Web Accessibility VPAT / ACR: What Are They? Differences Between Japanese Inspections and JIS Compliance

VPAT / ACR is a method used in the United States to demonstrate web accessibility conformance. What are the differences from testing and reporting conducted in Japan?

We explain the characteristics and differences from a practical perspective.

What are VPAT / ACR?

VPAT evolved from federal procurement requirements based on the US "Rehabilitation Act Section 508," and now offers versions that directly correspond to the international standard WCAG, making it a global standard for accessibility assessment. In the United States, driven by increased lawsuits against private companies under the ADA (Americans with Disabilities Act), many private companies have voluntarily begun issuing and publishing VPAT / ACR.

The Relationship Between VPAT and ACR

• VPAT (Voluntary Product Accessibility Template) = A format and template for accessibility assessment
• ACR (Accessibility Conformance Report) = An actual report created using the VPAT template

In other words, the relationship is "creating an ACR using the VPAT format." Recently, the term "ACR" has become the standard terminology.

US Culture: Why Certificates Are Avoided

In the United States, there is a tendency to avoid posting accessibility "certificates." This is because explicitly stating that a product is "compliant" increases the risk of legal liability if defects are later discovered. For this reason, the United States typically provides only "reports (ACR)" instead.

VPAT is self-assessment

VPAT is fundamentally self-assessment. Even when third-party verification is performed, the report is issued in the name of the site owner (product provider).

The core of VPAT is "transparency"

VPAT is not simply a judgment of "compliance" or "non-compliance." It is a document for "information disclosure" that describes in detail which features of a product are accessible and where limitations exist. By accurately disclosing current issues, it demonstrates a sincere commitment to adopting organizations and users, with the goal of building trust.

How to create VPAT / ACR

Created by product unit

In VPAT, the evaluation results of inspected pages are integrated, and the entire website is ultimately evaluated as a single "product." If it is one website, one report (ACR) is created.

How to define product scope

• Even on the same domain, separate systems (such as a public site and an admin panel) may warrant separate reports.
• Conversely, multiple domains using the same product may be consolidated into a single report.
• Landing pages (LPs) are often treated as separate products.

Evaluation method

VPAT evaluation is not simply about checking whether standards are met. The key point is "transparency"—revealing everything, including current issues.

Each item is evaluated on a 4-point scale below, with detailed descriptions of compliance status.

• Supports
• Partially Supports
• Does Not Support
• Not Applicable

Providing an honest, transparent report (ACR) that does not hide shortcomings is increasingly valued in modern global procurement as a reflection of corporate integrity.

Page Selection Method (Sampling Based on WCAG-EM)

In VPAT, pages are selected based on WCAG-EM (Website Accessibility Conformance Evaluation Methodology).

Page count guideline:

• A minimum of 5 pages can be evaluated, but this is not recommended due to low reliability (except for very small sites).
• In practice, 10-15 pages is standard.
• Even for large sites, approximately 20 pages is often sufficient.

Pages representing the "types (templates)" that make up the site—such as the homepage, article detail pages, forms, and search results—are selected as a "Structured Sample" (10-20 pages), and additional pages are randomly selected as a "Random Sample" to prevent oversights. Experts then conduct thorough checks.

① Structured Sample

Pages "intentionally selected" to cover the functions and types of the site. This is the main component.

② Random Sample

Pages selected randomly to prevent oversights. Aim for approximately 10% of the total pages being evaluated.

How to respond when issues are found on random pages

For example, if you find that images lack alt text on a randomly selected article page

• In the case of systemic defects (for example: the CMS is configured not to output alt attributes)

  → Evaluate as "Does Not Support" in the VPAT and document as a technical issue

• Operational errors (for example, an editor simply forgot to input alt text)

  → Rate as "Partially Supports" in VPAT, and describe it as "The CMS provides alt text functionality, but input omissions are observed in some content"

Selection examples by scale

Very small scale (single landing page, under 10 pages):

• Single landing page: Evaluate that page only as a single product
• Under 10 pages: Recommended to evaluate all pages. Or structured sample of 5-8 pages + random sample of 1 page

Small to medium scale (static corporate site, approximately 10-100 pages):

• Structured sample: 8-12 pages
• Random sample: 1-2 pages

Medium to large scale (dynamic sites, e-commerce sites, media sites, etc.):

• Structured sample: pages 15-18
• Random sample: 2 pages

Testing Methods and Reports in Japan

In Japan, JIS X 8341-3:2016 (equivalent to WCAG 2.0) has traditionally been the standard. However, in today's web environment, viewing on smartphones has become the norm, and WCAG 2.0 is increasingly inadequate in addressing emerging challenges.

The Public Website Operation Guidelines (2024 edition) by the Ministry of Internal Affairs and Communications also explicitly states, "In anticipation of future JIS revisions, construct sites based on WCAG 2.2 conformance criteria to the greatest extent possible."

Liberogic's accessibility audit service

At Liberogic, we use the latest WCAG 2.1/2.2 standards while basing our reporting format on a page-by-page evaluation approach that is familiar to Japanese companies.

Page selection method

Like VPAT/ACR, we select pages based on WCAG-EM. By combining representative templates with randomly selected pages, we efficiently and accurately evaluate the overall quality of your site.

Evaluation Process

We inspect each page individually and evaluate it against each success criterion.

• Each success criterion is evaluated on a three-point scale (conformant, non-conformant, not applicable)
• If any criterion is non-conformant, the page is marked as "non-conformant"
• If all success criteria are met, the page is marked as "conformant"
• Based on the results of all selected pages, we determine whether the site as a whole is fully or partially conformant

This evaluation method makes it immediately clear which pages have issues with which criteria

Deliverables: Test results list + certificate

In Japan, there is a strong emphasis on objective third-party evaluation. As a third-party testing organization, Liberogic issues a testing certificate to verify that we have conducted the inspection

Standard deliverables

1. List of pages tested (conformance/non-conformance status for each page)
2. Detailed evaluation report by page and success criterion
3. Third-party inspection certificate

Optional: Japanese VPAT / ACR for added value

In addition to the deliverables above, we can also create VPAT / ACR in Japanese.

Benefits of adding VPAT / ACR

1. Building trust through transparency

   Rather than a binary "compliant or non-compliant" assessment, we provide detailed disclosure of which features of your product support accessibility and where there are limitations. This honest approach to openly sharing current challenges—without concealing them—builds deep trust with both adopting organizations and end users.

2. Strategic use as a sales and bidding tool

   You can leverage it as part of your product specifications in implementation proposals and responses to RFPs (Requests for Proposal).

   • Combined with a page-by-page pass/fail list, a global standard assessment showing your product's overall compliance status enables more comprehensive quality assurance.
   • When bidding projects require "accessibility compliance status," this provides concrete evidence with strong persuasive impact.
3. Immediate readiness for global standards

   For foreign-affiliated companies and those planning global expansion, international standard ACME is a "common language."

   • When parent companies, overseas offices, or international clients request compliance submissions, you can respond immediately.
   • By evaluating against international standards from the outset, you can significantly reduce the cost and effort of re-testing when expanding overseas in the future.

Government projects requiring JIS compliance

We can also handle cases where compliance with JIS X 8341-3:2016 is required, such as in government procurement projects.

In that case, test target pages are selected based on WAIC's JIS X 8341-3:2016 Testing Implementation Guidelines.

Page selection for JIS compliance

Standard configuration example:

• Primary web pages: 20-30 pages (covering all templates)
• Random pages: 10-20 pages
• Total: 40+ pages

Why 40 pages are necessary

The primary goal is to build evidence for making a public conformance declaration regarding compliance with standards. Ideally, all pages should be audited, but for large-scale websites this is impractical. The WAIC testing guidelines therefore also present a sampling method using "representative pages + random pages," which has become the de facto standard. To ensure statistical reliability, a minimum number of pages (roughly 40+) is typically required.

WCAG-EM (approximately 10-20 pages), on the other hand, prioritizes understanding overall site trends and efficiently improving quality (quality management).

Unless JIS compliance is explicitly required (such as in public sector procurement), we recommend efficient auditing based on WCAG-EM standards.

Comparison of each method

Summary

Web accessibility evaluation in Japan uses two approaches: "VPAT / ACR" based on U.S. commercial practices, and an evaluation method derived from JIS standards.

• Global companies and foreign-affiliated enterprises: VPAT / ACR is mandatory
• Domestic public institutions and general enterprises: Page-by-page pass/fail list (test results report) is standard

Liberogic's web accessibility consulting services are flexible and can accommodate both formats based on your objectives.

A VPAT / ACR that provides detailed descriptions of "which features are supported and where limitations exist" is extremely valuable as a specifications document for your own service or as reference material for prospective clients. By combining a standard test results list with VPAT / ACR, you can also publish a more transparent and comprehensive evaluation.

Additionally, even for domestic-only sites, if you want to manage and publish in global standard format from the start, you can issue only a Japanese-language VPAT / ACR.

We propose the optimal output format tailored to your operational policies and business development. If you have concerns about how to evaluate and report on accessibility, please feel free to contact us!