
Procurement · EN 301 549 · WCAG 2.2 AA
The report procurement asks for, and why a statement is not it
A public buyer or a large corporate does not want a page on your website. They want a document that goes criterion by criterion, says pass, fail or not applicable for each one, names the date and the scope, and can be attached to a bid. Suppliers who have one answer in a day. The rest spend two weeks writing something that looks like it, usually after the deadline has been extended once.
Statement, report, VPAT: three different documents
| Document | Audience | What it contains |
|---|---|---|
| Accessibility statement | Consumers and authorities | Plain description of the service, standard applied, known limitations, contact point |
| Conformance report | Procurement and buyers | Every criterion with pass, fail or not applicable, evidence, date, scope, tools |
| VPAT | Mostly US buyers | The same idea in a fixed template, usually against Section 508 and WCAG |
They come from the same test. Producing them separately, months apart, is how the three documents end up contradicting each other, which is the failure a diligent buyer notices.
Why public buyers ask at all
Public sector bodies in the Union have their own accessibility duties for their websites and apps, and they discharge part of them by requiring accessible components from suppliers. Directive 2016/2102 sits behind that for public bodies, EN 301 549 is the standard named in public procurement of ICT, and the questionnaire is how the duty travels down the chain. Large corporates copy the same questions, partly for their own obligations and partly because their legal teams read the same directive.


What a good answer looks like
- Scope stated exactly: which product, which version, which platforms, what was excluded and why.
- Standard named with its level: EN 301 549 with WCAG 2.2 AA, not "accessible" or "compliant".
- Criterion-by-criterion results, including the ones that fail, with what you are doing about them.
- Method: tools, assistive technology, browser and platform versions, journeys tested.
- Date, and a person or company that signed it.
Buyers do not expect a perfect score. They expect an honest one with a plan, and they discount a report with no failures at all, because everyone in that room knows what a real audit finds.
The claims that lose bids
"100 per cent compliant" is the first. "Certified accessible" is the second, because there is no certification to hold. An overlay licence presented as conformance is the third, and it is increasingly disqualifying: procurement teams have read the same litigation reports as everyone else. A report that is honest about three open failures beats a claim that cannot survive a follow-up question.
Timing, and the mistake everyone makes
The questionnaire arrives with the rest of the bid pack, usually ten working days before submission. A real audit takes longer than that, which is why the report has to exist before the tender does. Suppliers who bid regularly keep a current report on the shelf, retested on a cycle, and update the scope section per bid rather than starting from nothing.
When the buyer asks for a remediation plan
Many questionnaires ask not only for the current state but for the roadmap: what is failing, when it is fixed, who owns it. A plan with dates and named owners scores; a plan that says "continuous improvement" does not. Where the failure sits in a third-party component you cannot change, say so, name the component and say what you asked the vendor.


Public sector in the UK asks the same thing differently
UK tenders reference the Equality Act and, for public bodies, the 2018 regulations, then ask for a WCAG 2.2 AA report anyway. We sign that report through REP27 LTD, a British company, because buyers prefer a signature from an entity in their own jurisdiction. The underlying test is the same one used for the EU statement.
What an evaluator does with your report
They score it, and they usually score three things: whether the scope matches what they are buying, whether the standard and level are named properly, and whether the failures come with owners and dates. A long document with no scope section scores worse than a short one with a precise one, because the evaluator cannot tell what was actually tested.
Some buyers go further and spot-check a claim: they open the product, tab through a form and see whether the report told the truth. A report that survives that check is worth more than any certificate, and a report that does not ends the relationship before it starts.
Answering the same questionnaire twice a year
Suppliers who bid regularly notice that the questions repeat with small variations: scope, standard, results, remediation plan, responsible contact, date of last test. Keeping a single source of truth, the report, and generating each answer from it removes the drift where one bid says WCAG 2.1 and the next says 2.2 for the same release.
It also removes the worst outcome, which is a claim made by a salesperson under deadline pressure that the technical team cannot support three months later during the acceptance test.
What we deliver for a bid
A conformance report criterion by criterion with date and scope, a short summary page a non-technical evaluator can read, the developer report behind it, and a signed record with a public code the buyer can verify. Where a VPAT template is requested, we fill it from the same results. See the audit and how the UK side works.
Questions we get before buying
Is a VPAT the same as a conformance report?
A VPAT is a template for one. The substance is identical, the layout is what US buyers expect.
Can we send our accessibility statement instead?
Only if the questionnaire asks for one. A statement lacks the criterion-by-criterion table that scores the bid.
Does a failing criterion lose the contract?
Rarely on its own. An unexplained gap or an unsupportable claim does more damage than an honest failure with a date.
How current does the report have to be?
Most buyers accept twelve months. Some public bodies ask for six, especially after a major release.
Who signs it?
The company that ran the test. We sign through Europe Services SE for EU buyers and REP27 LTD for UK buyers.
Can we produce it ourselves?
Yes. Buyers weigh a self-issued report against an independent one, and the more diligent the buyer, the more that difference counts.
Do we need one for every product?
Per product, and per major version where the interface changed. Scope is the first thing an evaluator reads.
What if a failure is in a third-party component?
Say so, name it, and show what you asked the vendor. Buyers deal with the same components and know the answer.
How fast can you produce one?
Five business days from your scope answers for a standard product, longer for large applications, quoted first.
Will you complete the buyer’s own spreadsheet?
Yes, from the same results, as long as the questions map to a recognised standard.
Have the report before the bid pack arrives
Criterion by criterion, dated, scoped, signed, with a public code the buyer can verify.