Businesses are focusing on their digital presence like never before. Since that is the only way to scale and expand the business beyond boundaries. And digital world requires every digital product to be accessible to all. The growing demand of digital accessibility has made it a business imperative to own an accessible website or application.
With regulations like the European Accessibility Act (EAA) coming into force, businesses selling digital products or services in the EU must ensure their offerings are accessible to people with disabilities. One critical part of demonstrating compliance is the Voluntary Product Accessibility Template (VPAT), which serves as the basis for the Accessibility Conformance Report (ACR).
But there is a catch - VPATs and ACRs are only as accurate and reliable as the audits backing them. And hence, manual accessibility audits are a must to conduct.
VPAT and ACR – Critical document for digital products!
A VPAT is a standardized document that outlines how an ICT (Information and Communications Technology) product or service conforms to accessibility standards, such as EN 301 549 (required under the EAA), WCAG 2.1/2.2, or Section 508. When a VPAT is completed, it becomes an Accessibility Conformance Report (ACR) - a formal disclosure of the product’s accessibility status. This document is often required during procurement processes by government agencies or large organizations.
However, creating a meaningful and trustworthy ACR requires more than filling in checkboxes. It demands thorough, expert-backed validation - and that’s where manual audits come into play.
The crucial role of manual audits in EAA VPAT/ACR documentation
- Uncovering real-world accessibility barriers
Automated tools can detect up to 30% of accessibility issues. But they can’t assess:
- Keyboard navigation
- Screen reader compatibility
- Logical focus order
- Visual indicators for users with cognitive disabilities
- Content clarity or alternative text context
A manual accessibility audit, conducted by human accessibility experts, dives deep into these areas. It reveals practical issues users with disabilities face, providing insights that automated tools simply miss.
- Providing accurate test results
VPAT documentation includes a detailed breakdown of how the product meets specific criteria of EN 301 549. Each success criterion must be marked as:
- Supports
- Supports with exceptions
- Does not support
- Not applicable
Only with manual audits can evaluators accurately justify these claims. They provide tested evidence and screen reader walkthroughs that validate the product’s conformance level.
- Ensuring alignment with EAA and WCAG standards
The European Accessibility Act aligns closely with WCAG 2.1 and 2.2, as well as EN 301 549. Manual audits ensure that a digital product is tested specifically against these standards - not just in theory, but in action:
- Is the video player accessible with captions and transcripts?
- Does the mobile app pass color contrast and touch target guidelines?
- Can a user with limited mobility complete checkout or booking?
This level of granular validation strengthens the credibility of the ACR.
From audit to ACR: The process!
Here is how a manual audit supports and integrates into VPAT/ACR documentation:
- Scope definition
Define the digital product (website, app, software) and the standards it will be tested against.
- Manual accessibility testing
Expert testers use assistive technologies (screen readers like NVDA, JAWS, VoiceOver), keyboard-only navigation, and browser/device simulations.
- Issue logging and severity rating
Every failure is documented with steps to reproduce, screenshots, and impact on the user experience.
- Mapping findings to VPAT criteria
Each relevant success criterion from EAA EN 301 549 or WCAG is cross-referenced with test results.
- Filling the VPAT template
Using the audit findings, the VPAT is filled with confidence and clarity, noting full, partial, or no support for each criterion.
- Final ACR report generation
The result is a comprehensive and compliant Accessibility Conformance Report – backed by expert testing, not just guesswork.
Benefits of manual audit-backed ACRs
- Improved trust with buyers
Clients and procurement officials can trust the organization’s claims when they are grounded in real user testing.
- Legal protection
A properly completed, audit-backed ACR reduces the legal risks under the EAA and other global laws.
- Better product accessibility
The audit doesn’t just tick a compliance box - it identifies real improvements that make the product usable by all.
- Competitive edge
Many businesses can produce a VPAT. Few can show they’ve invested in quality, human-led assessments.
Skynet Technologies: Your partner in EAA Accessibility!
At Skynet Technologies, we specialize in manual accessibility audits and full support for VPAT and ACR documentation. Our certified accessibility experts test the product thoroughly, remediate issues, and help organizations produce a defensible and detailed ACR tailored for EAA and EN 301 549 compliance.
We offer:
- Manual audits (WCAG 2.2, EN 301 549, ADA, Section 508)
- VPAT drafting and finalization.
- Accessibility consulting and remediation
- Assistive tech testing and usability validation.
Also read: EAA vs. ADA: Digital Accessibility Compliance Guide
A VPAT without a manual audit is just a guess!
If an organization is preparing for the European Accessibility Act or wants to participate in large public-sector contracts in the EU or the US, it needs more than automated scans and surface-level reports. Organizations need proof that their product truly works for people with disabilities.
A manual audit lays the foundation for reliable, compliant, and effective VPAT/ACR documentation - giving organizations confidence in their accessibility journey and credibility in the market.
At Skynet Technologies, we provide manual accessibility audit, EAA VPAT and ACR documentation, uncovering barriers that impact real users. Our detailed approach ensures your compliance efforts are accurate, credible, and user-centered. Kick-start accessibility with our manual accessibility audit or reach out [email protected].