Publish VPAT based Accessibility Conformance Report(s) ACR

This comes up from time to time, and unfortunately The Document Foundation has not yet generated the “voluntary” Accessibility Conformance Report (ACR) based on VPAT. Institutional and governmental users often need such ACR to document compliance/support of accessibility standards, i.e. W3C/WAI WCAG, EN 301 549 (EU), or Section 508 (US).

Believe VPAT based ACR should be published for the UI of TDF delivered LibreOffice builds. While Community built products (e.g. Zeta Office, Collabora Office) would be well aided by a central repository of accessibility information for the LibreOffice core, with ability to document facets unique to their builds.

Recommend BoD should resolve, and tender if needed, to post suitable ACR from completed VPAT to the Foundation WiKi, perhaps best hosted to the TDF Accessibility page [1].

Reporting VPAT format is rather flexible, but the VPAT 2.5 templates provided by the Information Technology Industry Council (ITI) [2] are suitable to task, though in OOXML rather than ODF :wink:

Looks like their “International” flavor might be the best template to complete for LibreOffice.

The effort would be helpful to document Foundation commitment to and the state of compliance with accessibility standards. It would really help keep institutional and governmental adopters compliant with accessibility regulations.

[1] Accessibility - The Document Foundation Wiki
[2] VPAT - Information Technology Industry Council

1 Like

Can you give an example of how having this report is necessary? Does it relate to some regulatory requirements (e.g. using a piece of software in a government facility)? If so - have we had relevant experience with this during adoptions in larger bodies like Tirana IIANM, Munich, or recently Schleswig-Holstein?

The VPAT is only relevant for US based institutions and government bodies, and does not apply to European ones. Lack of these documents is one of the reasons of our weakness in the US, where we have a very large number of individual users but a very small number of enterprise, institutional and governmental users.

1 Like

No Italo, the term VPAT is a broadly misused shorthand for a compliance testing requirement levied on the vendor of a communications product. Yes it arose from the US Section 508 of the Rehabilitation Act (29 U.S.C. 794d) but its use is international in scope. Applicable to characterizing W3C/WAI WCAG Web Content Accessibility Guidelines, or the EN 301 549 European Standard for ICT Accessibility, so what is actually required and would be useful for TDF to curate is an Accessibility Conformance Report (ACR).

In effect the VPAT can be any documentation template (guiding the testing and reporting effort to standard) but no standard exists, but the ITI offerings are broadly accepted/adopted. A single ACR could be produced (though translations might be appropriate). It would satisfy compliance considerations for adopters/implementers of a LibreOffice based Office suite.

1 Like

Sure, in the United States Federal Departments and Agencies are required under Section 508 of the Rehabilitation Act - 29 U.S.C. § 798 to comply with requirements for accessibility in Electronic and Information Technology as maintained by the US Architectural and Transportation Barriers Compliance Board (a.k.a. ‘Access Board’). Compliance is evaluated during the “procurement” of such Information Technology and Communications (ITC) products. So the “vendor” is pressed into documenting their products compliance with accessibility. Similar vendor assessment reporting of information security concerns under the US FedRAMP (risk and authorization management) program causes similar procurement grief, desktop versions of LibreOffice not affected–but the Ecosystem partners should check that out for their collaborative offerings.

While a Federal requirement, most US States comply with the Federal procurement requirements as not doing so puts their apportionment at risk. So Section 508 Accessibility requirements come along with the package. That extends down to local municipalities, public school districts, community colleges, etc.

And the chilling effect is that procuring, and operating non-accessible ICT places these governmental branches at risk of Section 508 compliance complaints or civil action.

Non-governmental and private entities may face civil action for not offering accessible services, so most will follow Section 508 practices when procuring ICT.

In my past professional life as a sysadmin and lab manager at a large research University I had to chase down ACR for multiple software products to satisfy procurement requirements for compliance before deployment. I did get to sidestep that for my LibreOffice installations, but having an ACR would have better covered the requirements or a compliance audit. Others simply don’t have that option and an ACR would be helpful.

Can’t speak directly to European Nations, but believe Sophie is up to speed on the corresponding EN 301 549 standard for the EU, and if any governmental (or private business) adopters had ICT accessibility compliance concerns.

Obviously LibreOffice as an ICT “procurement” as an office suite is as a generator of documents. So we do need to be concerned that we produce accessible documents, e.g. our ODF, SVG, PDF/UA, EPUB. But equally we also need to be concerned that the User Interface of LibreOffice is as accessible as feasible. And both facets should be addressed in a TDF curated Accessibility Conformance Report made readily available to any user or “procurement” official.

2 Likes

You can see the Microsoft prepared ACRs for their offerings here:

Think an ACR for the TDF Community build of LibreOffice posted to the TDF Accessibility wiki would cover a lot of territory.

Given your experience as a sysadmin and lab manager at a large research University, would you be able to support us in the process of creating a VPAT? Of course, only if needed. We would like to produce one for LibreOffice 25.2, which means mid-February as a starting date for the process.

If the BoD resolves to prepare an Accessibility Conformance Report and host it, then of course.

Myself and numerous trustees and contributors active on the accessibility@ ML could certainly undertake the testing using one of the VPAT templates, gratis. Just need some direction.

Likewise it seems a reasonable TDF expense to put out for tender.

Point is we need BoD resolution accepting TDF ownership of the process to get an ACR for LibreOffice prepared and hosted. And probably support from Staff to coordinate such ad-hoc committee to undertake the assessment(s), or to prepare a tender request if that is the decision.

My preference is a single ACR for the full LibreOffice suite, but a case can be made that each module should receive its own ACR. Either way use of ITI’s International VPAT template to record WCAG, EU (EN 301 549) , and US (Sec 508) criteria into a single report probably makes sense.

BoD should understand that such ACR reporting does not obligate changes to the evaluated ICT i.e. LibreOffice, it is meant only to document testing conformance in achieving the indexed success criteria against the standards.

A maintained current ACR could then help in categorizing development efforts needed to address accessibility deficiencies in the project. And to some extent help prioritize what gets addressed by TDF resources.

Its up to the Board, they do read this Discourse, right?

3 Likes

If this process requires some work on RTL-related aspects, do ask for help (i.e. not you personally, whoever is working on authoring such a document), e.g. on the LibreOffice RTL channel. Same for CJK I guess. I’m sure there would be at least some volunteers (if only because I’m there).

3 Likes

just to add to this topic. In Canada, all levels of government/school boards software procurement require an Accessibility Conformance Report (ACR) using the VPAT template.

Thus a filled LibreOffice VPAT for potential use in these institutions are crucial in being officially accepted in software procurement.

*Note that I have also checked for Mexican software procurement and, although officially not necessary, more and more ACR are being requested. So best to consider the same with any Mexican procurement requirement.

1 Like

Awaiting Board action! …or even a comment :wink:

Already proposed for the agenda after FOSDEM.

I’m totally in favour of doing it.

Hi,
I took the AI during our meeting. I’ve downloaded the EN 301 549, the international VPAT template and also the Technical Report who provides some guidance. I’ll read them through tomorrow and will get back to you, Marc and Michael on Monday, to further work together on narrowing what is needed to complete the ACR.

Hi Sophie,

Great news!

So BoD has resolved to proceed and add this ACR maintenance to governance? Or are we just dipping our toes… :wink:

You might also have a look at the ACRs that Microsoft puts up. They do multiples, e.g. Word and Excel each get an ACR. They also publish for Europe, for US and a generic–but don’t think that we’d have to do the same. Either one for full suite, or at most one per module.

A lot of the evaluation is made against WCAG A, AA, AAA level from the template(s). Assessment is that the functional capability is Supported, Partially Supported, or Not Supported, or given a Not Applicable assessment. And each gets as much of a remark or comment as seems warranted to clarify how the capability is handled.

Point is, the functional level assessments and writeups can be accomplished fairly quickly against the template(s). While any glaring deficiencies could be routed to BZ and prioritized for dev effort or even tendering. Nothing that would hold up publishing the ACRs, which with BoD sponsorship makes the ACR(s) acceptable for adopters of LibreOffice that require the documentation.

I’m happy to help with testing, writeups and proof reading. Maybe you and Jonathan C. can get some TDF NextCloud resource defined to host the effort. Allow staff and trustees to look it over as it progresses, before it moves over to Wiki or a public URI.

Stuart

Of course rather than Jonathan, TDF staffer would be Michael W. – sorry.

Hi Stuart,
No problem and thanks a lot for your offer to help, we will really need it!
I’ll open a NextCloud directory on our team area and will share the resource with you and Marc. I’ll upload all the material you recommended there.
I’m currently reading the documents (there’s quite a bit to read :slight_smile: I think we should also associate Olivier to the group for the accessibility of the Help files.
And be sure it’s not for dipping our toes, but to go to the end and get this CRA in place.

Thanks a lot @sophi for driving this forward!

1 Like

@sophi, expect we’d be targeting a finished publication of the ACRs as finished PDF with TDF “copyright” and ownership we really ought to “eat our own dogfood” and so first thing we should convert what ever VPAT template we are going to use into ODF!

NextCloud’s call to Collabora Desktop doesn’t even open the docx that I just checked.

Going to be a lot smoother for us if we convert templates from OOXML once at the start, work in LO, and publish to PDF when ready.

I fully agree. And also ask for having those documents available in ODF :slight_smile:

The link to the IT Industries VPAT templates are here:
VPAT templates from the Information Technology Industry (ITI) Council

Unfortunately they only offer OOXML flavors–so which ever we agree to work with, we will need to covert it ourselves to post to the Nextcloud share. Should not cause trouble if we agree we will only publish to PDF.