ACR Desk

Questions · Deadlines and legal requirements

Is a VPAT required by law, or is it really voluntary?

The template is optional; the report often isn’t. GSA says using ITI’s VPAT® form is not required, but federal agencies must buy accessible technology and, without an Accessibility Conformance Report, “the government may not proceed with the purchase.” Under the ADA Title II rule, a public university or city can make one a condition of its contract.

Selling to federal agencies

GSA’s vendor FAQ answers the question head-on: “While the use of the VPAT® itself is not required, it is not voluntary to complete an ACR if you wish the government to consider purchasing your product.” Only the government — “never a vendor” — can claim the special exception that removes the requirement.

GSA’s guidance to agencies tells them to require, for each commercial product, an ACR, a Supplemental Accessibility Report and GSA’s Issue Detail Supplement, and says the ACR must be complete to be considered for award.

Selling to states, cities and public universities

The ADA Title II rule sets a standard, not a document: 28 CFR 35.200 requires WCAG 2.1 Level A and AA for web content and apps, including licensed ones, and does not mention a VPAT® or an ACR. The public entity carries the obligation, and DOJ lists requiring detailed accessibility information from vendors before signing as a practice some entities found helpful.

Higher education adds a questionnaire. The HECVAT, published by EDUCAUSE, asks for a link to your accessibility statement or VPAT (ITAC-05) and whether your VPAT or ACR was created or updated for the version under consideration within the past 12 months (ITAC-06).

Private buyers

A company can make an ACR a condition of its own purchase. That is a term of the deal rather than a legal requirement on you, but it has the same effect on the sale.

How ACR Desk handles this

When a buyer has asked, we write the ACR on ITI’s template in the edition the request calls for: WCAG ($1,490), or Section 508, EU or INT ($1,990), fixed, in five business days. You review it and publish it under your name.

VPAT® for SaaS Free accessibility snapshot

Last reviewed: October 29, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.

Sources

Primary sources only. Each was read on October 29, 2026.

  1. Accessibility Conformance Report/VPAT® Frequently Asked Questions — Section508.gov, GSA (reviewed/updated June 2026).
  2. Request Accessibility Information from Vendors and Contractors — Section508.gov, GSA.
  3. 28 CFR 35.200 — Requirements for web and mobile accessibility (ADA Title II) — eCFR, current text.
  4. First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule — ADA.gov, Department of Justice (updated after the April 2026 extension).
  5. Higher Education Community Vendor Assessment Toolkit (HECVAT 4, current version 4.1.6) — IT Accessibility questions ITAC-01 to ITAC-18 — EDUCAUSE.
  6. VPAT® — current version 2.5Rev (April 2025), four editions, FAQs — Information Technology Industry Council (ITI).