The Four VPAT / ACR Editions: Differences Between WCAG, Section 508, EU, and INT Versions and Their Legal Background

In our previous article, "Differences Between VPAT / ACR and Japanese Testing Methods," we outlined the difference between VPAT / ACR, a reporting format originating in the United States, and the approach taken in Japan under JIS X 8341-3 testing.

This time, we continue with the topic of VPAT "editions."
The Information Technology Industry Council (ITI), which distributes the VPAT template, offers four versions of VPAT 2.5Rev: WCAG, Section 508, EU, and INT editions. When an overseas business partner asks for a VPAT, the edition you should provide depends on which law or standard your customer is procuring under.

This article explains the differences among the four editions, together with the legal frameworks behind each one.

A Quick Review of VPAT and ACR

• A VPAT (Voluntary Product Accessibility Template) is a blank template distributed by ITI.
• An ACR (Accessibility Conformance Report) is the completed report created by filling in that template with evaluation results.

ACRs are prepared per product. For each success criterion, the product is rated on one of four levels: Supports, Partially Supports, Does Not Support, or Not Applicable, and the basis for each rating is described in the Remarks column. As noted in our previous article, an ACR is not a "certificate of conformance" but a document that transparently discloses what has and has not been achieved.

Why Are There Four Editions?

VPAT was originally created for ICT procurement by the U.S. federal government. Later, the EU established its own accessibility standard (EN 301 549), and W3C continued revising WCAG, from 2.1 to 2.2. As a result, the contents of the table had to change depending on which standard was being addressed, and ITI began distributing the template in separate editions.

The current latest version is VPAT 2.5Rev (April 2025). The four editions are structured as follows.

The WCAG success criteria tables appear in every version, but the versions they cover differ.
The Section 508 version has no WCAG 2.2 success criteria rows at all, and the EU version only goes up to 2.1.
This is because each law and standard reflects the WCAG version it references.

The following sections explain the background of each version.

WCAG version: Answers to technical standards, not laws

WCAG (Web Content Accessibility Guidelines) is a technical standard for web content developed by the W3C and is not a law in itself.
However, the U.S. Section 508, the EU's EN 301 549, and Japan's JIS X 8341-3 all define web content requirements by referencing WCAG. In other words, WCAG is the "common foundation" of national legal frameworks.

The WCAG version of the VPAT responds directly to this foundation.
It lists all WCAG 2.0, 2.1, and 2.2 success criteria (Levels A, AA, and AAA), and has no chapters specific to any law.

Best suited for

• When a private business transaction, outside of U.S. federal government or EU market requirements, asks you to disclose your accessibility status
• When a domestic transaction requests a report in the global standard format
• When you are unsure which version to provide (start with the WCAG version, then add the 508 or EU version as needed)

Examples where laws directly reference WCAG

In the United States, the April 2024 revision of Title II of the ADA (Americans with Disabilities Act) requires state and local governments, including public facilities such as state universities and public libraries, to meet WCAG 2.1 Level AA for their web content.
Universities that receive federal funding are also subject to Section 504 of the Rehabilitation Act, which likewise requires WCAG 2.1 Level AA.
The Section 508 template only covers up to WCAG 2.0, so if these institutions request an ACR, it is appropriate to demonstrate conformance to 2.1 using the WCAG edition (or the INT edition).
US universities often require a VPAT when introducing software, and some states that reference Section 508 in state law may require the Section 508 edition.

Section 508 Edition: Meeting U.S. Federal Procurement Requirements

Legal Background

Section 508 of the Rehabilitation Act requires U.S. federal agencies to ensure that the information and communication technology (ICT) they procure, develop, and use is accessible to federal employees and members of the public with disabilities.
It took its current form through amendments in 1998, and under Subpart 39.2 of the Federal Acquisition Regulation (FAR), accessibility requirements must be incorporated from the planning stage of procurement.

In January 2017, the Revised Section 508 Standards were published as a final rule and took effect on January 18, 2018.
The revision incorporates WCAG 2.0 Levels A and AA by reference as the requirements for web content.
The Section 508 template lists only WCAG 2.0 because the law references 2.0. The U.S. Access Board issued a Request for Information (RFI) in 2025 toward updating the standards, and an update to WCAG 2.2 is expected in the future, but the current legal requirement is 2.0.

Template Contents

The Section 508 Edition includes a WCAG 2.0 table followed by tables for each chapter of the Revised Section 508 Standards.

• Chapter 3 Functional Performance Criteria: Answers whether the product is usable for each user characteristic, such as vision, hearing, speech, manipulation, and cognition.
• Chapter 4 Hardware
• Chapter 5 Software: Covers integration with platform accessibility services, authoring tools, and related items.
• Chapter 6: Support Documentation and Services: Whether documentation and support channels for the product's accessibility features are provided in an accessible format

For websites and web applications, most of Chapter 4 and many parts of Chapter 5 will be "Not Applicable." However, you must provide a justification for why they do not apply.
For example, in Chapter 5, a web application is classified as software under Section 508, but if it does not use platform accessibility services, it falls under the exception in 501.1. Include explanations like this.
This part cannot be written without understanding the structure of Section 508, and it is a major difference from the WCAG version.

Who requires it?

Neither Section 508 nor the FAR (Federal Acquisition Regulation) directly requires vendors to submit a VPAT.
However, because GSA procurement guidance asks federal agencies to require an ACR at the time of bidding, it becomes a bid submission requirement in situations such as the following.

• When delivering directly to a federal agency
• When providing products to a U.S. company that holds a federal government contract (when acting as part of the supply chain)

When the qualifications of the evaluator are in question

In federal procurement, in addition to the ACR, there may be questions about who conducted the evaluation and how it was done.

The U.S. Department of Homeland Security (DHS) has established the Trusted Tester Process as a procedure for consistently evaluating conformance with Section 508, and certifies individuals who complete the procedure as Trusted Testers. Agencies that adopt this procedure only accept evaluation results from certified Trusted Testers.

Liberogic has staff who hold Trusted Tester certification and can perform evaluations under this procedure as well as prepare the Section 508 version of the ACR.

EU Version: Answering EN 301 549 and the European Accessibility Act

Legal Background

EN 301 549 is a European standard for accessibility requirements for ICT products and services, developed by the EU's standardization bodies.
While Section 508 in the U.S. is a law, EN 301 549 is a standard, and several EU laws reference it.

• Web Accessibility Directive (Directive 2016/2102) applies to websites and mobile apps of public sector bodies. EN 301 549 is its harmonized standard.
• European Accessibility Act (EAA, Directive 2019/882) applies to private-sector products and services and began applying on June 28, 2025. It covers e-commerce, banking services, e-books, passenger transport, electronic communications services, operating systems and computers, and ATMs and ticketing machines.

A key point of the EAA is that it also applies to businesses outside the EU.
As long as a covered service is offered to EU consumers, it does not matter where the business is based.
Japanese companies that provide e-commerce sites or SaaS to EU consumers are also covered. (Micro-enterprises with fewer than 10 employees and annual turnover or balance sheet total of 2 million euros or less are exempt for services.)

Relationship Between EAA and VPAT

Like Section 508 in the U.S., the EAA does not legally require the submission of a VPAT or ACR.
What the EAA requires of businesses is an EU declaration of conformity and CE marking for products, and for services, publishing information on how accessibility requirements are met, as set out in Annex V, such as in terms of use.

On the other hand, the EU version of the ACR is widely used as a practical means of showing specifically how a product conforms to EN 301 549.
When EU customer companies select vendors, requesting an ACR against EN 301 549 follows the same pattern as U.S. procurement.
Also, when writing the explanation of how a service meets accessibility requirements that the EAA requires of service providers, an ACR that organizes conformance status by success criterion can be used directly as supporting evidence.

Template Contents

The EU version includes tables by EN 301 549 clause (referred to as "clause" in the standard), following the WCAG 2.0 and 2.1 tables.

• Chapter 4 Functional Performance Statements: Corresponds to Chapter 3 of Section 508
• Chapter 5: General Requirements, Chapter 6: ICT with Two-Way Voice Communication, Chapter 7: ICT with Video Capabilities, Chapter 8: Hardware
• Chapter 9: Web: see the WCAG table
• Chapter 10: Non-Web Documents, Chapter 11: Software, Chapter 12: Documentation and Support Services, Chapter 13: Access to Relay Services and Emergency Services

For web services, many chapters will also be marked "Not Applicable," but you still answer with a stated reason, as in the 508 edition.

Note Changes to the Standard

EN 301 549 currently references v3.2.1 (based on WCAG 2.1) as the harmonised standard.
Meanwhile, v4.1.1 (based on WCAG 2.2), revised to support the EAA, was adopted in August 2026 and published in September.
Once it is cited in the Official Journal of the EU as a harmonised standard, it will be the standard that grants "presumption of conformity."
The EU edition of the ITI template is also expected to be updated accordingly.

INT Edition: Answer Everything in One Document

The INT Edition (International Edition) combines the WCAG, 508, and EU editions into one.
The WCAG 2.0, 2.1, and 2.2 success criteria tables are followed by Chapters 3 to 6 of the revised Section 508 and Chapters 4 to 13 of EN 301 549.

Best suited for

• When you sell a product in both the US and the EU and do not want to prepare a separate edition for each customer
• When you offer a SaaS product globally and want one document that gives procurement officers in any country the information they need

Things to note

The document becomes long.
Following the full table of WCAG 2.0 to 2.2 success criteria, there are chapter tables for Revised Section 508 (Chapters 3 to 6) and EN 301 549 (Chapters 4 to 13). For web projects, you need to write responses and reasons across more than 200 rows combined.

Japan's position: Japan has no law requiring a VPAT

In Japan, JIS X 8341-3:2016 (whose content matches WCAG 2.0) is the web accessibility standard.
The revised Act on Eliminating Discrimination against Persons with Disabilities took effect in April 2024, making reasonable accommodation mandatory for private businesses as well. However, unlike Section 508 in the United States or the EAA in the EU, there is no legal mechanism requiring the submission of an accessibility conformance report at the time of procurement.

Even so, VPATs are relevant to Japanese companies in the following situations.

• Transactions with overseas customers: Providing products or services to the US federal government or EU companies, or entering the supply chain of US or EU companies
• Evaluating overseas SaaS: When Japanese companies introduce overseas products, they read the vendor's ACR and evaluate it
• Wanting to disclose in global standard format for domestic transactions: This is the purpose of the Japanese-language VPAT introduced in our previous article

In short, in Japan the approach is to use a Japanese-language VPAT for domestic audiences and the official ITI VPAT template for overseas audiences.

Note: JIS X 8341-3 is being revised. The policy is to align it with the same success criteria as WCAG 2.2, and publication is expected within fiscal 2026. Once published, domestic JIS-compliant testing and the overseas WCAG and INT versions of the VPAT will be evaluable against the same set of success criteria, laying the groundwork for producing both domestic and international reports from a single audit. Liberogic's diagnostics are currently evaluated against WCAG 2.2, so we can transition seamlessly after the revision.

Not sure which version to choose?

Liberogic supports all four versions.

Liberogic's accessibility audit can produce ACRs in WCAG, Section 508, EU, and INT editions using ITI's official template (VPAT 2.5Rev, April 2025 edition).
Our testing is carried out by IAAP-certified WAS (Web Accessibility Specialists) and Trusted Tester-certified professionals.

The scope covers websites and web applications used in a web browser. We do not cover software products such as hardware, operating systems, or native desktop and mobile apps. For the hardware and software sections of the Section 508, EU, and INT editions, we state the reason they do not apply to web products.

• Testing is based on WCAG-EM sampling, and the results can be used to produce any edition. Adding an edition later does not require repeating the testing.
• We perform the evaluation as an independent third party and state this, along with the testing period, in the evaluation method section. This makes it easier to demonstrate objectivity compared with an ACR evaluated only internally by the vendor.
• For the legal chapters of Section 508 and EN 301 549, we prepare responses and rationales tailored to websites and web application projects. The functional performance criteria (Section 508 Chapter 3 / EN Chapter 4) are derived from the pass/fail results for each WCAG success criterion. For the documentation and support chapters (Section 508 Chapter 6 / EN Chapter 12), we ask about the status of your help pages and support contact channels and document them accordingly.
• Deliverables are provided in both DOCX and PDF. If you want to make additions or edits internally before publishing, use the DOCX; if you plan to submit as-is, use the PDF.

Summary

• VPAT has four editions, WCAG, Section 508, EU, and INT, which differ in terms of "which law or standard the response addresses."
• The Section 508 edition covers U.S. federal government procurement (revised Section 508, WCAG 2.0), the EU edition covers EN 301 549 and the European Accessibility Act (WCAG 2.1, moving to 2.2), the WCAG edition is a technical standard independent of any legal framework, and the INT edition combines all of them.
• Japan has no law requiring VPAT, but it is increasingly requested in overseas transactions and within supply chains.
• Liberogic can produce ACRs for all four editions from a single round of testing.

If you have been asked by overseas clients or partners to submit a VPAT or ACR and are unsure which edition to provide, please get in touch. We will recommend the right editions and language combinations based on your business expansion plans.