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Understanding Vendor Claims in Accessibility Conformance Reports for Section 508 Conformance

In the modern digital landscape, it is critical that the federal government ensures equal access to information and services for all individuals, regardless of disabilities. The United States government recognized this importance by enacting Section 508 of the Rehabilitation Act, which mandates that federal agencies procure and use accessible information and communication technology (ICT) products and services. Vendors typically provide Accessibility Conformance Reports (ACRs) by completing a Voluntary Product Accessibility Template (VPAT®) to communicate the accessibility status of their products. These ACRs typically use terms like “supports,” “partially supports,” and “does not support” to describe a product’s conformance with Section 508 standards. The information below discusses what these terms mean and how purchasers can interpret them.

1. Supports

When a vendor claims that a product “supports” Section 508, it implies that the product is designed and developed with accessibility in mind and fully conforms with the relevant accessibility standards. In this context, “supports” indicates that the product is accessible to people with disabilities, and it should work seamlessly for users relying on assistive technologies such as screen readers, voice recognition software, or alternative input devices. A product that fully “supports” Section 508 is generally a safe choice for organizations seeking to meet accessibility requirements.

2. Partially Supports

A vendor may state that their product “partially supports” Section 508. This indicates that while the vendor has made efforts to address accessibility concerns, some aspects of the product may not meet the full accessibility requirements. In other words, the product does not conform to Section 508 standards. It is crucial for purchasers to examine the ACR in detail to understand which specific aspects of accessibility are partially supported and which ones are not. This information can help organizations make informed decisions to determine whether the product’s accessibility features align with their specific needs and the needs of their user base. Products labeled as “partially supports” may require additional accommodations or user training to ensure accessibility.

3. Does Not Support

When a product is marked as “does not support” Section 508, it means that the vendor has not incorporated accessibility features or has made minimal efforts to conform with accessibility standards. “Does not support” can also be interpreted to mean that the product does not conform to the Section 508 standards. Purchasers should exercise caution when considering such products, especially if they plan to use them in a government or federally funded context where Section 508 conformance is mandatory. In cases where a product “does not support” accessibility, organizations may need to invest significant resources in retrofitting or finding alternative solutions to meet accessibility requirements.

4. Not Applicable

Sometimes, a vendor may indicate that a specific standard within the VPAT is “not applicable.” This means that the particular requirement in question does not apply to the product’s functionality or design. It’s essential for purchasers to review the ACR carefully to understand why a certain criterion is marked as “not applicable.” Common reasons for this designation might include the product not having certain features or functionalities relevant to that criterion. “Not applicable” should not be confused with non-conformance; it simply signifies that a specific aspect of the accessibility standard is not relevant to the product in question.

5. Not Evaluated

A note of “not evaluated” in an ACR indicates that the vendor has not conducted an assessment or evaluation of the product’s accessibility in relation to the particular Section 508 standards in question. This could mean that the vendor has not yet assessed the product for accessibility or has not included the evaluation results in the ACR. In such cases, purchasers should seek clarification from the vendor regarding their plans for accessibility evaluation and whether future assessments will be available. It is important to note that “not evaluated” does not provide any assurance of accessibility and should prompt further inquiries and considerations.

Verify Vendor Conformance Claims

Whenever possible, purchasers should conduct independent conformance validation testing and evaluation to verify vendor accessibility conformance claims. For Web-based products, purchasers can refer to the ICT Accessibility Testing Baseline for Web and consider using a “Baseline-aligned” test process, such as the Trusted Tester process (see Trusted Tester and ICT Testing Baseline).

Understanding vendor claims in ACRs regarding Section 508 conformance is essential for organizations aiming to provide equal access to digital information and services. Purchasers should always review ACRs thoroughly, seek clarification from vendors if necessary, and align their product choices with the specific accessibility needs of their user base and their agency’s compliance obligations under Section 508. By doing so, they can make informed decisions that promote digital inclusivity and accessibility for all.

Reviewed/Updated: September 2023

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