What Are VPAT and ACR for Web Accessibility? Differences From Japan's Inspections and JIS Compliance

VPAT / ACR is a format widely used in the United States to demonstrate web accessibility conformance. How does it differ from the audits and reports conducted in Japan?

This article explains the characteristics and differences of each from a practical standpoint.

What Are VPAT / ACR?

The VPAT evolved as a federal procurement requirement based on Section 508 of the U.S. Rehabilitation Act. Today, versions that directly align with the international WCAG standard are also available, making it the global standard for accessibility evaluation. In the United States, lawsuits against private companies under the Americans with Disabilities Act (ADA) have increased, and as a result, many private companies now voluntarily issue and publish VPAT / ACR documents.

Relationship Between VPAT and ACR

• VPAT (Voluntary Product Accessibility Template) = a template format for evaluating accessibility
• ACR (Accessibility Conformance Report) = the actual report created using the VPAT template

In other words, the relationship is that an ACR is created by using the VPAT format. Recently, the term "ACR" has become the more common name.

Cultural Practices in the US: Why Certificates Are Avoided

In the US, there is a tendency to avoid publicly displaying accessibility "certificates." Explicitly stating that a site "conforms" increases the risk of legal liability if defects are discovered later. For this reason, it is common in the US to provide only the "Accessibility Conformance Report (ACR)."

VPAT Is Self-Assessment

A VPAT is fundamentally a self-assessment. Even when verified by a third party, it is issued in the name of the site owner (product provider).

The Core of VPAT Is Transparency

A VPAT is not simply a pass or fail verdict. It is a document for disclosing information, describing in detail which features of a product are accessible and where limitations exist. By accurately disclosing current issues, it demonstrates a sincere attitude toward adopting organizations and users and aims to build trust.

How to Create a VPAT / ACR

Creating at the Product Level

In a VPAT, the evaluation results of the pages tested are consolidated, and the entire website is ultimately evaluated as a single "product." For one website, one report (ACR) is created.

Understanding the Scope of a Product

• Even within the same domain, separate reports may be created if the systems are distinct (e.g., a public website and an admin panel).
• Conversely, multiple domains may be combined into a single report if they belong to the same product.
• Landing pages (LPs) are often treated as separate products.

Evaluation Method

A VPAT evaluation is not merely a check of whether the criteria are met. Its most important feature is transparency, which means disclosing everything, including current issues.

Each item is evaluated on the following four-level scale, and its compliance status is described in detail.

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

Providing a candid report (ACR) that openly discloses shortcomings is a key factor in how companies are evaluated in modern global procurement, where corporate integrity is highly valued.

Page Selection Method (Sampling Based on WCAG-EM)

VPAT selects pages based on WCAG-EM (Website Accessibility Conformance Evaluation Methodology).

Guideline for number of pages:

WCAG-EM does not specify a fixed number of pages. Instead, it leaves the decision to the evaluator, based on the site's size and complexity, template consistency, and the level of confidence required. As a general guideline:

• For sites with fewer than 10 pages, the baseline approach is to evaluate all pages without sampling.
• For small to medium-sized sites, 10 to 15 pages is standard.
• For large sites with many templates and feature types (such as e-commerce or member sites), the count may reach 25 to 50 pages.

The number of pages to review depends not on the total page count of the site, but on the number of templates and feature types. We select a "Structured Sample" that covers every template that makes up the site, such as the top page, article detail pages, forms, and search results. To avoid overlooking issues, we also add a random sample of about 10% of pages, selected at random, and our specialists conduct a thorough review.

1. Structured Sample

A set of pages intentionally selected to cover the site's features and types. This is the core of the sample set.

② Random Sample

A group of pages selected at random to avoid oversights. As a guideline, roughly 10% of the total number of pages selected.

How to handle issues found on random pages

For example, if an article page selected at random is found to have an image without alt text

• For systemic defects (e.g., the CMS does not output alt attributes by specification)

  → Rate as "Does Not Support" in the VPAT and describe as a technical issue

• For operational errors (e.g., an editor simply forgot to enter alt text)

  → Rate as "Partially Supports" in the VPAT and describe as, for example: "The CMS provides alternative text functionality, but some content is missing entries."

Sample selection by site size

Very small (single landing page, fewer than 10 pages):

• For a single landing page: evaluate that page alone as one product
• For sites with fewer than 10 pages: evaluating all pages is recommended. Alternatively, use 5 to 8 structured sample pages plus 1 random sample page

Small to medium (static corporate site, roughly 10 to 100 pages):

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

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

• Structured sample: 20-30 pages (more if there are many template and feature types)
• Random sample: 2-3 pages

Testing Methods and Reporting 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, where browsing on smartphones is commonplace, an increasing number of issues cannot be adequately addressed by WCAG 2.0 alone.

The Japanese government's Minna no Kokyo Site Guidelines (2024 edition) also explicitly states: "Anticipating future revisions to JIS, sites should be built based on WCAG 2.2 success criteria wherever possible."

Liberogic Accessibility Audit Service

Liberogic uses the latest WCAG 2.1/2.2 as its evaluation criteria, while basing its report format on a page-by-page evaluation approach that is familiar to Japanese companies.

Page Selection Method

As with VPAT / ACR, pages are selected based on WCAG-EM. By combining representative templates with random pages, we efficiently and accurately evaluate the quality of the entire site.

Evaluation Process

Each page is inspected individually, and each success criterion is evaluated.

• Each success criterion is rated on a three-level scale: Pass, Fail, or Not Applicable.
• If any criterion is not passed, the page is rated "Fail."
• If all success criteria are met, the page is rated "Pass."
• Based on the results of all selected representative pages, the overall site is determined to be either fully conformant or partially conformant.

This evaluation method makes it easy to see at a glance which criteria on which pages present issues.

Deliverables: Test results list + Certificate

In Japan, there is a strong emphasis on objective evaluation by independent third parties. Liberogic issues an inspection certificate to certify that the inspection was conducted by an independent third-party testing organization.

Standard Deliverables

1. List of tested pages (conformance status of each page)
2. Evaluation report for each page and each success criterion
3. Inspection certificate issued by a third-party testing organization

Optional: Added value with Japanese VPAT / ACR

In addition to the deliverables above, we can also prepare a Japanese-language VPAT / ACR.

Benefits of adding a VPAT / ACR

1. Greater trust through transparency

   Rather than a simple pass-or-fail verdict, we disclose in detail which features of the product are supported and where limitations exist. Openly and accurately publishing current issues, without hiding them, builds deeper trust with adopting companies and end users.

2. Use as a strategic sales and bidding tool

   As part of the product specifications, it can be used in your company's service introduction materials and in responses to RFPs (Requests for Proposal).

   • Beyond page-by-page pass/fail results, holding a global standard rating that reflects the overall conformance status of the entire product enables more comprehensive quality assurance.
   • When bid projects require evidence of your accessibility compliance status, this report serves as a strong and concrete proof point.
3. Prepared for Immediate Global Compliance

   For foreign-affiliated companies and businesses planning global expansion, the international ACR standard serves as a common language.

   • You can respond immediately when a parent company, overseas office, or international client requests submission.
   • Evaluating against international standards from the outset significantly reduces the cost and effort of re-auditing when you expand overseas in the future.

When JIS compliance is required for government projects

We can also support projects such as government agency procurement that require conformance with JIS X 8341-3:2016.

In that case, we select the pages to be tested based on the JIS X 8341-3:2016 Test Implementation Guidelines published by WAIC.

Page Selection for JIS Compliance

Standard sample structure:

• Representative web pages: 10 to 35 pages (covering all templates)
• Random pages: 25 to 40 pages
• Total: 40 or more pages

Why 40 or more pages are needed

The primary purpose is to build evidence that supports a public declaration of conformance to the standard (a conformance statement). Ideally, every page would be tested, but this is impractical for large sites. For this reason, WAIC's testing implementation guidelines also present a sampling approach combining "representative pages + random pages," which has become the de facto standard. To ensure statistical reliability, a certain minimum number of pages (roughly 40 or more) tends to be required.

On the other hand, WCAG-EM (roughly 10 to 20 pages) focuses on understanding the overall trends of a site and improving quality efficiently (quality management).

Unless there is a clear requirement to comply with JIS (such as public sector tenders), we recommend an efficient review based on the WCAG-EM methodology.

Comparison of Methods

Summary

In Japan, there are two approaches to evaluating web accessibility: "VPAT / ACR," which is based on U.S. business practices, and evaluation methods that follow from JIS (Japanese Industrial Standards).

• For transactions with global and foreign-affiliated companies: VPAT / ACR is required
• For Japanese public institutions and general companies: A page-by-page pass/fail list (test results report) is common

Liberogic's web accessibility assessment services can be flexibly tailored to either format, depending on your goals.

A VPAT / ACR that details "which features are supported and where limitations exist" is highly effective as a product specification document or as material for explaining your product to prospective customers. By combining a standard test results list with a VPAT / ACR, you can also publish a more transparent and detailed evaluation.

Even for a site intended for the domestic market, if you want to manage and publish it in a global standard format from the outset, it is also possible to issue a VPAT / ACR in Japanese only.

We will propose the output format that best fits your operational policies and business plans. If you are unsure how to evaluate or report on accessibility, please feel free to reach out to us!