A VPAT should be reissued or revised when the product it documents has changed enough that the existing Accessibility Conformance Report no longer reflects the current state of the product. The most common triggers are major product releases, redesigns, remediation work that resolves known issues, a move to a newer WCAG version, and procurement requests that require current documentation. ACRs do not carry a formal expiration date, but a report tied to last year’s build will not hold up to buyer scrutiny.
A revision means updating the existing ACR. A reissue means producing a new ACR after a fresh evaluation. Which path applies depends on how much the product has shifted.
| Trigger | What It Means for the ACR |
|---|---|
| Major product release | New features or UI changes require a fresh evaluation and reissue. |
| Remediation completed | Resolved issues should be reflected in an updated conformance table. |
| WCAG version change | Moving from 2.1 AA to 2.2 AA requires a new evaluation against the new criteria. |
| Procurement request | Buyers expect a current ACR, generally within the past 12 months. |
| Edition change | Switching from WCAG edition to Section 508 or EN 301 549 requires a new ACR. |
| Minor copy or label fix | Often a revision to the existing ACR, not a full reissue. |
What is the difference between reissuing and revising a VPAT?
A revision is a targeted edit to an existing ACR. The product has not materially changed, but specific entries need correction or refinement. Examples: a remarks field needs more detail, a misclassified criterion needs correction, or a small UI fix moved one criterion from Partially Supports to Supports.
A reissue is a new ACR built on a new evaluation. The product has shipped meaningful changes, the audit data is stale, or the conformance standard has shifted. In a reissue, the auditor re-evaluates the product against the chosen WCAG edition and rebuilds the conformance table from current findings.
The practical test: if the product looks different from when the audit was conducted, a reissue is the right path. If the product is the same and the report has small errors or outdated remarks, a revision is enough.
Triggers that should prompt a reissue
A few events almost always call for a new ACR rather than a patch to the existing one.
Major product releases. A redesigned checkout, a new dashboard, a rebuilt navigation, or a substantial framework migration changes the accessibility profile of the product. The existing ACR no longer describes what buyers see.
Completed remediation. After fixes ship, the ACR should reflect the improved state. A reissue gives the company a current document to share with procurement teams and prospects.
WCAG version change. Moving from WCAG 2.1 AA to WCAG 2.2 AA introduces new criteria. The existing ACR was evaluated against the older standard and does not cover the new ones. A new evaluation is required.
VPAT edition change. If a buyer requires Section 508 or EN 301 549 and the existing ACR uses the WCAG edition, the company needs a new ACR built on the requested edition.
How often should a VPAT be updated?
There is no formal rule, but most procurement teams expect an ACR dated within the past 12 months. Beyond that window, buyers start asking whether the document still reflects the product.
A practical cadence: review the ACR annually, reissue after significant product changes, and revise mid-cycle when small corrections are needed. Companies with frequent releases often pair an annual evaluation with targeted updates after each major launch.
Static products, like a marketing site that rarely changes, can sometimes stretch longer. Active SaaS products generally cannot.
What changes do not require a reissue?
Not every product change calls for a new ACR. Cosmetic tweaks that do not affect accessibility, backend updates with no UI impact, and content edits that follow existing patterns generally do not require a fresh evaluation.
The question to ask: did the change affect any WCAG criterion documented in the ACR? If the answer is no, the existing report still holds. If the answer is yes or unclear, a revision or reissue is warranted.
Who should reissue the VPAT?
Independently issued ACRs carry more weight in the market than self-issued ones. A buyer reviewing an ACR wants to know that a qualified auditor evaluated the product, not that the vendor filled out the template internally.
When reissuing, the same standard applies. The new ACR should be backed by a current accessibility evaluation, and the auditor should be qualified to assess against the chosen WCAG edition. A reissue with no underlying audit work is not a credible document.
FAQs
How do I know if my VPAT needs a reissue or just a revision?
If the product has shipped meaningful changes since the last evaluation, reissue. If the report has small errors or stale remarks but the product is unchanged, revise. When in doubt, ask the auditor who produced the original ACR.
Does an ACR expire?
ACRs do not carry a formal expiration date. In practice, buyers expect a document dated within the past 12 months, and a report older than that loses credibility quickly.
Do I need a new audit before reissuing a VPAT?
Yes, when the product has changed. A reissued ACR should reflect a current evaluation of the product against the chosen WCAG edition. Reissuing without fresh audit data produces a document that will not hold up under buyer review.
Can I revise a VPAT myself after my vendor delivers it?
Small clarifications to remarks fields are common, but changes to conformance levels should come from the auditor. Self-edited conformance claims raise red flags during procurement review.
What if a buyer asks for a WCAG 2.2 AA ACR and I only have 2.1 AA?
A new evaluation is required. WCAG 2.2 AA introduces criteria not assessed in a 2.1 AA evaluation, so the existing ACR cannot be converted by editing alone.
Keeping an ACR current is a procurement asset. A stale report quietly costs deals; a current one closes them.
Contact Kris Rivenburgh to discuss VPAT and ACR work at krisrivenburgh.com/contact.