Procurement Guide to ADA Compliance and Web Accessibility

If you’re a procurement manager, the guide below will help you with vetting vendors and third parties for digital accessibility and ADA compliance.

Difference Between Web and Digital Accessibility

Web and digital accessibility are used interchangeably but here’s the difference: Web pertains to all things web: websites, mobile apps, documents hosted online, etc.

Digital accessibility encompasses the web but also includes electronic technology such as kiosks and software.  There can be large overlap but the two terms are distinct.


With any products, it’s best to require a VPAT® or Voluntary Product Assessment Template and ideally you want that VPAT to be issued under the WCAG 2.1 AA standards (2.2 AA after the summer of 2021).

The VPAT technically is only the template form to be filled out but the marketplace typically refers to a finished form as a VPAT even though the correct term for a finished report is ACR or Accessibility Conformance Report.

A VPAT doesn’t need to state 100% conformance with WCAG.  Usually products fall short in a few accessibility areas.  However, you should highly favor selecting products that are the most accessible.

Note that VPATs don’t have to be independently issued by a third party; they can be created by the product creators.  However, VPATs created in-house have minimal value because:

  1. Most product creators aren’t accessibility experts and aren’t in a position to accurately evaluate the accessibility of a product
  2. There’s a tendency to over-exaggerate or lie about the accessibility of a product
  3. As a procurement agent, what you really want is an independent accessibility assessment

Conformance Statements

For web accessibility, procurement departments should evaluate websites and apps based on conformance statements.

Why is this important?

Illustration #1:

Your bank website relies on a customer account dashboard hosted on an externally controlled domain.  That external dashboard needs to be accessible as you are sending your customers to that dashboard as a part of your offering.

Illustration #2:

You integrate a social media widget inside of your website.  That social media widget needs to be vetted for accessibility as it directly affects and reflects upon the accessibility of your website.

Back to conformance statements.

Conformance statements basically amount to certification of accessibility and are almost always issued by an independent company comprised of experts.

Conformance statements certify that a website or app meets all of a particular standard, usually WCAG 2.0 AA or 2.1 AA.

Conformance statements are the result of at least one manual audit, remediation, and a second audit to ensure that all of the issues found in the audit are taken care of.

After that, accessibility certification by an independent agency can be issued.

Note that scans are helpful accessibility tools but an automated scan or checker alone can never be the basis of confirming a fully WCAG conformant website or mobile app.

Also note that not all organizations are aware of conformance statements and they have had excellent accessibility audits and remediation performed but they may have not formally announced it.

Check that organization’s accessibility policy or accessibility statement.  In a policy or statement (commonly used interchangeably), you may see that indeed their website is conformant.

Again, it’s important that any audits conducted are manual and they have been conducted by an independent, reputable third-party.


The two best things to look for when procuring digital products or requiring web accessibility are VPATs and conformance statements.

VPATs are becoming essential and will be a staple in 2021 and going forward.

Conformance statements are lesser known but will also be looked to with increasing frequency.  In the meantime, organizations that have made a genuine effort in accessibility will have all that you would look for in a conformance statement without the formal document.