Reporting Conformance to ICT Accessibility Standards
A practical approach to public and private sector ICT acquisitions
July 17, 2019 (updated October 23, 2023)
In light of the growing demand for information and communications technology (ICT) products withaccessible features, manufacturers are increasingly being required to declare whether a product orservice fully “conforms” with specific accessibility standards or “complies” with specific regulations.
Technical specifications such as the U.S. Section 508 accessibility standards, ETSI EN 301 549 V3.2.1,
and the W3C Web Content Accessibility Guidelines 2.x (WCAG 2.2, WCAG 2.1, WCAG 2.0, or ISO/IEC40500), are growing in influence, with some version of WCAG used as the basis of web accessibility rules
and regulations worldwide. Requests for conformance information occur in a variety of situations, suchas during bidding on contracts/tenders or assessments of manufacturer compliance with government
regulations.
Manufacturers are often asked to confirm accessibility compliance via a simple “yes/no” or “pass/fail”
response, rather than via submission of a detailed conformance report. This is troubling, because itignores the complexity involved in conforming to accessibility standards.
The latest accessibility standards, such as Europe’s ETSI EN301 549, can create significant challenges fordesigning, coding, and testing for accessibility, particularly in the case of complex enterprise-classproducts, applications, or web sites with thousands or perhaps millions of pages or lines of code. Suchproducts and related content are typically created by developers in multiple locations, and then are
customized by the purchaser or perhaps a third party. Hardware and software configurations canchange continuously. Web-based applications and software-as-a-service are often deployed using a“continuous delivery” model where development and test cycles may last only a few weeks or days. This
complexity and constant change pose a significant challenge for assessing conformance withaccessibility requirements. While a fully accessible product or web site is a laudable goal, it does notreflect reality.
What is driving the growing trend toward pass/fail evaluations? Perhaps one of the triggers is the WCAG
2.x “Conformance Requirements” and “Conformance Claims,” which use phrases such as “met in full” or“satisfies all...Success Criteria,” and “Conformance (and conformance level) is for full web page(s) only,
and cannot be achieved if part of a web page is excluded.” Such criteria create the assumption that
content and applications can be rendered in a fully accessible manner on a continual basis. Moreover,this approach implies that a web site that fails to meet a single criterion, however minor, is as
inaccessible as a site where none of the criteria are met.
We believe that the best way to characterize conformance to an accessibility standard is by addressing
the “degree of conformance.” This metric, also referred to as “best meets,” was introduced by the U.S.
General Services Administration (GSA) with the publication of the initial Section 508 standards. The
approach encouraged manufacturers to provide detailed standards conformance information on acriterion-by-criterion basis, enabling prospective purchasers to evaluate whether a product may still
meet essential accessibility objectives even if it is not fully conformant with technical requirements. This
flexible approach is important for a number of reasons:•••••••The presence of defects does not always constitute “failure.” Not all users use all features ofapplications or web sites. With the most complex enterprise-class applications, few customers
even use a majority of features that are typically provided.
Not all standards and defects are equal. In fact, some “defects” have absolutely no negative
impact on accessibility (e.g., non-unique IDs on a web page for controls that are not a direct partof the user interface).
Despite vast improvements in the wording of accessibility standards like WCAG 2.x, many
standards still leave much room for interpretation. A detailed accessibility statement allows anorganization to fully describe what was implemented and how it was tested for eachrequirement.
Some regulations, such as those implemented in conjunction with the Section 508 standards,require procurers to purchase the product that “best meets the standards” (see clause E202.7).
There is no way to accurately determine which product best meets the standards if eachmanufacturer can only respond with a “yes/no” answer.
In the case of a customer-licensed authoring tool for creating web sites and applications, aconformance statement may also include information about the tool’s output. This information
can only describe what the tool is capable of producing, not what the output actually conforms
to, because that is a function of how the tool is used.
If accessibility conformance statements provide only “yes/no” answers, it may cause
manufacturers to only focus on “passing the test” and thereby have the unintended
consequence of removing any incentive to create novel solutions that provide a positive user
experience for persons with disabilities.
Products and services may rely on advanced technologies such as AJAX (Asynchronous
JavaScript and XML) and WAI-ARIA (Web Accessibility Initiative - Accessible Rich InternetApplications) to address accessibility criteria. Knowing if and how a technology was used toaddress each criterion may inform the reader of the appropriateness of a solution for aparticular task or environment, the choice of browsers and assistive technology, and training
requirements.

The Voluntary Product Accessibility Template® (VPAT®) is widely used for reporting accessibility
conformance to Section 508, and addresses all of the issues above. The VPAT was developed jointly by
the Information Technology Industry Council (ITI) and GSA to assist Federal Government contracting
officials and other buyers in making preliminary assessments regarding the availability of commercial ICT
products and services with features that support accessibility. The VPAT allows a manufacturer to reporton a provision-by-provision basis how well Section 508 is met (or can be met), to provide remarks that
document detailed information such as implementation and testing performed, and to describe known
defects (if any). More information about the VPAT is available athttps://www.itic.org/policy/accessibility/vpat.
The VPAT, used by public and private sector purchasers in the United States and beyond, has proven tobe a highly effective way to report accessibility conformance, providing a prospective purchaser with anaccount of the product’s accessibility status and other useful information to help them make an
informed decision. The format of the VPAT readily lends itself to describing conformance with a varietyof standards, as well as adapting to a broad range of information technology such as web pages,software, hardware, and documentation.
ITI has updated the VPAT to cover WCAG 2.0, WCAG 2.1, WCAG 2.2, ETSI EN 301 549 V3.1.1 and V3.2.1,and will continue to maintain the VPAT with the latest version of relevant standards as they emerge. We

welcome the opportunity to discuss how the VPAT can help procurers to assess and compare theaccessibility features of ICT products and services.
For more information, please contact Megan Petersen, Senior Director of Policy, Public Sector andCounsel at mpetersen@itic.org.