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RE: About VPAT usage in the EU

From: Joppe Kroon <J.Kroon@topdesk.com>
Date: Wed, 23 Oct 2019 09:11:23 +0000
To: "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Message-ID: <8cafc9e98456473190c9b9d2d47fdbb5@KIM02.tis.local>
Disclaimer: I’m not in the sales department, but I have my ear to the ground for this subject 😉

> Joppe, what kinds of accessibility documentation do they request?
They don’t… ☹

There have recently been a few cases where RFI’s have included questions on accessibility. Usually taking the form of the single question: “do you adhere to WCAG?”. But occasionally we get an RFI where the WCAG success criteria have basically been copy-pasted.

But at no point (as far as I know) have we had a request for official documentation on accessibility from any of our non-US customers.


From: Mitchell Evan<mailto:mtchllvn@gmail.com>
Sent: Monday, October 21, 2019 7:05 PM
To: Joppe Kroon<mailto:J.Kroon@topdesk.com>
Cc: w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>
Subject: Re: About VPAT usage in the EU

More anecdotes... US-based ICT suppliers often do use the VPAT International edition when they want to reach buyers in both the US and Europe public sectors. Suppliers might be using VPAT for disclosure to European buyers more often than a web search would suggest, because only a small fraction of companies post their VPAT reports publicly (examples: Microsoft<https://www.microsoft.com/en-us/trust-center/compliance/accessibility>, Adobe<https://www.adobe.com/accessibility/compliance.html>). Most companies provide them directly to buyers on request.

...and more questions...

> We have been doing business for more than two decades in Europe, including many public sector bodies, and have never encountered anyone asking for a VPAT document

Joppe, what kinds of accessibility documentation do they request?

> The term I would expect in a European context is "Supplier's Declaration of Conformity"

Christophe, this sounds reasonable. How common is it in practice, as a means of accessibility disclosure to buyers? Searches for "Konformitätserklärung" and "BITV" on ted.europa.eu<https://ted.europa.eu> yield few results.


Mitchell Evan
+1 (510) 375-6104

On Mon, Oct 21, 2019, 2:52 AM Joppe Kroon <J.Kroon@topdesk.com<mailto:J.Kroon@topdesk.com>> wrote:
Hi Sailesh,

Another anecdote,

We have been doing business for more than two decades in Europe, including many public sector bodies, and have never encountered anyone asking for a VPAT document.
Only since entering the American market we have had our first request for a VPAT.

We found that there are several VPAT versions available, including an international VPAT where Section 508, WCAG 2.1, and EN 301 549 are all included.

I think it is fair to say that a VPAT is not usually required in the EU, but I found the (full) VPAT helpful to collect all issues and cover all our bases.


From: James A.<mailto:A.James@soton.ac.uk>
Sent: Friday, October 18, 2019 8:17 PM
To: Sailesh Panchang<mailto:sailesh.panchang@deque.com>
Cc: Christophe Strobbe<mailto:strobbe@hdm-stuttgart.de>; w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>
Subject: Re: About VPAT usage in the EU

From my experience with UK universities, VPATs cause more confusion than assistance as they are structured for the US regulatory framework. They create more questions than answers.

Public sector organisations are increasingly asking vendors to provide details of compliance due to new regulations that make them responsible for the accessibility of 3rd party content on their digital platforms if they have paid for it.  Organisation want vendors to provide  details of what does and doesn't comply with WCAG 2.1 AA /en 301 549 so that they can add details to their accessibility statements. This includes description of accessibility limitations in layman’s terms for users to understand. There is growing interest in using Mandate 376 procurement toolkit based http://mandate376.standards.eu/standard which is based on EN 301 549.

Best wishes

Abi James

University of Southampton

On 16 Oct 2019, at 20:07, Sailesh Panchang <sailesh.panchang@deque.com<mailto:sailesh.panchang@deque.com>> wrote:
Thanks very much Christophe for the confirmation and the  supporting details.
Best wishes,

On 10/15/19, Christophe Strobbe <strobbe@hdm-stuttgart.de<mailto:strobbe@hdm-stuttgart.de>> wrote:

Hi Sailesh

On 10/10/19 19:31, Sailesh Panchang wrote:
Is it customary  in the EU to require ICT vendors  to provide a VPAT
to support an accessibility claim for ICT-product / service?
In other words, do public sector bodies   or corporations in the EU
require  a VPAT from their ICT vendors?

The VPAT is something I only know from the context of Section 508 of the
USA's Rehabilitation Act.
When I searched a number of European top-level domains for VPAT
(combined with the terms "accessibility" and "template"), I found
companies and institutions that mention Section 508. I have listed a few
examples below.

The term I would expect in a European context is "Supplier's Declaration
of Conformity", but since that is based on an ISO standard (ISO 17050),
there is not specifically European about it.

* University of Northampton: The Kaltura Accessibility statement:
https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Faskus.northampton.ac.uk%2FLearntech%2Ffaq%2F188896&amp;data=01%7C01%7Ca.james%40soton.ac.uk%7C4ed8f19d91a042752c8a08d7526c0955%7C4a5378f929f44d3ebe89669d03ada9d8%7C0&amp;sdata=RKN5anthheQV5BawpxnEleB7Z%2BkBg6%2BKEA3Y8AmPn3w%3D&amp;reserved=0 (Mentions WCAG 2.1
AA but not Section 508.)
* ZenDesk:
(WCAG 2.0 and Section 508.)
* PebblePad UK:
(Section 508 of the Rehabilitation Act and WCAG 2.1 Levels A and AA.)
* ARROW@TU Dublin: https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Farrow.dit.ie%2Faccessibility.html&amp;data=01%7C01%7Ca.james%40soton.ac.uk%7C4ed8f19d91a042752c8a08d7526c0955%7C4a5378f929f44d3ebe89669d03ada9d8%7C0&amp;sdata=kmfLmIkRuzVJwdfl%2Fm7E8qvTUd%2FWUQhQzMS2f892BiA%3D&amp;reserved=0 (WCAG 2.0
Level AA and Section 508.)
* SWORD - South West Open Research Deposit (Cork, Ireland):
https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsword.cit.ie%2Faccessibility.html&amp;data=01%7C01%7Ca.james%40soton.ac.uk%7C4ed8f19d91a042752c8a08d7526c0955%7C4a5378f929f44d3ebe89669d03ada9d8%7C0&amp;sdata=rEYKBtkzGHYfMbNsap9RbIJ%2FmhNcCoX6Chnn6YSG%2Fio%3D&amp;reserved=0 (WCAG 2.0 Level AA and Section
* Communardo (German domain):
(Confluence is developed by the Australian company Atlassian.)

Best regards,

Christophe Strobbe

Christophe Strobbe
Akademischer Mitarbeiter
Responsive Media Experience Research Group (REMEX)
Hochschule der Medien
Nobelstraße 10
70569 Stuttgart
Tel. +49 711 8923 2749

“I drink tea and I know things.”
Falsely attributed to Christophe Lannister.

Sailesh Panchang
Principal Accessibility Consultant
Deque Systems Inc
381 Elden Street, Suite 2000, Herndon, VA 20170
Mobile: 571-344-1765

Received on Wednesday, 23 October 2019 09:11:32 UTC

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