Why you’re being asked
Buyers now have dated, written reasons to ask for an ACR.
An ACR tells a buyer, criterion by criterion, how your product meets an accessibility standard.
Without one, a purchase can stall in procurement or legal review. Three kinds of buyers have
concrete reasons to ask:
April 26, 2027
Public universities, states, large cities and counties
Under the ADA Title II rule, public entities with a total population of 50,000 or more must meet
WCAG 2.1 AA for web content and apps they provide “directly or through contractual, licensing, or
other arrangements.” A state university counts its state’s population. Smaller entities and special
districts: April 26, 2028.
Source: 28 CFR 35.200, as amended by the
April 20, 2026 interim final rule;
ADA.gov.
WCAG 2.0 AA
Federal agencies
Section 508 covers the technology federal agencies develop, procure, maintain or use. The Revised 508
Standards apply WCAG 2.0 Level A and AA to software and web content, and GSA’s buyer guidance tells
agencies to require an ACR for each commercial product.
Source: 36 CFR part 1194 (E205.4, E207.2);
Section508.gov.
12 months
Higher-ed vendor reviews
The HECVAT 4 questionnaire (version 4.1.6) asks whether your VPAT® or ACR was created or updated for
the version under consideration within the past 12 months, and whether a third-party expert audited
your most recent version.
Source: EDUCAUSE HECVAT 4.1.6, questions ITAC-06 and ITAC-11.