The process of identifying and vetting products for the NCADEMI EdTech Accessibility Directory has brought a significant challenge to the forefront: the often-opaque nature of Voluntary Product Accessibility Templates (VPATs). While these documents are crucial for assessing the accessibility of technology, many vendors in the EdTech sector do not make them readily available, instead requiring potential customers to formally request them. This practice has raised questions about the effectiveness of accessibility efforts and the ease with which educational institutions can procure truly inclusive technologies.
Understanding the Voluntary Product Accessibility Template (VPAT)
At its core, the VPAT is a standardized document developed by the Information Technology Industry Council (ITI). Its purpose is to translate complex accessibility standards, such as those mandated by Section 508 of the U.S. Rehabilitation Act and international guidelines like EN 301 549, into practical, testable criteria for technology products and services. A completed VPAT, often referred to as an Accessibility Conformance Report (ACR), provides a detailed account of a product’s compliance with various accessibility features, indicating whether it meets, partially meets, or does not meet specific requirements.
The need for such a template arose from the inherent difficulty in evaluating the accessibility of rapidly evolving technology. As noted in a 2021 ITI blog post, "Many employees living with disabilities rely on internet-, hardware-, and software-based accessibility solutions to help empower them in their workplaces. Although minimum U.S.-based and international legal standards exist for accessible technologies, determining whether a product will fully meet employees’ needs can be challenging." The VPAT serves as a vital tool for potential users and customers, offering them a structured way to gauge the accessibility of a product before making a purchasing decision.
The Gatekeeping of Accessibility Information: Vendor Perspectives and Criticisms
The practice of requiring a formal request for a VPAT, rather than making it publicly accessible, has been a recurring observation during the development of the NCADEMI EdTech Accessibility Directory. This approach has been met with bewilderment from accessibility advocates and procurement specialists alike. The fundamental question arises: "Why would a vendor allocate resources to creating a VPAT only to create a friction point for someone that is interested in giving you money?"
To explore potential vendor rationales, an inquiry was posed to several AI agents, asking why a vendor might legitimately require a potential client to request a product’s VPAT. The synthesized responses broadly fell into three categories: customized information, competitive information, and the need to ensure correct information is disseminated.
Customized Information: Tailoring Accessibility Data
One hypothetical vendor concern suggests: "We have an extensive list of products and need to make sure that potential customers have the right information based on which version or configuration of a product they are considering." This concern highlights the complexity of product offerings, where different versions or configurations might have varying levels of accessibility.
However, the VPAT template itself is designed to address this. It encourages vendors to specify the relevant product version or configuration. In instances where accessibility features remain consistent across multiple iterations, a single VPAT can be scoped to cover these. Therefore, the argument for requiring a request based on product versions could be more effectively managed by vendors proactively providing current and appropriately scoped VPATs, rather than placing the onus on the potential customer to navigate this request process.
Competitive Information: The Proprietary Data Dilemma
Another frequently cited reason for withholding VPATs is the protection of proprietary information. A vendor might state: "We can’t make proprietary information available publicly. We even require prospects to sign a non-disclosure agreement (NDA)." This stance suggests a belief that the detailed accessibility conformance data within a VPAT constitutes sensitive business intelligence.
This concern is directly challenged by institutions prioritizing accessibility in procurement. The California State University San Marcos, for example, explicitly states on its VPAT Vendor Requirements page that "A VPAT does not contain or disclose proprietary information; instead, quality VPATs will faithfully represent a product’s current accessibility conformance, whether accessible or inaccessible." They further elaborate that "The current accessibility conformance of any product is readily available to anyone accessing a product’s interface, and as such, CSUSM will not sign vendor NDAs to receive accessibility conformance documentation." This position underscores the understanding that accessibility conformance is not proprietary but rather a fundamental characteristic of a product’s usability.
Correct Information: Navigating Diverse Regulatory Landscapes
A third vendor rationale revolves around ensuring accuracy for a diverse clientele: "We sell our products to customers from a range of countries across public and private industries. We need to make sure that our prospects get the right information." This concern points to the varying legal and technical standards for accessibility that exist globally.
The VPAT framework itself is designed to accommodate these differences. There are multiple editions of the VPAT, including those aligned with Section 508 (U.S.), EN 301 549 (European Union), WCAG (Web Content Accessibility Guidelines), and international standards. Furthermore, within the WCAG editions, there are variations to address different versions of the guidelines. Vendors can leverage these different VPAT editions to provide prospects with information tailored to their specific regulatory requirements. In addition to providing the appropriate VPAT, vendors can also offer supplementary guidance and documentation to clarify accessibility conformance for diverse customer bases.
Quantifying the VPAT Availability Challenge
The anecdotal observation of limited VPAT availability has been substantiated by preliminary research conducted for the NCADEMI EdTech Accessibility Directory. The project, which currently features around 60 published products, has prompted a broader investigation into the accessibility documentation practices of EdTech vendors.
A comprehensive analysis was undertaken, generating a list of over 231 K-12 products identified as having "moderate usage" based on AI-driven research. The web pages and accompanying documentation for these products were then analyzed using Google Gemini to detect references to VPATs.
The findings revealed a significant gap in accessibility transparency. Of the 186 unique vendors represented across these 231 products, only 35 (approximately 19%) provided any reference to VPAT information. This means that nearly four out of every five K-12 EdTech products reviewed did not readily indicate their accessibility conformance status.
Furthermore, among the vendors that did reference VPATs, a substantial portion (more than 1 in 5, or 22%) still required potential customers to request the document, rather than making it publicly accessible. While this AI-driven research is not a definitive, exhaustive assessment, it strongly suggests that access to product VPATs remains a pervasive challenge for educational institutions seeking to ensure digital accessibility.
A Glimmer of Transparency: Vendors Providing Public VPATs
Despite the general trend of limited availability, some vendors are making their VPATs publicly accessible, demonstrating a commitment to transparency and an awareness of accessibility guidelines. As of the early stages of the NCADEMI directory, 27 vendors have provided public access to their VPATs.
However, even among these vendors, there is room for improvement. Of the 27 publicly available VPATs, six were found to have failed an accessibility evaluation themselves. This highlights that the mere act of publishing a VPAT does not automatically guarantee a product’s accessibility; the document itself must also be accessible and accurately reflect the product’s conformance.
Nevertheless, it is important to acknowledge the 21 K-12 EdTech vendors who have provided publicly available and accessible VPATs. Their proactive approach contributes to a more informed procurement process for educational institutions.
Charting the Path Forward: Enhancing Accessibility Procurement
The infrastructure and best practices for improving accessibility procurement already exist. Tools like OpenACR, developed by the U.S. General Services Administration (GSA) and CivicActions, are transforming VPAT data into searchable YAML and JSON formats. This allows buyers to efficiently compare vendors based on their accessibility conformance, moving beyond the laborious task of individually sifting through numerous VPAT documents.
For educational institutions that are serious about digital inclusion, best practices extend beyond simply obtaining a VPAT. This includes pairing VPAT data with a clear, plain-language accessibility statement that outlines the institution’s commitment and goals. Crucially, for products that only partially meet critical accessibility criteria, a remediation roadmap with a defined timeline for improvements is essential. This proactive approach ensures that accessibility is not an afterthought but an ongoing commitment, with clear steps for achieving full compliance.
The ongoing challenge of VPAT accessibility underscores the need for greater vendor accountability and a more streamlined procurement process. By encouraging greater transparency and adopting robust evaluation methods, the EdTech landscape can move closer to ensuring that all students and educators have equitable access to digital learning tools.
