Accessibility Conformance Reports (ACRs): Legal Guide

Courts are increasingly requiring accessibility conformance reports. When you're sued for ADA violations, the defendant's lawyer will ask: "Do you have documentation of your accessibility efforts?" Without a conformance report, the answer is "No"—which implies negligence. A well-documented conformance report proves you took accessibility seriously, tested thoroughly, and documented your findings. This is critical for defense.

An Accessibility Conformance Report (ACR) is a formal document that describes: The Voluntary Product Accessibility Template (VPAT) is the industry-standard ACR format. It's created by the IT Accessibility Testing Center and used by government agencies, enterprises, and courts.

A VPAT typically includes: Each WCAG success criterion is listed with status:

A VPAT lists all WCAG 2.1 success criteria. Here's how to read them: Criterion 1.1.1 Non-text Content (Level A) Status: Supports Remarks: All images have alt text. Decorative images have empty alt attributes. Icons have aria-labels. Example Criterion: 2.4.3 Focus Order (Level A) Criterion 2.4.3 Focus Order (Level A) Status: Partially Supports Remarks: Tab order is logical on most pages. Contact form has focus trap issue (Tab key gets stuck). Fix planned for Q4 2025. Example Criterion: 2.1.2 No Keyboard Trap (Level A) Criterion 2.1.2 No Keyboard Trap (Level A) Status: Does Not Support Remarks: Autocomplete dropdown can trap keyboard focus. Escape key does not close dropdown. Issue affects search functionality on all pages. Remediation timeline: 30 days. Reading the Levels Level A: Foundational accessibility (must meet) Level AA: Recommended for all websites Level AAA: Enhanced accessibility (optional but preferred) If you claim WCAG 2.1 Level AA conformance, you must meet ALL Level A AND AA criteria. No "partial" compliance at AA level.

Choose what you're going to comply with: Use a combination of methods: For each WCAG criterion: Criterion: [1.1.1 Non-text Content] Status: [Supports / Partially Supports / Does Not Support] Testing Method: [Automated + Manual Inspection] Remarks: [Detailed findings] Remediation: [If applicable] Timeline: [If applicable] Step 4: Identify Non-Compliant Items For each failure: Issue: Form labels not properly associated with inputs Criterion: 1.3.1 Info and Relationships (Level A) Affected Pages: All pages with forms Severity: High (impacts all users) Remediation: Add proper label-for associations to all form inputs Timeline: 14 days from report date Assigned To: Development team Status: In Progress Step 6: Get Professional Review For high-stakes compliance, have an accessibility expert review your report:

When sued, the plaintiff's attorney will request: A report that identifies known issues but doesn't fix them can be problematic: Best practice: Document issues, then fix them immediately. Update the report as fixes are completed.

You don't need to test every page—select representative samples: Document which pages you tested and why you selected them.

❌ Claiming full Level AA compliance when you haven't tested everything ✅ Claim only what you've tested and verified ❌ "Some images missing alt text" ✅ "Homepage banner images lack descriptive alt text (5 instances found)" ❌ Identifying issues without explaining how you'll fix them ✅ Document specific fixes, responsible parties, and timelines ❌ Only testing the homepage ✅ Representative sample of all major content types ❌ Report from 2023, no updates for 2025 ✅ Annual reviews and updates as changes are made ❌ Report doesn't explain how it was created ✅ Detail tools used, pages tested, testing dates, screen readers used