Section 508 Compliance for SaaS Vendors: VPAT / ACR and Federal Procurement Guide

Section 508 of the Rehabilitation Act requires federal agencies to make covered information and communication technology accessible to people with disabilities.

The Revised Section 508 Standards address websites, software, electronic content and other covered ICT.

Federal acquisition rules, including FAR 39.203, address accessibility in ICT procurement.

Read FAR 39.203 .

Section 508 directly governs federal agencies. SaaS vendors seeking federal contracts may need to demonstrate accessibility through procurement requirements.

Relevant products include:

• ERP and CRM applications
• HR, payroll and employee portals
• Learning management systems
• Healthcare and appointment platforms
• Document management and e-signature tools
• Recruitment and applicant tracking systems
• AI chatbots and virtual assistants
• Helpdesk and project management software
• Reporting and analytics dashboards
• Custom-developed government applications

An ACR should identify the product, version, evaluation methods, applicable criteria and conformance results. A blank VPAT does not demonstrate that a product has been tested.

The word “Voluntary” is part of the VPAT name. It does not mean that federal buyers must accept a proposal without accessibility evidence.

A federal solicitation may require a completed ACR or equivalent accessibility documentation. Requirements depend on the product, contract, applicable exceptions and agency instructions.

ITI released VPAT 2.5Rev in April 2025. Four editions are available.

For US federal procurement, the 508 edition is often the relevant starting point. The INT edition may suit products sold internationally. Follow the format requested in the solicitation.

Download official ITI VPAT 2.5Rev templates .

A reliable ACR should be based on actual product evaluation. Automated testing can identify some technical failures, but it cannot confirm that users can complete every important task.

Recommended Assistive Technology Matrix

The final testing matrix should match the product’s supported environments and procurement requirements.

The Revised Section 508 Standards incorporate WCAG 2.0 Level A and AA success criteria for applicable web content. WCAG 2.2 AA provides additional accessibility criteria beyond WCAG 2.0.

Review W3C WCAG 2.2 .

A Supplemental Accessibility Report (SAR) provides more information about the product’s accessibility evaluation and features.

It may include:

• Evaluation methods
• Tested platforms and versions
• Accessibility features
• Assistive technology support
• Known accessibility limitations
• Accessible configuration instructions
• Accessible content creation features, where applicable

GSA’s acquisition guidance discusses SAR documentation for standard ICT items. Vendors should check the actual solicitation for required submissions.

Read GSA accessibility information guidance .

The ACR Issue Detail Supplement is a companion document developed by GSA to describe known accessibility barriers in more detail. GSA updated its guidance in October 2026.

It helps buyers understand the severity, affected functions, user impact and workarounds for reported issues.

Example: Inaccessible Date Picker

The supplement is recommended by GSA as a procurement best practice. It is not automatically required for every federal contract.

Review GSA’s ACR Issue Detail Supplement .

A useful ACR should describe actual product accessibility rather than hide known problems.

VPAT 2.5Rev uses four conformance terms:

• Supports: The product meets the applicable criterion.
• Partially Supports: Some functions meet the criterion while others do not.
• Does Not Support: The product does not meet the criterion.
• Not Applicable: The criterion does not apply to the product.

Remarks should describe evaluation results. When a criterion is not fully supported, identify affected functions and relevant limitations.

Yes. Federal acquisition guidance encourages agencies to consider independent accessibility evaluation. A buyer may request access to a representative product release and test important workflows.

Common Procurement Test Tasks

• Sign in and complete authentication
• Navigate the main dashboard
• Create and edit a record
• Complete a multi-step form
• Use data tables and filters
• Export and read a report
• Recover from form errors
• Complete a task using a screen reader

SaaS vendors should be ready to demonstrate accessible workflows, not only submit written claims.

There is no single universal ACR update schedule for all SaaS products. Vendors should review the report when important product changes affect accessibility.

Common Review Triggers

• Major application release
• New modules or workflows
• Changes to navigation or forms
• New third-party components
• Changes to supported platforms
• Significant accessibility remediation
• New procurement requirements
• Customer requests for current evidence

Include the tested product version and evaluation date so buyers understand the report’s scope.

Enabled.in supports software vendors preparing accessibility evidence for US government procurement.

For SaaS platforms serving federal agencies, state and local governments, and public-sector organisations, explore Enabled.in’s ADA Title II, Section 508, WCAG accessibility testing and VPAT/ACR services .

ADA Title II and Section 508 are separate legal frameworks. The applicable requirements depend on the public entity and technology.

Frequently Asked Questions

Official References

1. Federal Acquisition Regulation: FAR 39.203
2. Section508.gov: Create an ACR Using VPAT
3. ITI: VPAT 2.5Rev Templates and Instructions
4. GSA: Request Accessibility Information from Vendors
5. GSA: ACR Issue Detail Supplement
6. Section508.gov: Sell Accessible Products and Services
7. W3C: WCAG 2.2

Reviewed November 2026. Federal procurement requirements vary by solicitation. Confirm applicable standards, exceptions and agency instructions before submission.