Introduction to Accessibility Conformance Reports

Posted on Friday, 15 October 2021 by Graeme Coleman in Standards, Testing

An Accessibility Conformance Report (ACR) is a document that formally summarises the extent to which an information and communications technology (ICT) product or service conforms to an agreed set of international accessibility guidelines and standards.

Typically, an ACR will document a product or service's conformance to the Web Content Accessibility Guidelines (WCAG) 2.2, but it is often also used to show conformance against the Revised 508 standards (for products and services sold in the US) and EN 301 549 (for products and services sold in the European Union). Read our WCAG Primer to learn more about the Web Content Accessibility Guidelines.

Why might I need to produce an ACR?

ACRs are commonly used as part of the procurement or tendering process. Buyers of the product or service can use the ACR to compare compliance levels between competing suppliers in order to make the choice that best meets their requirements.

ACRs are not mandatory per se, but certain organisations will not enter into agreements to purchase the related product or service unless an associated ACR is available. In particular, an ACR is often required for products and services sold to:

• State governments
• Government agencies
• Non-governmental organisations who otherwise receive government funding

Even non-governmental organisations may require you to provide an ACR. Examples include:

• Private schools/universities soliciting bids for a new virtual learning environment (VLE)
• Online stores soliciting bids for a new content management system
• Large companies soliciting bids for videoconferencing software

Therefore, it is good practice to have an ACR for each of your ICT products and services in case an opportunity arises for you to market them to organisations of the above types in the future. Additionally, even if an ACR is not required as part of the procurement process, providing one can show your commitment to making sure that your product or service is available to as wide an audience as possible - and to concede where you need to improve. ACRs are not set in stone - if you improve the accessibility of your product over time, then you can always revisit and update your ACR accordingly.

What types of products and services are covered by an ACR?

In short, most ICT products or services are subject to an ACR. The following list includes a few examples, although there are many, many more.

• Electronic content such as a website, web application, PDF document, or web-based authoring tool
• Software (open) such as a desktop application, native mobile application (including authoring tools in each of these environments), video communication software, or assistive technology software
• Hardware such as a kiosk, mobile phone, or peripheral device
• Support documentation and services such as manuals, help documentation, contact information

How is an ACR structured?

An ACR is based on a formal template known as a Voluntary Product Accessibility Template (VPAT). Note that the term "VPAT" is often used interchangeably with "accessibility conformance report", even though a VPAT specifically refers to the report's template rather than its contents (and is a registered trademark).

The VPAT is available as a Word document, but the related report can be presented in whichever format you prefer - such as Word, PDF, or even as an HTML page on the product's website.

The ACR is broken up into the following sections:

1. Product/service summary - this section includes a short description of the product or service, the ACR's publication date and version number, contact information, and the evaluation methods used to produce the results within the ACR.
2. Applicable standards/guidelines - the accessibility standards/guidelines that the product or service is intended to conform to.
3. WCAG 2.x report - the extent to which the product or service conforms to WCAG. The vast majority of ICT products or services are subject to this section. This section is further broken up into three subsections - WCAG Level A, WCAG Level AA, and WCAG Level AAA.
4. Revised Section 508 report - the extent to which the product or service conforms to Revised Section 508. Reporting conformance against this standard is normally required for products or services used by government agencies in the USA. This section is broken up into four "chapters", each of which matches up directly with the equivalent chapter in the related standard.
5. EN 301 549 report - the extent to which the product or service conforms to EN 301 549. Reporting conformance against this standard is normally required for products or services used by government agencies in the European Union. Similarly to the previous section, this section is broken up into ten chapters, each of which matches up directly with the equivalent chapter in the related standard.
6. Legal disclaimer - your company's legal disclaimer, if required.

Each of the relevant standards are further separated out into individual tables made up of three columns covering:

• Individual criteria in each standard
• The extent to which the product or service meets individual criteria (known as the conformance level)
• Supporting remarks and explanations

There are five possible conformance levels:

• Supports: All of the content and functionality within the product or service meets the related success criterion. For example, all images are provided with appropriate text descriptions, or all functionality is keyboard accessible.
• Partially supports: Some content and functionality within the product or service does not meet the related success criterion. For example, most images are provided with appropriate text descriptions, but some text descriptions are missing, or most of the product's functionality is keyboard accessible, but one of the widgets cannot be operated without using a mouse.
• Does not support: The majority of the content and functionality within the product or service does not meet the related success criterion. For example, most images are missing appropriate text descriptions, and most functionality relies on mouse operation.
• Not applicable: The related success criterion is not relevant to the product or service. For example, success criteria related to video content is not relevant if the product does not include any video content, or if the product is a non-interactive document, then success criteria related to keyboard access are not relevant.
• Not evaluated: The product or service has not been evaluated against the related success criterion. For example, if a product has only been assessed against WCAG 2.2 Level A and Level AA, then the conformance level is set to "not evaluated" on all Level AAA success criteria.

The following table demonstrates how conformance against the first two WCAG Level A success criteria may be recorded in practice.

It is important to note that, depending on the applicable standards and guidelines, and the type of product or service, certain sections within the ACR can be skipped entirely. For example, if your product or service is not available within the European Union, tables related to EN 301 549 do not need to be completed. Similarly, if your product is a web-based application that only runs in the browser and does not require documentation or additional support services, then it is normally not necessary to complete tables related to software and support documentation.

I think I need an ACR - how can TetraLogical help?

At TetraLogical, every member of our team has extensive experience producing ACRs for a wide range of ICT products and services.

We begin by agreeing the applicable international standards and guidelines based on your needs, and where your (potential) customers are located. We also determine which sections of the VPAT need to be completed based on the type, functionality, and features of the product or service.

We then formally assess your product or service against the agreed international standards and guidelines using a blend of inspection tools, manual testing, and usability verification with assistive technologies. The results of this assessment will then form the basis of the ACR. At this stage, you can choose to release the ACR "as is".

If you have agreed to a retest to be conducted at a later date, we can also update the ACR to reflect the results of our retest.

Next steps

Find out more about the European Union Public Sector Accessibility Regulations and how assessments can help you identify issues in your websites, mobile applications, design systems, and other products and services.

Updated: 12 December 2023