Simkins & ElgazarWhich VPAT Edition: WCAG, 508, EN 301 549 or INT?
Use the edition that matches your buyer's standard: 508 for federal, WCAG 2.1 for Title II, EN 301 549 for the EU, INT for all three.
By Maximilian Simkins. Published . 5 min read.
Topics: VPAT, ACR, Section 508, WCAG 2.1, procurement
Pick the edition that matches the standard your buyer cites. A federal agency buying under Section 508 expects the 508 edition, which rests on WCAG 2.0 Level A and AA for web content. A state or local government covered by the ADA Title II web rule must meet WCAG 2.1 Level A and AA, so the WCAG edition is the natural fit. European public buyers use EN 301 549, and the INT edition covers all three.
This is general information, not legal advice. Your solicitation controls: if it names an edition, use that one.
What are the four VPAT editions?
The VPAT is a template from the Information Technology Industry Council (ITI). The finished document is the Accessibility Conformance Report (ACR). Section508.gov describes an ACR as a document that explains how ICT products meet the Revised 508 Standards, and says the VPAT is the most common way to complete one.
ITI's current version is VPAT 2.5Rev (April 2025). It comes in four editions:
- 508: the Revised Section 508 Standards, the US federal standard (ITI says it incorporates WCAG 2.0).
- EU: EN 301 549, the European standard for public procurement of ICT (ITI says it incorporates WCAG 2.1).
- WCAG: WCAG 2.0 (also ISO/IEC 40500), WCAG 2.1 and WCAG 2.2 (ITI says the WCAG and INT editions incorporate 2.2).
- INT: all three of the above in one document.
ITI says vendors declare conformance with one of four levels: supports, partially supports, does not support, or not applicable.
Which edition goes with which buyer?
| Buyer | Standard they apply to web content | Edition to start from |
|---|---|---|
| US federal agency | Revised 508 Standards, WCAG 2.0 Level A and AA | VPAT 2.5 508 |
| State or local government under Title II | WCAG 2.1 Level A and AA (28 CFR 35.200(b)) | VPAT 2.5 WCAG, tested to 2.1 |
| European public-sector buyer | EN 301 549 | VPAT 2.5 EU |
| You sell to more than one of these | All of the above | VPAT 2.5 INT |
Two cautions. The Title II rule sets the accessibility standard for the entity's web content and mobile apps. It does not tell vendors which template to use, so a county's procurement office may ask for any edition. And the 508 edition covers more than web content. The Revised 508 Standards also have chapters on functional performance, hardware, software and support documentation, so a hardware or desktop software vendor has more to report than a web app vendor.
Why does Section 508 cite WCAG 2.0 when Title II requires 2.1?
The Access Board adopted WCAG 2.0 as the federal web standard in a rule published January 18, 2017. WCAG 2.1 was published in June 2018, after that rule was written. The Revised 508 Standards still say electronic content must conform to the Level A and AA success criteria in WCAG 2.0 (section E205.4 of 36 CFR part 1194, Appendix A).
When DOJ wrote the Title II rule in 2024, it considered WCAG 2.0 and decided 2.1 was more appropriate. It said 2.1 "provides for important accessibility features that are not included in WCAG 2.0," and referred to 2.1's 12 additional Level A and AA success criteria. DOJ also noted that the federal government is required to conform to WCAG 2.0 under Section 508.
Can one ACR serve several buyers?
Often, yes, if you test to the higher level. W3C states that content conforming to WCAG 2.1 also conforms to WCAG 2.0. So a product tested to WCAG 2.1 Level AA meets the 508 web criteria as well. ITI's WCAG edition covers WCAG 2.0, 2.1 and 2.2, so one document can show results against each version.
Two limits apply. First, a federal buyer reading a WCAG-only report may still want the 508 edition, because the 508 chapters on software, hardware and documentation are not WCAG criteria. Second, an ACR is only as good as the testing behind it. Reporting against 2.1 from a 2.0 evaluation does not make the product 2.1 conformant.
What if a buyer asks for WCAG 2.2?
Report it if you have tested to it. The Title II rule incorporates WCAG 2.1, so 2.1 is the standard a public entity must meet, and DOJ noted in its preamble that WCAG 2.2 was published recently and includes more success criteria. A buyer who asks for 2.2 is going past what the rule requires, which is allowed. The WCAG edition includes 2.2. Do not report against it unless your testing covered the 2.2 criteria. For the differences between the versions, see our post on WCAG 2.2 vs 2.1.
What should you check before you publish an ACR?
- The edition matches what the solicitation asks for.
- The WCAG version you tested to is named, with the product version and test date.
- Each "Supports" or "Partially supports" row has remarks that say what was tested and what fails.
- Testing covered more than an automated scan. Scanners find only some failures.
- "Not applicable" is used only where the criterion really does not apply.
What happened when a federal agency argued for WCAG 2.0?
This is a public case, not one of our engagements. In the 2024 rulemaking record for the Title II rule (89 FR 31320, April 24, 2024), DOJ describes a comment from the Small Business Administration, which "argued that public entities should not have to comply with a more rigorous standard for online accessibility than the Federal Government, which is required to conform to WCAG 2.0 under section 508." DOJ answered that when the Access Board adopted WCAG 2.0 in 2017, WCAG 2.1 "had not been finalized," and concluded that adopting WCAG 2.1 "is more appropriate than adopting WCAG 2.0." The result is the split in this article: federal ICT reports to a 2.0-based standard, and state and local governments to 2.1. A vendor selling to both needs a report that shows each. This is a rulemaking record, not a court decision.
If you need an ACR that matches your buyer's standard, see our VPAT and ACR preparation service.
Sources
- ITI, VPAT page (editions, VPAT 2.5Rev April 2025, rating categories): https://www.itic.org/policy/accessibility/vpat
- Section508.gov, Accessibility Conformance Report (ACR) (what an ACR is): https://www.section508.gov/sell/acr/
- Section508.gov, How to Create an ACR with a VPAT (VPAT is the most common method; reviewed June 2026): https://www.section508.gov/sell/how-to-create-acr-with-vpat/
- Access Board, Information and Communication Technology standards (Revised 508, E205.4, WCAG 2.0 Level A and AA; Appendix C 702.10.1; chapters 3 to 6): https://www.access-board.gov/ict/
- 28 CFR 35.200 (WCAG 2.1 Level A and AA, dates April 26, 2027 and April 26, 2028; eCFR text as of 2026-09-01, amended by 91 FR 20912, Apr. 20, 2026): https://www.ecfr.gov/current/title-28/section-35.200
- DOJ final rule, 89 FR 31320 (Apr. 24, 2024), preamble section "WCAG 2.0 and Section 508 of the Rehabilitation Act" (SBA comment; 12 additional Level A and AA criteria; Access Board 2017 rule, 82 FR 5790): https://www.federalregister.gov/documents/2024/04/24/2024-07758/nondiscrimination-on-the-basis-of-disability-accessibility-of-web-information-and-services-of-state
- W3C, WCAG 2.1 (published June 2018; "Content that conforms to WCAG 2.1 also conforms to WCAG 2.0"): https://www.w3.org/TR/WCAG21/
- ETSI, EN 301 549 V3.2.1 (2021-03), reflects WCAG 2.1: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf