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VPATs Demystified: What Business Leaders Need to Know About Voluntary Product Accessibility Templates

Kimberly Springs

Jeffrey Rodgers

April 28 12 min read

In today’s digital landscape, accessibility isn’t just a nice-to-have—it’s increasingly becoming a business imperative. If you’re a CEO, CTO, or digital project manager, you may have heard the term “VPAT” floating around, especially if your organization wants to sell to government agencies or educational institutions. But what exactly is a VPAT, and does your business need one?

Let’s break it down in plain language.

What Is a VPAT, Anyway?

A Voluntary Product Accessibility Template (VPAT) is a document that explains how your digital product—whether it’s a website, software application, or hardware device—conforms to various accessibility standards. Think of it as a structured way to disclose your product’s accessibility features and limitations.

The keyword here is “voluntary”—there’s no legal requirement to create one. However, VPATs are becoming increasingly common ” asks” from companies—both public and private—who want to address accessibility. This means having a VPAT can open doors to certain markets and demonstrate your commitment to digital inclusion.

Why Your Business Might Need a VPAT

Accessing Government and Education Markets

The most compelling reason to create a VPAT is to sell to the local, state, and federal government agencies. Section 508 of the Rehabilitation Act requires federal agencies to purchase accessible technology. Section II of the Americans with Disabilities Act requires public institutions to meet WCAG 2.1 Level AA requirements.

This means that a VPAT helps procurement officers evaluate whether your product meets their accessibility requirements.

Similarly, many state governments, libraries, universities, and K-12 school districts require VPATs as part of their procurement process. If these sectors are part of your market strategy, a VPAT becomes essentially mandatory.

Competitive Advantage

Even in the private sector, a VPAT can give you an edge. As more companies prioritize accessibility in their vendor selection process, having a ready-to-go VPAT demonstrates that you take accessibility seriously and can save potential clients the hassle of conducting their own accessibility evaluations.

Risk Mitigation

With the rise in digital accessibility lawsuits, a VPAT can serve as part of your due diligence documentation. While it doesn’t provide legal immunity, it demonstrates a good-faith effort to address accessibility concerns and can be valuable in the event of litigation.

Market Expansion

Creating a VPAT often leads to improvements in your product’s accessibility, which in turn expands your potential user base. Remember that approximately 26% of adults in the U.S. have some type of disability—that’s a significant market segment you don’t want to exclude.

When You Might NOT Need a VPAT

Not every business needs to invest in creating a VPAT. Here are some scenarios where it might not be necessary:

You Don’t Sell to Government or Education

If your customer base is purely in the private sector and doesn’t include organizations that require VPATs, you might allocate your accessibility resources elsewhere—like directly improving your product’s accessibility rather than documenting it in a specific format.

Your Product Is Early-Stage

For startups or products in beta, it might make sense to wait until your product stabilizes before investing in a formal VPAT. However, building with accessibility in mind from the start will make the eventual VPAT process much easier.

Purpose-Built Products for Specific Abilities

Some products are designed specifically for users with certain abilities and may inherently exclude others by their very nature and purpose. For example, a speech therapy application relies on users being able to speak and hear. Users who are deaf or non-verbal would likely use different, specialized tools designed for their specific needs.

Similarly, some products are designed for professions where certain abilities are occupational requirements—like digital tools for airline pilots or radiologists. In these cases, a VPAT might be less relevant, though you should still consider accessibility for the aspects of your product that don’t inherently require specific abilities.

Keep in mind, that even if your product does require specific abilities to use it, you can still have a VPAT. We’ve had a number of companies that needed a VPAT even though their product had certain aspects that were not fully accessible because certain abilities are required to use it.

The Different Types of VPATs

Not all VPATs are created equal. The Information Technology Industry Council (ITI) provides several VPAT templates, each addressing different standards:

VPAT 508 (Revised Section 508)

This focuses specifically on the requirements of the refreshed Section 508 standards, which apply to federal agencies and contractors. If you’re primarily selling to the U.S. federal government, this is the version you’ll likely need. It also contains WCAG 2.0 criteria because 508 is based on WCAG 2.0.

A 508 VPAT takes a bit longer to create since it contains requirements for both Section 508 and WCAG 2.0.

VPAT WCAG

This template addresses all of the Web Content Accessibility Guidelines (WCAG) 2.2, which are international standards developed by the W3C. This version is useful if you’re marketing your product internationally or to organizations that specifically reference WCAG.

The WCAG VPAT is also the most universal one if you simply want a VPAT. It’s also the least expensive to make. Finally, we can still make a WCAG 2.1 VPAT for cases where those are specifically being requested.

VPAT EU (European Union EN 301 549)

This covers the European Union’s accessibility requirements for ICT products and services. If you’re selling in European markets, this version will be relevant.

VPAT INT (International)

The most comprehensive option, this incorporates all of the above standards. It’s the most work to complete but gives you the broadest coverage for various markets.

The choice of which template to use depends on your target markets and the specific requirements of your customers. Many organizations create multiple versions to address different audience needs.

What’s Involved in Creating a VPAT?

Creating a VPAT is not a quick checkbox exercise—it’s a substantial undertaking that requires expertise and rigorous testing. Here’s what the process typically entails:

1. Accessibility Testing

The foundation of any VPAT is thorough accessibility testing. This involves evaluating your product against each applicable success criterion in the relevant standards. Testing typically includes:

  • Manual testing by accessibility experts
  • Automated testing using specialized tools
  • Testing with assistive technologies like screen readers
  • Testing by users with disabilities (highly recommended)
  • Testing on desktop or mobile devices (highly recommended)

2. Documentation and Analysis

Once testing is complete, the results must be documented in the VPAT format, which includes:

  • Detailed descriptions of how each criterion is supported (or not)
  • Notes about specific features or limitations
  • Information about alternative methods to access functionality, if applicable

3. Review and Validation

Before finalizing, the VPAT should undergo review by accessibility experts and stakeholders to ensure accuracy and completeness.

Time and Cost Considerations

The effort required to create a VPAT varies widely based on the complexity of your product. Here’s a general estimate:

  • For a relatively basic websites and applications: 40-80 hours of expert time
  • For a complex websites and applications: 80-100+ hours
  • For enterprise software with multiple interfaces: 200+ hours

In terms of cost, professional VPAT services typically range from $10,000 to $25,000+ depending on the scope. Factors that influence cost include:

  • Size and complexity of the product
  • Number of user interfaces and unique page templates
  • Which standards you need to address (508, WCAG, EU, etc.)
  • Whether remediation services are included

Maintenance Requirements

Remember that a VPAT isn’t a one-and-done document. It should be updated:

  • When your product undergoes significant changes
  • When you release major new features
  • At least annually to ensure continued accuracy

What to Expect from Your Completed VPAT

A finished VPAT provides a structured disclosure of your product’s accessibility conformance. For each requirement in the applicable standard, it will indicate one of the following conformance levels:

  • Supports: The functionality fully meets the criterion.
  • Partially Supports: The product supports some, but not all, aspects of the criterion, or supports the criterion with some exceptions.
  • Does Not Support: The functionality does not meet the criterion.
  • Not Applicable: The criterion is not relevant to the product.
  • Not Evaluated: The criterion has not been evaluated.

Additionally, your VPAT will include remarks explaining each evaluation and providing context about how features work with assistive technologies.

Understanding the Non-Scoring Nature of VPATs

VPAT FACT: There is no pass/fail or minimum required score!

One of the most commonly misunderstood aspects of VPATs is that they are not scored documents with a pass/fail designation. This confuses many people who are used to compliance documents that provide a clear “compliant” or “non-compliant” verdict.

Why VPATs Don’t Have Scores

VPATs are disclosure documents, not certification or compliance reports. They’re designed to provide transparency about a product’s accessibility features and limitations, allowing procurement officials to make informed decisions based on their specific requirements.

The absence of scoring acknowledges several important realities:

  1. Different organizations have different needs: What’s essential for one customer may be irrelevant for another. For example, a university library may prioritize screen reader compatibility, while a design firm might focus more on color contrast features.
  2. Contextual appropriateness matters: Some criteria may be inappropriate or unnecessary for certain products by their very nature and purpose.
  3. Partial support is nuanced: Many products support accessibility criteria in some ways but not others. A simple pass/fail wouldn’t capture these nuances.
  4. Purpose-specific exclusions are valid: Some products are legitimately designed for users with specific abilities.

Normal and Acceptable Limitations

VPAT Fact: A “Does Not Support” does not mean a failed VPAT!

It’s absolutely normal—and perfectly acceptable—for products to have some accessibility criteria marked as “Not Applicable” or even “Does Not Support.” This does not automatically make a product unsuitable for procurement! In fact, a VPAT that claims full support for every single criterion should raise red flags about its accuracy, as this is virtually impossible for most complex products.

Consider these examples:

  • A voice recognition software designed specifically for speech therapy would naturally require users to be able to speak. The inability to support users who cannot speak isn’t a failure—it’s inherent to the product’s purpose.
  • Specialized medical imaging software for radiologists may require color vision to accurately identify subtle differences in scans. This limitation is tied to the occupational requirements of the intended users.
  • A music education platform might have certain features that rely on hearing. While they should make as many features accessible as possible, some core functionality may inherently require auditory perception.

Business Parallels: When “100% Compliance” Isn’t Realistic

The non-scoring nature of VPATs reflects a reality that exists in many other business contexts. Consider these analogies:

Enterprise Risk Management Frameworks: Organizations don’t aim for zero risk in every category (which would be impossible), but rather appropriate risk levels based on their specific context. Some risks might be acceptable for certain business models while being unacceptable for others.

Environmental, Social, and Governance (ESG) Reporting: Companies rarely achieve perfect scores across all ESG dimensions. Instead, they focus on the aspects most relevant to their industry and stakeholders while acknowledging areas for improvement.

Industry-Specific Certifications: Manufacturing facilities might excel at certain ISO standards while meeting only baseline requirements for others, based on their specific products and markets.

Software Security Compliance: Even highly secure software applications prioritize different security controls based on their threat model and user needs, rather than implementing every possible security feature.

The key is honesty and transparency. Your VPAT should accurately reflect both your product’s accessibility strengths and its limitations, with clear explanations of why certain criteria aren’t supported when applicable. This transparent approach actually builds more credibility than claiming universal support across all criteria.

Best Practices for VPAT Creation and Usage

To get the most value from your VPAT investment:

Be Thorough and Honest

Resist the temptation to overstate your product’s accessibility. Inaccurate claims can lead to legal issues and damage your reputation. An honest assessment that acknowledges limitations is more valuable than one that makes unfounded claims.

Provide Detailed Remarks

The “Remarks and Explanations” section is arguably the most valuable part of a VPAT. Use it to explain how features work with assistive technologies, describe known limitations, and provide workarounds where possible.

Use Expert Evaluators

VPATs require specialized knowledge of accessibility standards and testing methodologies. Work with qualified accessibility professionals who understand both the technical requirements and the real-world implications for users with disabilities.

Consider it a Starting Point

View your VPAT as part of an ongoing accessibility journey rather than an endpoint. Use the findings to inform your product development roadmap and continuously improve accessibility.

Conclusion: Strategic Accessibility Documentation

A VPAT is more than just a procurement requirement—it’s a strategic document that can open markets, reduce legal risk, and demonstrate your commitment to inclusive design. While not every business needs one, those selling to government, education, or enterprise customers should seriously consider investing in this valuable accessibility documentation.

Remember that a VPAT is just one component of a comprehensive accessibility strategy. The most successful organizations integrate accessibility throughout their design, development, and quality assurance processes rather than treating it as a separate compliance exercise.

By understanding what a VPAT is, when you need one, and how to create an accurate and useful document, you can make informed decisions about your organization’s approach to accessibility documentation—and potentially unlock new market opportunities in the process.

Need help determining if your organization needs a VPAT or assistance with creating one? Accessiblü offers expert VPAT development services with our direct-to-expert model. Contact us to learn how we can help document your product’s accessibility in a way that opens doors while providing a roadmap for continuous improvement.

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