VPATs are not really for websites. They can be if the website is part of a product or service, or it is the product, but it is not, VPATs are not traditionally to be filled out for websites. So of course we know that VPATs are a template, the template that the Accessibility Conformance Report is based off of.
So when a VPAT is filled out and completed, it creates an ACR and many people want to know, or many people are using VPATs to create ACRs for websites, but that’s technically not correct. And so sharing the split screen with me, I have a document with a heading of VPATs, and let’s take some of the language directly from section 508.gov.
So if you are dealing with a federal agency, then you may be required to provide an ACR that accounts for the accessibility of your product or service. So on section 508.gov, it says a Voluntary Product Accessibility Template is a document that explains how information and communication technology, ICT products, such as software, hardware, electronic content, and support documentation may conform to the revised 508 standards for IT accessibility.
So notice that it said ICT products, but also notice that it said that ICT included electronic content. So if you look for electronic content examples, the first bullet point is websites and web-based content. And then there’s also documents, training materials, multimedia, et cetera. There’s even subscription services, such as news feeds, alert services, and professional journals.
So a VPAT may very well be filled out for a website, but keep in mind that for you to be technically aligned with what a VPAT is getting at, it needs to be a part of a product or service. So maybe the website is a platform that is a product, then the VPAT would be applicable. And of course, VPATs can go beyond just dealing with the federal government, but this is really where VPAT usage started out as is the federal government making sure they’re procuring accessible products and services.
And so section 508 is largely influential when it comes to VPAT usage. So continuing on from section 508.gov, it says government solicitations, which include ICT will specify accessibility requirements, indicating which provisions are necessary to ensure the deliverable is accessible. Notice the word deliverable. So this is not just for any website.
And then it goes on to say a VPAT is a good way to address the accessibility requirements defined in the solicitation. So again, it’s a product or service. So the government really wouldn’t be going and saying, hey, we’re soliciting your website. It’s going to be a part of a product or service if that’s the case.
So we recommend that vendors generate a VPAT for any ICT that’s intended to be marketed to the federal government. So if your website is intended to be marketed to the federal government, then it could be included within the scope. So next on the document, I have a subheading, ITIC.org, and this stands for Information Technology Industry Council, and they are the creators and the producers of the document, the VPAT template.
It says the accessibility conformance report based on the ITI VPAT is the leading global reporting format for assisting buyers and sellers in identifying information and communications technology, ICT products and services with accessibility features. So again, it’s products and services. So if your website is a part of a product or service, then it would be appropriate to have an ACR created for it.
So what can your product include? It can include documentation, support services, hardware, software, third-party products integrated into your product. So it may very well be that your website contains the documentation. In that case, you need to make sure that for at least the documentation portion of this, that accessing that documentation, the links to that documentation are accessible.
But broadly, of course, you want to make your website accessible anyways, but I wanted to address this because it is a question, and I keep hearing that people are asking for VPATs for websites. VPATs are not for just a website. Now, I can’t think of any reason why you couldn’t use one, but I don’t think people understand really what VPATs are for and the level of depth in a VPAT.
So a VPAT is not a certification by any means. A VPAT just merely addresses the accessibility of your product or service. It doesn’t mean that it’s completely accessible. There very well could be, and usually are, accessibility issues that exist. The VPAT is simply letting the different participants in the market know how accessible the product or service is, and if there are accessibility issues, which accessibility issues exist so that the product can be evaluated.
If your product or service does have accessibility issues, it doesn’t disqualify them from use, but it is taken into consideration when evaluating that product or service. So again, it’s not a certification. You have to remember, and it’s also not in depth, so you would need to audit a digital asset anyway to create the VPAT, so the audit would be much more in depth, but the VPAT’s not going to be a way to lower the cost.
You still have to, someone is going to have to evaluate your product or service. Now, when it comes to filling out the VPAT template, you want to have your own, you want to have your own team involved because they are familiar with the product or service, but you also need to have people who are proficient or have expertise in accessibility, and that’s where usually people source to third-party providers for that expertise and testing so that the VPAT can be tested potentially by people with disabilities using assistive technology.
But it can be a document that’s created in-house, but you just have to be aware that if you are limited in your knowledge in filling out the VPAT and assessing the product or service, then it’s going to be, it’s going to limit the helpfulness of the accessibility conformance report that is eventually created.
So are VPATs for websites? No, but they can be. They can be if the website is a part of the product or service. So for example, if the website is where the documentation for the product or service is, where the product or services documentation is housed, then you need to make sure that that documentation is accessible.
But what is happening in the marketplace is where people are just asking for VPATs for any website, and the website is not a product or service. Again, I don’t know why you couldn’t, but it’s really not what VPATs and ACRs are for. They are for products or services.
