Why VPATs Are No Longer Just for Platforms

What Publishers and Procurement Teams Are Seeing in Practice 

For many years, accessibility compliance in education publishing has been framed primarily as a platform responsibility. Learning management systems, content delivery portals, and assessment platforms were expected to provide VPATs and demonstrate conformance to accessibility standards. Content, by contrast, was often treated as subordinate—implicitly covered by the platform on which it was delivered.

That framing is now changing.

Across higher education, K–12, and public-sector procurement, digital instructional content itself—EPUBs, PDFs, and related formats—is increasingly being evaluated as a standalone product that must independently demonstrate accessibility conformance.

In April 2024, the U.S. Department of Justice issued a Final Rule under ADA Title II clarifying that public entities must ensure that their digital content conforms to WCAG 2.1 Level AA by April 2026. While the rule does not mandate VPATs by name, it has had a clear downstream effect: institutions now require auditable, defensible evidence of accessibility conformance for the materials they procure.

In practice, VPAT-based Accessibility Conformance Reports (ACRs) have emerged as the most widely accepted mechanism for providing that evidence.

Procurement documents increasingly reference digital instructional materials, not just platforms. Publishers are therefore seeing requests for accessibility documentation at the title or edition level rather than only at the platform level.

Publishers have made significant investments in accessibility workflows and certifications such as Benetech Global Certified Accessible (GCA). These programs demonstrate process maturity and commitment. However, procurement and accessibility offices typically require product-specific evidence when making compliance determinations.

As expectations rise, both publishers and institutions face operational challenges: repeated audits, inconsistent documentation, high costs, and difficulty maintaining currency. These challenges suggest a structural shift rather than isolated friction.

S4Carlisle Publishing Services is conducting independent research to understand how content-level VPAT and ACR expectations are emerging, what procurement teams consider acceptable, and how documentation can scale sustainably.

Standardizing content-level accessibility is a complex task, but it’s a necessary one. We invite you to contribute your voice to our research and help define the future of sustainable compliance by participating in a short survey or conversation to help validate these findings. Write to us at nandak@s4carlisle.com if you need further information.