VPAT “Not Applicable” Conformance Level

“Not Applicable” in a VPAT means a specific WCAG criterion does not apply to the product being evaluated. The criterion describes functionality or content type that does not exist anywhere in the product. When a criterion is marked N/A in the completed Accessibility Conformance Report (ACR), it tells the reviewer that the criterion was considered and intentionally excluded because the product lacks the relevant content or feature.

This is one of the most misunderstood fields in the VPAT template. Marking a criterion as Not Applicable when it does apply undermines the credibility of the entire ACR. Marking a criterion as Supports when it should be N/A adds unnecessary noise. Either mistake signals to procurement reviewers that the evaluation was not thorough.

Key Points: Not Applicable in a VPAT
Consideration Detail
What N/A means The criterion describes content or functionality that does not exist in the product
Common example A text-only product with no audio or video content would mark prerecorded media criteria as N/A
When N/A is wrong When the content type exists in the product but was overlooked or intentionally skipped
Who reviews it Procurement teams, IT reviewers, and accessibility specialists at purchasing organizations
Risk of misuse Reduces trust in the ACR and can disqualify a product during procurement evaluation

How Not Applicable Differs from Other Conformance Levels

The VPAT template includes several conformance level options: Supports, Partially Supports, Does Not Support, Not Applicable, and Not Evaluated. Each one communicates something different to the reviewer.

“Supports” means the product fully meets the criterion. “Does Not Support” means it does not. “Not Applicable” means the criterion is irrelevant to the product entirely. These are distinct assessments, and conflating them creates a misleading ACR.

A product that includes video content cannot mark the captions criterion as N/A. That criterion applies. Whether the product passes or does not pass is a separate question, but the criterion is relevant. N/A is reserved for when the content type or interaction pattern described by the criterion does not exist in the product at all.

When Is It Correct to Mark a Criterion as Not Applicable?

A criterion is correctly marked N/A when the product genuinely lacks the content type or functionality the criterion addresses. Here are common scenarios where N/A is appropriate:

  • No audio or video content: Criteria related to captions, audio descriptions, and media alternatives do not apply if the product contains no time-based media
  • No user input forms: Criteria related to error identification, labels, and input assistance do not apply if the product has no forms or interactive inputs
  • No time limits: The criterion for adjustable timing does not apply if the product never imposes a time constraint on users
  • No sensory characteristics: If content never relies on shape, size, or visual location as the sole method of conveying instructions, the related criterion does not apply

The key principle: the content type described in the criterion must be entirely absent from the product. If it exists even once, the criterion applies.

Common Mistakes When Using Not Applicable

The most frequent error is marking a criterion as N/A to avoid documenting an accessibility issue. This happens when an evaluator encounters a criterion the product does not meet and categorizes it as irrelevant instead of recording the nonconformance. Procurement reviewers are trained to spot this pattern.

Another common mistake is applying N/A too broadly across media-related criteria without confirming whether the product embeds third-party video, audio players, or multimedia content. A product that integrates YouTube videos, for example, triggers media-related criteria even if the product team did not create the video content.

A third error involves marking criteria as N/A based on the current version of the product while ignoring features that are part of the evaluated scope. If the ACR covers the full product and a feature exists within it, every criterion that applies to that feature must be evaluated.

Does N/A Require an Explanation in the Remarks Column?

Yes. Every N/A entry should include a brief remark explaining why the criterion does not apply. A remark like “Product contains no prerecorded audio or video content” gives the reviewer enough context to confirm the N/A designation is accurate.

Leaving the remarks column blank next to an N/A entry forces the reviewer to guess. At Accessible.org, every ACR includes clear remarks for each N/A criterion so that the reasoning is transparent and verifiable.

How Procurement Teams Interpret N/A Entries

Procurement reviewers at universities, government agencies, and enterprise organizations usually scrutinize ACRs. A pattern of excessive N/A entries raises immediate questions. If a web application marks several criteria as N/A, reviewers will cross-reference that against the product’s visible functionality.

Reviewers understand that a complex SaaS product with forms, media, navigation, and dynamic content will have very few legitimately N/A web-based criteria. When the numbers do not add up, the ACR loses credibility. In competitive procurement, that can be the difference between winning and losing a contract.

FAQ

Can I change a criterion from N/A to Supports after adding new features?

Yes. If a product adds functionality that triggers a previously N/A criterion, the ACR should be updated. For example, adding video content to a product that previously had none means captions criteria now apply. The updated ACR should reflect the current state of the product, with the newly relevant criteria evaluated and documented.

What if I am unsure whether a criterion applies to my product?

When there is any uncertainty, the criterion should be evaluated rather than marked N/A. An experienced evaluator can determine whether the content type or functionality described in the criterion exists within the product. If a criterion is borderline, evaluating it and documenting the result in the remarks column is always the safer and more credible approach.

Does marking a criterion N/A count against my product in procurement?

A legitimate N/A entry does not count against a product. Procurement scoring models typically exclude N/A criteria from the overall conformance calculation. The risk comes from misuse. If a reviewer determines that a criterion was incorrectly marked N/A, it may be rescored as Does Not Support, which directly lowers the product’s conformance rating.

Accuracy in an ACR protects the product’s position in procurement evaluations more than any attempt to minimize documented issues. Reviewers reward transparency because it signals that the evaluation was conducted with integrity.

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