Accessibility statement vs. VPAT: which document does your site actually need

If your site serves both EU and US visitors, you may need both of these documents — and they're genuinely different formats, not two names for the same thing.

The EU accessibility statement

Required under the EAA (and, for public-sector sites, under the earlier Web Accessibility Directive), an accessibility statement is a single published document, in a fixed structure set out in Annex V of the relevant implementing decision, covering: the standard you're conforming to (citing EN 301 549), a statement of compliance status, any content you're claiming is exempt and why (including any disproportionate-burden justification), and a feedback mechanism for reporting accessibility problems. It's written in prose, published as its own page, and meant to be readable by an ordinary site visitor, not just a compliance specialist.

The US VPAT / ACR

A VPAT (Voluntary Product Accessibility Template) is a blank document format, maintained by the Information Technology Industry Council, filled out per-product. Once completed, the filled-in version is called an ACR (Accessibility Conformance Report). Unlike the EU statement's prose format, a VPAT/ACR is structured as a table: every applicable technical criterion gets a specific conformance level — Supports, Partially Supports, Does Not Support, or Not Applicable — with a remarks column for explanation. It's built for procurement audiences (particularly US government and enterprise buyers who are required to evaluate accessibility as part of purchasing decisions), not for a general site visitor.

Same underlying scan, two different outputs

Here's the part that matters practically: both documents are describing the same underlying technical reality — how well your site conforms to WCAG success criteria. WCAG 2.1 AA is a strict superset of Section 508's older WCAG 2.0 AA baseline and satisfies ADA Title II's requirement directly, so the same audit evidence can produce either document. You're not running two separate technical processes; you're presenting one set of findings in two different formats for two different legal contexts.

This is exactly why Cluesia asks which market a site targets when you add it: choosing "EU" produces an Annex V-style accessibility statement from your audit results, and choosing "US" produces a VPAT/ACR instead — from the same underlying WCAG scan.

Which one do you actually need?

• Selling to or serving EU consumers, not a qualifying micro-enterprise: you need an accessibility statement. This isn't optional once the EAA applies to you.
• A US state or local government entity: Title II now codifies WCAG 2.1 AA; a VPAT/ACR is the standard way to document conformance, though the specific documentation format required can vary by contracting context.
• A US private business selling to enterprise or government buyers: you'll likely be asked for a VPAT/ACR during procurement even without a blanket legal mandate, since many buyers require one as part of vendor evaluation regardless of your specific ADA Title III exposure.
• Both: produce both, from the same underlying audit.

See pricing to run an audit that produces the right document for your market, or check your website for free first to see where you currently stand.