysis of your ICT’s compliance with Revised 508 Standards, demonstrating your commitment to accessibility and legal compliance.

Market Differentiation: Understanding your ICT’s level of accessibility gives you a clear competitive advantage in procurement processes, especially when competing for government contracts or working with accessibility-conscious organizations.

Transparent Communication: The document gives your company an opportunity to explain conformance to each individual accessibility criterion, showing potential clients that you understand and address accessibility proactively.

Competitive Benchmarking: VPATs allow procurement teams to compare accessibility compliance across similar products, positioning your solution favorably when accessibility is properly implemented.

Strategic Alignment: A well-executed VPAT helps demonstrate that your ICT meets both the functional and legal accessibility requirements that organizations increasingly prioritize.

Why Your Business Might Need a VPAT

With current regulations including WCAG 2.2 now fully implemented and enforced, VPATs help ensure that all citizens of the United States, not just federal employees, can access and use digital documents, devices, websites, and software equally. Here are the key business scenarios where VPATs become essential:

Federal Business Opportunities: Any business whose ICTs might be used by federal employees must comply with 508 regulations. This opens significant market opportunities while ensuring compliance.

Government Funding Recipients: Organizations receiving state or federal funding, including educational institutions, or groups working indirectly with government entities, typically require VPAT documentation.

State-Level Compliance: Some states, particularly California, have enacted their own accessibility laws, and VPAT documentation helps demonstrate compliance with these varying requirements.

ADA Title III Compliance: Any public-facing website with a physical business presence should conform to the Americans with Disabilities Act to ensure equal digital access for all users.

International Market Access: Businesses with products or services intended for European markets must consider EU Accessibility Act requirements, making international VPAT variants valuable.

Private Sector Requirements: Many public and private organizations now require VPAT documentation as part of their procurement processes, only purchasing accessible products and ICTs.

Third-Party Validation: Increasingly, organizations require VPATs completed by independent, third-party accessibility auditors to ensure accuracy, honesty, and impartiality in accessibility claims.

Understanding Different VPAT Types

There are four specific VPAT variants designed for different accessibility standards and business requirements:

508 VPAT: Addresses U.S. Revised 508 Accessibility Standards, essential for federal contracting.

WCAG VPAT: Focuses on Web Content Accessibility Guidelines, crucial for web-based products and services.

EU VPAT: Meets European Union accessibility requirements, necessary for international market access.

INT VPAT: Incorporates all three accessibility standards, providing comprehensive international coverage.

Legal Requirements and Business Risk Mitigation

While creating a VPAT isn’t legally mandated, not having one can prevent federal or state organizations from doing business with you — essentially closing off significant market opportunities. Title III of the ADA may require your company’s online presence to be accessible as a “place of public accommodation,” and having a VPAT demonstrates proactive compliance efforts.

From a risk management perspective, maintaining current VPAT documentation is an excellent strategy for minimizing litigation risk under existing federal and state accessibility laws. It shows courts and potential plaintiffs that your organization takes accessibility seriously and works continuously toward compliance.

The VPAT Process: A Strategic Business Approach

Understanding the VPAT process helps business leaders make informed decisions about accessibility investments and vendor relationships. The terms VPAT and Accessibility Conformance Report (ACR) are sometimes used interchangeably, which can create confusion. While a VPAT is technically a type of ACR, many accessibility companies provide comprehensive reports that go beyond the basic VPAT form.

At Accessiblü, our approach differs from traditional audit-focused companies. Rather than simply delivering a list of issues, our Managed Accessibility Ops service provides an agile model that facilitates simultaneous testing, identification, and remediation. This approach recognizes that digital accessibility, like cybersecurity, requires ongoing attention rather than periodic audits.

The Strategic VPAT Process:

Comprehensive Accessibility Audit: Every ICT component — whether website, application, electronic content, hardware, or software — undergoes thorough testing against Revised Section 508 standards or the specific VPAT requirements your business needs.

Detailed Conformance Reporting: The resulting ACR identifies accessibility issues for each criterion and provides clear guidance on meeting 508 Standards compliance requirements.

Remediation Methodology: Our reports include evaluation methods and practical steps for validation and remediation, giving your development teams actionable guidance.

Strategic Implementation: Review the ACR results and implement necessary remediations through your internal team, accessibility specialists, or development partners capable of addressing identified issues.

Ongoing Authorization and Updates: The VPAT process allows for comments and progress indicators, meaning you can publish updates as remediation work progresses, maintaining current documentation while continuously improving accessibility.

These processes exist to serve both business objectives and social responsibility. While VPAT documentation requires detailed attention, working with the right accessibility partners makes the effort worthwhile and cost-effective for achieving compliance goals.

Creating and Maintaining VPATs: Best Practices for Business Leaders

Anyone can technically create a VPAT using freely available templates, but completing one properly requires extensive knowledge about accessibility standards, assistive technology testing, and the specific criteria needed for each document type. The testing process involves approximately 70% manual evaluation and only 30% automated testing — understanding this distinction is crucial for creating valid documentation.

Most organizations work with specialized accessibility companies like Accessiblü to conduct comprehensive audits and complete ACR and VPAT documentation. When selecting an accessibility partner, ensure they provide VPAT 2.4 or higher. Section 508 was revised in 2017 and now measures accessibility using Web Content Accessibility Guidelines (WCAG) 2.1 and 2.2 criteria. Any VPAT developed before this revision may be outdated, especially if your ICT has been updated since then.

VPAT Update Frequency and Maintenance

From a business operations perspective, best practice involves updating VPATs annually or whenever significant changes occur to your ICT systems. Major changes include new document releases, website restructuring, ICT modifications, or updated application versions. Additionally, when new accessibility standards are released — such as the transition from WCAG 2.1 to WCAG 2.2 — existing VPATs should be updated to reflect current compliance status.

This ongoing maintenance approach aligns with Accessiblü’s philosophy that accessibility requires continuous attention rather than periodic compliance checks. Our Managed Accessibility Ops service helps organizations maintain current documentation while continuously improving their accessibility posture.

Legal Protection and Business Benefits

While lawsuits can occur at any time — and accessibility litigation has increased significantly in recent years — having current VPAT documentation demonstrates to courts that your organization understands accessibility requirements and makes ongoing efforts toward compliance. The Legal Disclaimer section within VPAT documentation allows companies to craft statements that provide additional protection.

Most accessibility lawsuits focus on improving access for disabled persons rather than seeking financial compensation. Conducting regular audits and maintaining current VPATs shows commitment to accessibility conformance. Accessiblü recommends publishing an “Accessibility Statement” alongside VPAT documentation to demonstrate ongoing commitment to accessibility and inclusion.

The Business Case for Strategic VPAT Investment

Beyond compliance requirements, VPATs represent strategic business investments that open market opportunities, reduce legal risk, and demonstrate corporate responsibility. Organizations that approach accessibility proactively — rather than reactively — position themselves advantageously in procurement processes while building inclusive user experiences that benefit everyone.

Working with accessibility partners who understand both compliance requirements and business objectives ensures that VPAT documentation supports broader organizational goals while meeting technical requirements. The investment in comprehensive accessibility — including VPAT documentation — typically pays dividends through expanded market access, reduced legal exposure, and improved user satisfaction.

Understanding VPATs as strategic business tools rather than mere compliance documents helps organizations approach accessibility with the seriousness and investment it deserves. When implemented properly, accessibility becomes a competitive advantage that opens doors to new opportunities while serving the broader goal of digital inclusion.

Key Accessibility Terms for Business Leaders

VPAT: Voluntary Product Accessibility Template

ICT: Information and Communication Technology
ACR: Accessibility Conformance Report
PWD: Persons with Disabilities (or persons with different abilities)
Revised 508 Standards: Requirements ensuring information and communication technology is accessible and usable by individuals with disabilities
Rehabilitation Act 1973: Federal law prohibiting discrimination based on disability in programs conducted by federal agencies, programs receiving federal financial assistance, federal employment, and federal contractor employment practices
ADA (Americans with Disabilities Act): 1990 federal law prohibiting discrimination against people with disabilities in employment, transportation, public accommodations, communications, and access to state and local government programs and services
WCAG 2: Web Content Accessibility Guidelines, a stable technical standard developed by the World Wide Web Consortium (W3C) for creating accessible websites and web content, organized around four principles: Perceivable, Operable, Understandable, and Robust (P.O.U.R.)
WCAG 2.2: The current version of Web Content Accessibility Guidelines, implemented in 2023, providing updated success criteria for digital accessibility compliance