WCAG 2.2 does affect filling in a VPAT, but the impact is structural rather than complicated. If you select the WCAG edition of the VPAT and choose 2.2 Level AA as your target, the document includes additional success criteria your auditor must evaluate against. The format of the ACR stays the same. The scope of evaluation expands. Buyers asking for current standards increasingly expect 2.2 AA, so choosing the right version of the template at the start matters more than any single conformance entry inside it.
| Area | What changes with WCAG 2.2 |
|---|---|
| VPAT edition | Use the current WCAG edition of the VPAT template that includes 2.2 criteria. |
| Audit scope | Evaluation covers additional Level A and AA success criteria introduced in 2.2. |
| ACR structure | Same Tables 1 and 2 format. Same Supports, Partially Supports, Does Not Support remarks. |
| Buyer expectation | Enterprise and government buyers increasingly request 2.2 AA over 2.1 AA. |
| Cost impact | Minimal. The audit covers more criteria, but the VPAT preparation workflow is the same. |
What actually changes in the VPAT when you move to 2.2
The VPAT template has a specific edition for WCAG. When 2.2 became the recommended standard, the template was updated to include the new success criteria. Filling it in follows the same process: each criterion gets a conformance level and any supporting remarks.
If you previously had an ACR built against 2.1 AA, moving to 2.2 means your auditor evaluates the additional criteria and adds those entries to the document. Nothing about the structure of the ACR shifts.
Why the audit matters more than the template
The VPAT is the template. The ACR is the completed document. Neither is meaningful without an accessibility audit behind it. An auditor evaluates the product against each WCAG success criterion and reports the result.
With 2.2 AA, that means evaluating against the full Level A and AA criteria set, including those that were added in this version. The auditor identifies issues, and those findings inform the conformance entries written into the ACR. Without a current audit, the document is guesswork dressed in a template.
Should you choose WCAG 2.1 AA or 2.2 AA for your ACR?
For most SaaS companies and product teams in 2026, WCAG 2.2 AA is the practical choice. It is the most recent W3C recommendation, and buyers are increasingly writing it into procurement requirements.
WCAG 2.1 AA is still acceptable in many contexts and remains the baseline for ADA Title II and several international rules. If your buyer or contract specifies 2.1 AA, that is what your ACR should reflect. If the request is open or the buyer says “current standards,” 2.2 AA is the safer choice.
Does WCAG 2.2 make the VPAT process longer?
Not in any meaningful way. The audit covers more criteria, which adds some time on the evaluation side, but the VPAT preparation itself follows the same workflow: review audit findings, map each criterion to a conformance level, write accurate remarks, finalize the document.
The cost difference between a 2.1 AA and 2.2 AA audit is small in most cases. The cost of choosing the wrong version, then having to redo the work when a buyer asks for the newer standard, is much higher.
How to approach VPAT prep with WCAG 2.2 in mind
Start with the audit. Confirm the version you need before the auditor begins, because the evaluation criteria are set at that point. If 2.2 AA is the target, the auditor evaluates against 2.2 and the resulting audit report reflects that standard.
From there, the auditor or your team translates findings into the ACR. The VPAT process stays consistent regardless of which WCAG version you target. The version only changes which success criteria appear in the document and what your product is measured against.
FAQ
Should I get a new ACR if I already have one for WCAG 2.1 AA?
If your buyers are asking for 2.2 AA, yes. The existing ACR can be updated against the newer standard with an audit that covers the additional criteria. There is no formal expiration on an ACR, but a version mismatch with buyer expectations is a real reason to update.
Can the same auditor cover both 2.1 AA and 2.2 AA in one evaluation?
An auditor can evaluate against 2.2 AA and the resulting findings cover 2.1 AA as well, since 2.2 builds on 2.1. The ACR itself is written to one target. Pick the version your buyer needs.
Is WCAG 2.2 AA harder for products to pass?
The added criteria address focus appearance, dragging movements, target size, and a few authentication and help patterns. Products built with current accessibility practices tend to map well. Products that were last evaluated years ago often have new issues to address.
Does the VPAT edition change based on WCAG version?
No. The WCAG edition of the VPAT template is the same edition. It is updated to include the criteria from whichever WCAG version you target. Section 508 and EN 301 549 editions are separate templates with their own scopes.
Choosing 2.2 AA today positions the ACR for what buyers are asking for now and in the year ahead. The form does not get more complicated. The standard behind it gets more current.
Contact Kris for help preparing a VPAT and ACR against WCAG 2.2 AA: krisrivenburgh.com/contact.