A VPAT checklist for procurement officers: 20 checks

This is the short version. The reasoning behind each check is in How to read a VPAT; this VPAT checklist is for the moment a report is open on your screen and you need to work through it in order. It applies to any Accessibility Conformance Report built on the ITI VPAT 2.5 template, in any edition.

Some checks come from the template itself. ITI's instructions for VPAT 2.5Rev list content every report must contain, and say that authors who deviate from those essential requirements may not call the result a VPAT. Others are good procurement practice. Both are marked.

Part 1: Is this the right document?

These checks can invalidate a report before you read a single row.

1. Edition matches your solicitation. WCAG, Section 508, EU (EN 301 549) or INT. An INT report answers a WCAG requirement; a WCAG report does not answer a Section 508 requirement. Practice. See which edition to require.
2. WCAG version matches. The report must state which WCAG versions it covers. If you require WCAG 2.1 Level AA, which is the ADA Title II standard, a WCAG 2.0 report is short. If you require 2.2, a 2.1 report is short by nine criteria. Template requires the statement; the match is practice.
3. Product name and version match what you are buying. The template requires the product name "including product version identifier if available". A report for an older release, or for the vendor's other product, is about different software. Template.
4. The report is dated. At minimum a month and year. Template. Then judge whether it is current: was it written for this release, and within roughly the last year? Practice.
5. Scope is clear. The product description and notes should say what the report covers and what it does not: the public-facing portal and the admin console, the web product and the mobile apps. If the product is split across several reports, the template requires each to say so in its Notes. Template, for multiple reports.

Part 2: Is the header complete?

6. Evaluation methods are described. The template requires them. Look for whether testing was manual, automated or both; which assistive technologies and browsers were used; and who tested. "Evaluated using industry-standard tools" is a description of nothing. Template requires a description; the detail is practice.
7. Terms are defined. The report must list the definitions of the conformance values it uses. If the vendor changed ITI's definitions, the template requires the change to be noted. Template.
8. There is a contact. An email address for follow-up questions is the minimum. You will need it. Template.

Part 3: Is every criterion there?

9. Count the rows. When a report covers a level, the template requires every criterion at that level to be answered for the WCAG version reported. Level AA conformance includes Level A: 50 criteria in WCAG 2.1, 55 in WCAG 2.2. Fewer rows means something is unaccounted for. Template.
10. Every row has a conformance value. Supports, Partially Supports, Does Not Support or Not Applicable. A blank value is not a pass. Template.
11. "Not Evaluated" appears only for Level AAA. ITI permits it nowhere else. On an A or AA criterion it means nobody checked. Template.
12. For Section 508 or INT reports, the non-WCAG chapters are answered. Functional Performance Criteria (Chapter 3), Hardware (Chapter 4), Software (Chapter 5) and Support Documentation and Services (Chapter 6) should be answered. A section that does not apply may be removed or summarized, but the template requires an explanation of why. Template.

Part 4: Do the remarks support the claims?

13. "Partially Supports" and "Does Not Support" are explained. ITI's instructions say the remarks should identify the functions or features with issues and how they fall short. A bare "Partially Supports" fails the template on its own terms. Template.
14. "Not Applicable" is justified. The template says: if the criterion does not apply, explain why. "No pre-recorded video in the product" beside 1.2.2 Captions is a justification. A blank beside it is not. Template.
15. "Supports" describes a mechanism. "All form fields have programmatic labels; errors are announced via a live region" is evidence. "Supports" with nothing beside it is an assertion. The template asks for remarks to justify the answer; the habit of reading them closely is practice.
16. No Level A gaps, or every one is accounted for. Level A is the floor. Any Level A criterion that is not "Supports" is the headline finding, ahead of any total. Practice.
17. Claims do not depend on a widget or overlay. If remarks or evaluation methods lean on an accessibility toolbar or remediation script, ask for the product's conformance without it. Practice. See accessibility overlays.
18. Alternatives and workarounds are described. If an accessible alternative is used, the template requires it to be described. Known workarounds and dependencies (supported browsers, operating systems) belong in the remarks. Template for alternatives; the rest is ITI best practice.

Part 5: What happens next?

19. There is a plan for the gaps. Every "Partially Supports" and "Does Not Support" on a criterion you care about should map to a remediation commitment: the fix, the release, a date. The VPAT template does not require a roadmap, so you may need to ask for one separately. Practice. See when a vendor cannot fix it.
20. Your questions and the vendor's answers are on file. For each gap worth raising, ask in writing for the testing evidence, a remediation date or a justification, and keep the reply with the report. Practice.

Using the VPAT checklist results

Very few reports pass all twenty. That is normal, and it is not a reason to reject a product. What the checklist gives you is a specific list of follow-up questions instead of a general unease, and a record of what you checked.

A rough triage:

Finding	Typical response
Wrong edition, wrong product, wrong version	Ask for the correct report before evaluating further
Missing rows, blank values, unexplained "Partially Supports"	Ask the vendor to complete the report
Level A gaps in workflows the public uses	Remediation plan with dates; consider whether it is a blocker
Level AA gaps with explanations	Remediation plan; note in the file
Thin evaluation methods	Ask how the product was tested and with which assistive technology

A VPAT is the vendor's own disclosure, and the checklist does not turn it into proof. It tells you whether the disclosure is complete enough to rely on, and where to press. For how the standard and the editions fit together, see What is a VPAT?.

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Sources: ITI VPAT 2.5Rev template instructions (WCAG edition, April 2025), "Essential Requirements for Authors" and "Best Practices for Authors"; W3C WCAG 2.1 and 2.2; 28 CFR part 35, subpart H (the DOJ's 2024 Title II web rule, WCAG 2.1 Level AA).

GOVvpat works through every one of these checks on each vendor report and returns a dated assessment for the procurement file. Request a quote.