Audit report, VPAT® and accessibility statement: which document do you need?
In Poland, only the public-sector accessibility statement has an official template: technical conditions from the Ministry of Digital Affairs version 2.0 of 31 July 2024. The service accessibility information required by the EAA has no official template. Audit and conformance reports have no mandatory form; the industry standard is the ITI VPAT® 2.5Rev template.
Four documents, four roles
| Document | Who prepares it | Official template? | Purpose |
|---|---|---|---|
| Accessibility statement | Public sector body | Yes, Ministry of Digital Affairs technical conditions 2.0 | Public declaration of accessibility status of a website or app |
| Service accessibility information | Company providing an EAA-covered service | No | Description of how the service meets accessibility requirements |
| Audit report | Auditor | No | Full list of defects, evidence, and repair recommendations |
| Conformance report (ACR on VPAT® template) | Manufacturer or auditor on their behalf | ITI industry template | Criterion-by-criterion conformance summary for customers and procurers |
The most important distinction: the statement and service information are declarations by the organization itself. The audit report supports them but does not replace them.
Accessibility statement: MC 2.0 template
Under the Digital Accessibility Act (Polish act on digital accessibility of public sector websites and apps), Article 10 obliges public sector bodies to prepare and publish an accessibility statement. The statement must be an HTML document. From 1 August 2024 it must comply with technical conditions version 2.0, published by the Ministry of Digital Affairs on 31 July 2024.
Version 2.0 introduced 15 headings at levels 1–3 and an obligation to state accessibility status against the act’s annex. The statement must also list identified problems: type of problem, page URL, user-friendly description, and information on alternative access.
Generators compliant with version 2.0, including our free generator, make preparing the statement easier.
EAA: service accessibility information
The Act of 26 April 2024 implementing the EAA requires service providers to make available information about the service and how it meets accessibility requirements. There is no official template for this document. Guidelines for businesses were issued by PFRON (Polish state fund for rehabilitation of disabled persons) under Article 39(6) of the act.
VPAT® 2.5Rev: industry standard
VPAT (Voluntary Product Accessibility Template) is a template from the Information Technology Industry Council (ITI). A completed template is called an ACR, Accessibility Conformance Report. “VPAT” is ITI’s registered service mark.
ITI publishes the template in four editions: WCAG, Revised Section 508, EN 301 549 (EU), and International, combining all of them. The current version is 2.5Rev from 2025. Templates are free.
Conformance levels in the VPAT are:
- Supports: the function meets the criterion without known defects or with an equivalent facilitation,
- Partially Supports: part of the function does not meet the criterion,
- Does Not Support: most of the function does not meet the criterion,
- Not Applicable,
- Not Evaluated: only for AAA criteria.
ITI rules allow among other things merging WCAG level tables, changing their order, translating the template, publishing it in HTML or PDF, and adding your own branding. Mandatory elements include a title in the form “[Company name] Accessibility Conformance Report”, a note on template version, product name and version, date, product description, contact, evaluation methods used, and standards covered. A document that departs from mandatory elements should not be called a VPAT.
Three pitfalls with VPAT and EN 301 549
The EU edition is based on V3.2.1. At the time of writing we did not find a VPAT edition for EN 301 549 V4.1.1. Until the new version is cited in the Official Journal of the EU that is not a problem, because V3.2.1 is still the reference version (timeline).
Five VPAT levels vs three standard outcomes. Annex C knows only passed, failed, and not applicable. “Partially Supports” in the logic of the standard means “failed”. A reliable ACR explains this in remarks so a client talking about “EN 301 549 conformity” does not confuse partial support with conformity. Test details: Annex C.
VPAT is by design a manufacturer declaration. When an external auditor prepares it, the evaluation methods section should state who tested the product, when, on what sample, and with what tools.
Which document package we prepare
In PRO and PREMIUM packages we can prepare three layers of documents from the same test data: full audit report, conformance report on the VPAT® template with mapping to the standard’s tables, and accessibility statement or service accessibility information content for the client to publish.
Generate an accessibility statement for free or order a full document set in Accessibility PRO.
Frequently asked questions
Is VPAT mandatory in the EU?
No. It is a voluntary industry template, often required by procurers and large clients.
How does VPAT differ from ACR?
VPAT is the empty template; ACR is the completed report for a specific product.
Does an accessibility statement replace an audit?
No. The statement describes accessibility status; to be reliable it should be based on testing.
Sources
- Ministry of Digital Affairs: technical conditions for accessibility statements
- PFRON: guidelines for businesses
- ITI: VPAT® templates
- Accessible.org: VPAT completion rules
- Act of 26 April 2024 (Journal of Laws 2024 item 731)