"Not Applicable" in a VPAT: when it is legitimate
Not Applicable in a VPAT is valid only with a reason. When it is correct, when it hides a gap, and how vendors should explain it in the remarks column.
"Not Applicable" in a VPAT is the conformance value that gets the least scrutiny. It looks like a non-answer, so reviewers skip past it, and that is exactly why it is worth reading carefully. Used correctly, it tells a buyer that a criterion has nothing to act on in this product. Used carelessly, it removes a criterion from consideration without anyone noticing.
What the template says
The ITI VPAT 2.5Rev template defines Not Applicable in one line: "The criterion is not relevant to the product." Its instructions for the Remarks and Explanations column add the part that matters: "If the criterion does not apply, explain why."
So a Not Applicable entry with a blank remarks field is incomplete on the template's own terms, in the same way an unexplained Partially Supports is.
Section508.gov's guidance on reviewing vendor claims makes the buyer's half of the point: it is essential to review the report carefully "to understand why a certain criterion is marked as 'not applicable'", and "not applicable" should not be confused with non-conformance.
Supports and Not Applicable can mean the same thing
There is a wrinkle that confuses buyers comparing reports. WCAG's own explanation of conformance says that if there is no content to which a success criterion applies, the criterion is satisfied. The ITI template follows that: in the WCAG tables, a vendor may use "Supports" where it might otherwise have used "Not Applicable".
In practice, then, two vendors with identical products may report 1.2.2 Captions (Prerecorded) differently: one says Not Applicable, the other says Supports, both with the remark "the product contains no prerecorded video". Both are permitted. Neither is better. What matters is the remark, not the value. A buyer should not count either one as a strength or a weakness, and a vendor should pick one convention and use it consistently.
When Not Applicable in a VPAT is legitimate
The test is simple: does the product contain the kind of content or functionality the criterion is about? If it genuinely does not, Not Applicable is correct. Typical legitimate cases:
| Criterion | Legitimately N/A when |
|---|---|
| 1.2.1 to 1.2.5 (audio and video) | The product contains no prerecorded or live audio or video |
| 1.4.2 Audio Control | Nothing plays audio automatically |
| 2.2.2 Pause, Stop, Hide | Nothing moves, blinks, scrolls or auto-updates |
| 2.5.4 Motion Actuation | No function is triggered by device motion |
| 3.1.2 Language of Parts | No passages are in a different language from the page |
| Section 508 Chapter 4, Hardware | The product is software only |
| Section 508 502 and 503 | A web-only application, as the ITI 508 instructions themselves note |
The last two rows come from the Section 508 edition, where the template allows a whole chapter or section that does not apply to be removed, provided the report explains why in the notes. Individual criteria cannot be removed; only whole sections, with a reason.
When it is misused
In the reports we review, misuse of Not Applicable tends to fall into a few patterns.
On criteria that apply to almost everything. Some criteria are relevant to nearly any software with a user interface. Not Applicable on 1.1.1 Non-text Content (any icon or image), 1.4.3 Contrast (Minimum) (any text), 2.1.1 Keyboard (any interactive control), 2.4.7 Focus Visible, or 4.1.2 Name, Role, Value should prompt an immediate question. So should 3.3.1 Error Identification and 3.3.2 Labels or Instructions on a product with forms, which is most products.
When the vendor means "we did not test it". That is not what Not Applicable means. The template's "Not Evaluated" value exists for untested criteria, and it may only be used for Level AAA. At Level A and AA, a criterion that was not evaluated is a gap and should be reported as one.
When the content exists, but the vendor thinks it is someone else's. A common case is media. A platform that lets customers upload video cannot caption those videos itself, and the vendor may mark 1.2.2 Not Applicable on that basis. But the platform still supplies the player, and whether the player can display captions is very much the vendor's responsibility. The accurate answer describes what the product supports ("the player displays caption tracks supplied with uploaded video; captioning uploaded content is the customer's responsibility") rather than declaring the criterion irrelevant. The same applies to the vendor's own help videos and tutorials: if they ship with the product, they are part of it.
When a feature is out of scope but not excluded. If a report quietly covers only the public-facing pages and marks criteria Not Applicable because the admin interface was not evaluated, the problem is the scope, not the criterion. Scope belongs in the Notes section, stated plainly, so the buyer knows what the report does not cover.
When it appears with no remark at all. Even where the value is right, a blank remark leaves the reader unable to tell a correct N/A from a convenient one.
How vendors should explain it
A good Not Applicable remark states the fact that makes the criterion irrelevant, specifically enough that a reader could check it. Compare:
| Criterion | Weak remark | Useful remark |
|---|---|---|
| 1.2.2 Captions (Prerecorded) | (blank) | The product contains no prerecorded video or synchronized media. Help content is text only. |
| 2.2.2 Pause, Stop, Hide | N/A | No content moves, blinks, scrolls or auto-updates. The dashboard refreshes only when the user selects Refresh. |
| 2.5.4 Motion Actuation | Not used | No functionality is operated by device motion or user motion. |
If the facts change, so does the answer. A product that adds a video tutorial library in its next release needs those 1.2.x rows revisited; see how often a VPAT should be updated. For remark patterns on other values, see VPAT remarks examples.
What buyers should do with it
When reading a report, give Not Applicable rows a quick pass of their own:
- Read each Not Applicable row and ask whether the product plausibly has that kind of content. You often know from the demo.
- Flag any Not Applicable on 1.1.1, 1.4.3, 2.1.1, 2.4.7, 4.1.2 or the form criteria.
- Flag any Not Applicable with no remark.
- Check the Notes section for scope statements that explain clusters of Not Applicable.
- Ask in writing for the reason behind each flagged row, and keep the answer.
How to read a VPAT puts this step in context with the rest of the review, and Supports vs Partially Supports covers the other three values.
Sources: ITI VPAT 2.5Rev template instructions (WCAG and Section 508 editions, April 2025); W3C, Understanding Conformance (WCAG 2.1); Section508.gov, Understanding Vendor Claims in Accessibility Conformance Reports.
GOVvpat flags unexplained and implausible Not Applicable claims in the reports your vendors submit. Request a quote, or if you are a vendor, have your report reviewed.