WebInclusiveby Giuseppe Stumbo

ACR and VPAT: completion, standards and examples

Distinguish VPAT from ACR, choose an edition and document results and scope with worked examples.

ACR: what to understand before completing it

VPAT is the template; the ACR is the document completed for your product.

  • Format

    VPAT is the blank template; ACR is the completed document

    VPAT (Voluntary Product Accessibility Template) is the template published by ITI, in version 2.5Rev. When completed with data and evaluation results for a specific product, the resulting document is called an ACR (Accessibility Conformance Report). The terms are often confused: the template is used to compile information, while the report communicates results.

    • ITI publishes and maintains the VPAT template.
    • An ACR records the product name, version, date and evaluation methods used.
    • An ACR does not replace the accessibility statement required in Italy or the information required for services subject to the EAA.
  • Editions

    The four official editions: WCAG, 508, EU and INT

    ITI publishes four editions of the VPAT 2.5Rev template, with different requirement tables. The choice depends on the market, client requirements and the versions of the standards to document, rather than solely on where the supplier is based.

    • WCAG edition: WCAG criteria for technical requests independent of a particular national market.
    • 508 edition: Section 508 requirements for US federal procurement.
    • EU edition: EN 301 549 criteria for European requirements referring to the standard. Check the version included in the template against the specification.
    • INT edition: includes WCAG, Section 508 and EN 301 549 tables for documenting multiple references in one report.
  • States

    Conformance levels and the limited use of Not Evaluated

    The ITI template defines four conformance levels and permits Not Evaluated only for WCAG AAA criteria. These labels describe support for a requirement, rather than defect severity or remediation priority.

    • Supports: at least one method meets the criterion without known defects, or equivalent facilitation is provided under the template instructions.
    • Partially Supports: some functionality does not meet the criterion; a remark explaining what is missing is always required.
    • Does Not Support: most functionality does not meet the criterion.
    • Not Applicable: the criterion does not apply to the product, for example when there are no videos with prerecorded audio for caption criterion 1.2.2.
    • Not Evaluated: may be used only for WCAG AAA criteria, rather than leaving applicable A or AA criteria unevaluated.
  • Notes

    Without Remarks and Explanations, the stated level cannot be verified

    The instructions require Remarks and Explanations for Partially Supports and Does Not Support, and also recommend notes for Supports. Explain the verified behaviour and justify any non-applicability, rather than simply repeating the label.

    • Identify the components, pages or journeys involved, rather than only the WCAG criterion.
    • Separate known technical limitations from deliberate scope exclusions.
    • Avoid unverifiable remarks such as “being improved” without further detail.

Example: the same row written poorly and well

Illustrative example, not a real report. It shows the difference between a generic and a verifiable remark.

  • 1.4.3 Contrast (Minimum)

    Declared support level
    Partially Supports
    Weak remark
    Improvements in progress.
    Verifiable remark
    Body text and primary buttons meet the requirement (at least 4.5:1). Footer links in the dark theme are at 3.8:1: fix in backlog. Tested in Chrome and Firefox on desktop.

  • 2.1.1 Keyboard

    Declared support level
    Supports
    Weak remark
    Conforms.
    Verifiable remark
    All functions in the evaluated flows (search, basket, checkout) are usable with a keyboard. The product described in the ACR is the public storefront; the administrative editor belongs to a separate product and is not evaluated in this report.

  • 3.3.1 Error Identification

    Declared support level
    Does Not Support
    Weak remark
    Not applicable to forms.
    Verifiable remark
    In the contact, registration and checkout forms, which cover most of the product's data-entry functions, detected errors are indicated only by a red border, without identifying the field and describing the problem in text. Tickets are open; retesting is to be performed after fixes.

Which standard applies to what

Technical requirements, legislation and documents serve different purposes. Always state the applicable reference and the version used in the assessment.

  • WCAG 2.2

    What it covers
    W3C technical standard with levels A, AA and AAA for web content.
    Who it applies to
    Anyone designing, developing or assessing web content: businesses, public administrations, agencies and suppliers. Obligations depend on the legislation or contract referring to a WCAG version and level; the standard itself does not identify which businesses are obliged to comply.
    In documents
    ACR criteria, WCAG edition.

  • EN 301 549

    What it covers
    European standard for ICT products and services, with requirements beyond WCAG. Version 3.2.1 references WCAG 2.1 A and AA; v4.1.1, published in September 2026, references WCAG 2.2 A and AA.
    Who it applies to
    Organisations and ICT suppliers when legislation, specifications or contracts refer to EN 301 549. For example, a software company supplying an app to a public administration. Being based in the EU alone does not impose all requirements of the standard on every business.
    In documents
    ACR criteria, EU edition.

  • EAA (EU Directive 2019/882)

    What it covers
    Accessibility requirements for specific products and services, including e-commerce, consumer banking services, e-books and certain elements of passenger transport services.
    Who it applies to
    Providers of services listed in the directive, such as online sales to consumers and private banking services, and manufacturers, importers or distributors of covered products. In Italy, the reference is D.Lgs. 82/2022. Microenterprises providing services are exempt; products have a separate regime.
    In documents
    Defines requirements and documentation obligations; ACRs and Allegato 2 do not automatically replace the information required for the service.

  • Legge 4/2004 and AgID guidelines

    What it covers
    Obligations for entities identified by the law, with specific regimes for public administrations and private entities.
    Who it applies to
    Public administrations and other entities under art. 3, comma 1, including public-service concession holders and bodies governed by public law. Comma 1-bis instead concerns private entities offering services to the public through websites or apps with average turnover exceeding EUR 500 million over the last three years; for EAA services, AgID's clarification on the information regime applies.
    In documents
    Public administrations: self-assessment and statement through AgID. Private entities under art. 3, comma 1-bis: dedicated model, except for services covered by D.Lgs. 82/2022.

  • Section 508 — US federal agencies and ICT suppliers

    What it covers
    Accessibility requirements for ICT developed, procured, maintained or used by US federal agencies.
    Who it applies to
    US federal agencies; ICT suppliers must meet the requirements specified in the supply contract. This does not automatically concern every business operating in the United States.
    In documents
    The 508 edition of VPAT documents Section 508; it is not a general attestation of ADA compliance.

  • ADA — US state and local entities and public accommodations

    What it covers
    Anti-discrimination obligations concerning access to services, programmes and activities, including those offered online.
    Who it applies to
    Title II: US state and local entities. Title III: public accommodations, such as shops, banks, hotels, restaurants, healthcare facilities and theatres. The ADA has a different scope from Section 508; establish which title applies to the entity and service.
    In documents
    An ACR can collect technical evidence, but a 508-edition VPAT is not a general attestation of ADA compliance.

EN 301 549: what to know before citing it

The European ICT accessibility standard, also used in the EU edition of VPAT. In documents, state the evaluated version and distinguish technical publication from citation as a harmonised standard.

  • Versions

    Published version and harmonised reference are different

    EN 301 549 v3.2.1 (2021) is cited in the Official Journal of the EU in support of the directive on the accessibility of public sector websites and apps. Version 4.1.1, published in September 2026, adopts WCAG 2.2: its publication does not amount to citation as a harmonised standard for the WAD or EAA.

    • Always state the version and date of the standard used in documents.
    • Check the relevant citation, covered requirements and any transitional periods: presumption of conformity concerns the requirements covered by the cited standard, not every service obligation.

  • Structure

    The clauses needed for web content, documents and software

    The standard is organised into clauses: 9 concerns web content, 10 non-web documents, 11 software and apps, and 12 documentation and support services.

    • For a website, start with clause 9; for a native app, clause 11.
    • Other clauses cover hardware, real-time communication and video if the product includes them.

  • WCAG 2.2

    What changes in v4.1.1

    Version 4.1.1 moves from WCAG 2.1 to WCAG 2.2 for A and AA criteria: it incorporates six new success criteria and removes the obsolete 4.1.1 Parsing. WCAG 2.2 adds nine criteria in total, including three AAA criteria. The standard also introduces an annex mapping requirements to the European Accessibility Act.

    • Those who have already assessed against WCAG 2.2 are closer to the new version.
    • For ongoing audits, declare which version of the standard was used.

  • Documents

    How to cite it in an ACR and Allegato 2

    In an ACR, the EU edition of VPAT uses EN 301 549 criteria; in AgID Allegato 2, the standard appears among the self-assessment references.

    • State the standard version, date and tested scope.
    • Do not claim conformance with v4.1.1 until its criteria have been assessed.

Official sources

Legislation, models and instructions to consult when completing the documents.