ACR Desk

Questions · The VPAT® and the ACR

Can our ACR cover only part of our product, such as sign-up and checkout?

Yes, if the report says so: ITI’s template lets you state in the Notes what the report covers. But buyers judge the product they will use. From April 26, 2027 (2028 for smaller ones), public schools and universities must ensure that apps they provide through licensing meet WCAG 2.1 AA, so a sign-up-and-checkout ACR rarely answers their question.

What the template allows

ITI’s Essential Requirements set the minimum content of an ACR, including the product name and version, the report date, Notes, the evaluation methods used, the standards covered and a remark for every criterion. Its best practices suggest using the Notes for “additional information about what the document does or does not cover.”

Scope matters because the conformance terms describe the product: “Partially Supports” means “some functionality of the product does not meet the criterion.” A report on a few screens that does not say so reads as a statement about the whole product.

What WCAG and the W3C method add

  • Complete processes: when a page is one step of a process, every page of the process must conform. WCAG’s own example is an online store, from product selection to checkout.
  • WCAG-EM 2.0, the evaluation method published by the W3C’s Accessibility Guidelines Working Group, defines the scope as all views, states and functionality of a product, and warns that excluding specific parts would likely conflict with the full-page and complete-process requirements or distort the results.

So a narrower report is possible, but it should test each flow from start to finish and name what it leaves out.

What the buyer needs covered

Under 28 CFR 35.200(a), a public entity must ensure that the web content and mobile apps it provides “directly or through contractual, licensing, or other arrangements” are accessible, and 35.200(b) makes that WCAG 2.1 AA from April 26, 2027 or April 26, 2028, depending on the entity’s population. When a public school district licenses your app for students, the part students use is what it provides; an ACR on account creation and payment leaves that part unanswered.

How ACR Desk handles this

We agree the product, version and up to 15 screens or key flows in writing before testing, test every step of each agreed flow, and state in the report what was tested and what was out of scope. If your product can’t be represented fairly within that limit, the quote says so. $1,490 (WCAG edition) or $1,990 (Section 508, EU or INT), fixed, in 5 business days.

What counts as a screen or a key flow Free accessibility snapshot

Last reviewed: October 19, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.