How current does your accessibility conformance report need to be?
Updated 2026-10-13 · by Hieu Tran, written with AI agents and checked against the sources below
An ACR (a filled-in VPAT) is a dated claim about one version of your product. Buyers at universities, school districts and agencies read it before they buy, and the ADA Title II web rule now covers the third-party software they use. There's no single legal expiry date for a report, but there are things reviewers check every time.
Link your published VPAT/ACR (PDF or web page) or open the file: it's read in your browser and checked against what reviewers look for.
What reviewers check
The date. Many buyers expect a report from the last 12–18 months, and ask again at renewal or after a major release. That's procurement practice, not a rule; procurement pages ask for a “current” report.
The template. ITI's current version is VPAT 2.5Rev (April 2025): 508, EU, WCAG and INT editions. The WCAG and INT editions include WCAG 2.2.
WCAG 2.2. Published 5 October 2023; adds 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum) (AA), 3.2.6 Consistent Help, 3.3.7 Redundant Entry (A), 3.3.8 Accessible Authentication (Minimum) (AA), plus three AAA criteria, and removes 4.1.1 Parsing.
Ratings. Supports, Partially Supports, Does Not Support, Not Applicable, with remarks. A report where everything “Supports” reads as untested.
Evaluation methods. Which tools, assistive technology and manual checks were used. Automated tools alone cover a minority of WCAG criteria.
Why the requests are increasing
The Department of Justice's ADA Title II rule requires state and local governments' web content and mobile apps, including third-party software they use, to meet WCAG 2.1 AA. An interim final rule of 20 April 2026 set the compliance dates to 26 April 2027 for entities serving 50,000 or more people and 26 April 2028 for smaller ones and special districts. Public universities and school districts are covered, so their procurement teams ask vendors for evidence.
Keeping it current without a new audit every quarter
Keep the manual test results (keyboard, screen reader, zoom) as data, per criterion, with the version tested.
Run automated checks on each release and note which criteria they touch.
On each release, re-test only what changed, update those rows, and re-date the report.
Say plainly in the report which results are automated and which were tested by a person.