How to choose the right VPAT approach for your organization (and whether you should use AI to complete your ACR!)

At this point, we’re all pretty familiar with the broad benefits of artificial intelligence (AI) in a business setting: cost, speed, efficiency, scale, and so forth. Given AI’s capabilities, you may be tempted to feed the results of an accessibility audit into an AI tool, then give it a copy of a Voluntary Product Accessibility Template (VPAT) and have it quickly produce a brand-spanking-new Accessibility Conformance Report (ACR), complete with thoughtful comments, deep insights, and fully fleshed-out ideas. You may even think you can do the testing and the ACR production all in one fell swoop.

The reality is, relying on AI alone can be problematic. When you’re talking about high-risk areas such as security, privacy, or accessibility, you can’t afford anything less than trustworthy, accurate results—something AI is notoriously poor at delivering.

In this post, I’m going to discuss why accuracy matters for digital accessibility in an era of evolving global standards and increased regulatory scrutiny. I’ll explain where and how VPATs and ACRs fit into your accessibility strategies, and what you need to know before making any decisions about AI use. I’ll also outline challenges and opportunities, explore the potential benefits of producing a completed ACR internally, and help you choose the right VPAT approach for your organization.

Why accuracy matters in accessibility compliance

Testing is an essential part of achieving and maintaining digital accessibility compliance over the long term, and accuracy matters because it’s the foundation of trust. With trustworthy results, you can be confident about your state of accessibility, and document and report it successfully. Without results you can trust, you’re exposed to risk.

Digital accessibility compliance is high-risk because failing to meet applicable standards and regulations can cost your organization a great deal—legally, financially, and reputationally. Potential consequences include losing business, being sued for breach of contract, or facing an accessibility lawsuit.

Standards and regulations are also regularly evolving and expanding, meaning compliance can be a moving target, and digital accessibility is increasingly global. For example, while the European Accessibility Act (EAA) is a European Union (EU) directive, it potentially applies to any organization selling into or within the EU, whether the organization is based there or not. Regulatory scrutiny continues to intensify across the globe, and organizations must be prepared to demonstrate compliance.

Standards and regulations are there for a reason—to help ensure equal access to digital products, services, and experiences. Failure to comply excludes people; being accessible is inclusive.

How organizations use VPATs and ACRs

Using a template called a VPAT to draft an ACR is one way to document your current state of accessibility. It’s common for organizations to use a VPAT to demonstrate that they meet standards such as the Web Content Accessibility Guidelines (WCAG), as required by regulations such as the Americans with Disabilities Act (ADA) and the European Accessibility Act (EAA).

I recently hosted a webinar about VPATs called “It’s time for your global VPAT: VPAT compliance in the era of EAA,” so if you’d like to learn more about VPATs and ACRs—what they are and why you need them—I encourage you to watch the recording. It’s a good way to learn the basics, which I’m not really going to cover here.

Working with a trusted digital accessibility provider is one reliable way to complete a VPAT and produce an ACR. But you can also do that work yourself, as it enables you to build firsthand knowledge about ensuring accuracy across testing, remediation, and validation. You’ll also be building institutional knowledge and refining your ability to communicate clearly and accurately about your accessibility status.

The workflow behind a completed VPAT

The broad workflow that leads to a completed VPAT starts with an audit. That’s how you learn what needs fixing. From there, you perform the fixes. That’s remediation. Then you test and validate. Once you know you’ve met the requirements, you’re ready to fill in the VPAT and produce your completed ACR. It can be a complicated process, but the good news is that expert organizations such as Deque and many others are available to do the work.

That doesn’t mean you can’t complete an ACR internally. Deque even offers tools for exactly this purpose. As my colleague Vipul Khandelwal recently wrote about, ACR generation is now built directly into Axe Monitor, which means “you can move from completed accessibility audits to customer-ready VPAT-based ACRs in a single workflow—reducing manual effort for your teams and generating documentation up to 90% faster than traditional processes.”

If you do opt to do this work internally, be cautious if you’re considering using AI in the process. Let’s explore where AI falls short, where it helps, and what you can do to get trustworthy results.

VPATs and AI: Challenges

If you’re going to complete a VPAT yourself, there are some important things to understand about what you can and can’t use AI for.

Testing

First, you can’t rely on general AI tools to perform comprehensive digital accessibility testing when they’re typically limited to code analysis and lack real browser rendering, runtime ARIA states, and computed contrast. Even highly accurate, efficient, and advanced tools such as Deque’s automated Intelligent Guided Tests still require human review.

Remediation

Second, AI alone can’t reliably recommend fixes, conduct remediation, or report accurately and comprehensively on actions taken. Automating accessibility remediation is absolutely doable, but again, it requires a combination of advanced tools and human expertise.

We recently published a case study outlining how the engineering team built an agentic workflow, integrated the Axe MCP Server into its existing engineering process, and applied the workflow to 171 WCAG 2.2 AA accessibility issues. In total, 80 percent of applicable accessibility issues were successfully remediated and validated end-to-end, with 70 percent requiring no human edits and 10 percent requiring only light human review. Remediation was 98 percent faster overall, and internal estimates suggest the workflow saved more than $25,000 in engineering costs.

Conformance assessment

Finally, you can’t reliably trust general AI tools to assess conformance. WCAG, for example, is based on four core principles, collectively known by the acronym POUR: Perceivable, Operable, Understandable, and Robust. Underneath these principles are guidelines and success criteria, many of which rely on subjective context that requires human evaluation.

VPATs and AI: Opportunities

At this point, you might be asking, what can I use AI for?

Catch errors and inconsistencies

If you’re going to complete a VPAT yourself, AI can be very useful for helping with accuracy. AI is excellent at catching mistakes like pasting into the wrong field or misinterpreting the nuance between EN 301 549, clause 12.2.2 vs. 12.2.3. It is also great at comparing version results to show what has changed and what might be inaccurate. AI can help you find seemingly small mistakes that are actually important, such as an out-of-date copyright, misspellings, or even invalid results (saying “not evaluated” instead of “not applicable,” for instance).

Clean and clarify language and messaging

On a case-by-case basis, AI can also be effectively leveraged to help turn roughly worded prose into something more digestible, with two big caveats: first, you must know what you are asking, so you know if the results make sense, and second, you must tell it to rewrite it in simpler terms. The goal is to produce final language that is both accurate to your current accessibility status and easy for all audiences to read and digest.

Benefits of producing a completed ACR internally

Filling out a VPAT and producing a completed ACR yourself can be a valuable experience. You’ll build institutional knowledge and refine your ability to accurately and clearly communicate about accessibility on behalf of your organization. You’ll be able to answer questions about your audits, test results, and remediation efforts with confidence and understanding. Not just in general, but in the very real scenario where a potential client contacts you for clarity on results. You’ll know where your company stands and what you’ve accomplished, and you’ll help insulate your organization against risk and legal exposure.

Many people, teams, and organizations may see your completed ACR. On the business side, for example, procurement buyers will evaluate it before purchasing. On the personal side, your ACR helps people with disabilities make informed decisions when buying digital products and services.

Choose the right VPAT approach for your organization

Completing a VPAT and producing an ACR is an important piece of your digital accessibility compliance puzzle. It’s how you communicate your state of accessibility to vendors and people with disabilities, meet expectations from both regulators and customers, and prove your accessibility conformance.

While it’s not work you want to trust entirely to an AI tool, you can certainly use AI to help with speed, accuracy, and clarity.

Ready to get started? We recommend that you schedule a strategic consultation with our experts to determine which VPAT/ACR is right for your organization and the best approach to achieve your goals and meet your requirements.

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