Digital Accessibility: The Importance of the VPAT

Published September 18, 2020

A company’s products must be accessible to individuals with disabilities to be compliant with established federal laws and guidelines.

What is a VPAT?

A VPAT, or Voluntary Product Accessibility Template, is a document that allows a company to analyze how accessible its digital properties (electronic content, hardware, software, support documentation) are to persons with disabilities, based on the Revised Standards set forth in Section 508 of the Rehabilitation Act of 1973 (Section 508). The VPAT allows a company to provide a comprehensive analysis of its conformance to Section 508, as the template outlines Section 508’s key accessibility requirements and gives companies an opportunity to explain their conformance to each individual criterion.

In the table fields of the VPAT, a company provides specific details as to how the features and functionality of their products meet each technical requirement of accessibility standards, including Section 508, the Web Content Accessibility Guidelines 2.0 (WCAG 2.0 or ISO/IEC 40500), the Web Content Accessibility Guidelines 2.1 (WCAG 2.1), or EN 301 549 for companies that sell into Europe or Australia.

Overall, the VPAT format outlines the digital accessibility functions of a company’s digital properties, while also showing that the company has taken all necessary steps to ensure that its’ products are fully accessible to persons with disabilities.

VPATs are available in a company’s procurement office, and are distributed by the company’s procurement officer.

Why are VPATs used?

Buyers and other contracting officials use a VPAT, which was created by the Information Technology Industry Council (ITIC), to determine how accessible a company’s products are, and to determine whether or not the products contain any deficiencies. The VPAT, given its’ detailed, criterion-by-criterion framework, allows buyers and contracting officials to more easily make preliminary assessments on a company’s information technology (IT) products and service offerings. VPATs are oftentimes a major component of a company’s Request for Proposal (RFP) process (the process by which companies show interest in procuring a product, service, or valuable asset, and ask for bids from potential suppliers to procure these products, services and/or assets).

The VPAT is extremely relevant to any company that is a provider of electronic information technology (EIT) that can or will be used by federal workers. Section 508 mandates that all products used by federal employees must be compliant with its’ listed Standards.
Section 508 applies to a broad range of companies and products. As long as a company’s products are being used by someone directly or indirectly funded by the federal government, that company, by extension, is also federally funded, and Section 508 could apply to it. With this being said, it is very likely that many companies are losing potential business by not being compliant with Section 508, or by not preparing a VPAT that properly (adequately) outlines their compliance.

Buyer vs Seller responsibilities

If a buyer requests to see a company’s VPAT for a particular product/collection of products, the company must provide this information to the buyer. Both buyers and sellers share responsibility for ensuring that a company’s products are accessible to persons with disabilities. How so?
A buyer must exercise due diligence in requesting to see a company’s VPAT, as this will allow him or her to gauge how compliant a company’s products are to federal accessibility standards. Buyers like to take a company’s VPAT at face value (trust that the document is a true and accurate reflection of the accessibility of a company’s digital properties), but they should evaluate the document closely enough to feel that they are making an informed (and safe) decision.

Likewise, a company has a responsibility to honestly, accurately, and fully disclose all information relating to the accessibility (or lack thereof) of its’ products. Companies do not like to admit when their products contain deficiencies (even minor deficiencies or deficiencies that the company is working on), as these disclosures could hinder, or outright halt, their sales. Despite this risk, however, companies have a duty to be completely transparent as to the accessibility of all of their products. The customer comes first.

The best way to ensure that both the buyer and company are happy is for both sides to make a commitment-companies agree to be honest in their disclosures, and buyers agree to exercise due diligence in assessing the accessibility of a company’s products, such that compliant companies are not penalized. As the old saying goes, teamwork is dream work.


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