WCAG 2.2 compliance checklist for government suppliers
What you need to evidence to meet WCAG 2.2 AA for Australian government procurement, what evaluation teams actually look for, and how to prove conformance credibly.
Overview
What does a government supplier need for WCAG 2.2 compliance?
Suppliers need to evidence that their product meets WCAG 2.2 Level AA and that accessibility is built into their delivery process, not just claimed. The strongest evidence is an independent VPAT or Accessibility Conformance Report against WCAG 2.2, supported by an audit with severity-ranked findings, a remediation plan for known issues, and a public accessibility statement. Procurement teams increasingly verify these claims rather than accepting a self-assessment tick-box.
The supplier readiness checklist
Work through these before you respond to an accessibility-conditioned tender. Each item is something a government evaluation team can reasonably ask you to produce.
- Independent WCAG 2.2 AA audit of the product you are supplying, with findings ranked by severity and mapped to specific success criteria.
- VPAT or Accessibility Conformance Report against WCAG 2.2, reporting conformance criterion by criterion for procurement.
- Remediation plan for any non-conformances, with dated commitments and a defined owner, rather than a claim of perfect conformance.
- Public accessibility statement aligned to WCAG 2.2 AA, stating known issues honestly and the path to resolving them.
- Document accessibility for any PDFs, forms or templates you supply, typically to WCAG 2.2 AA and PDF/UA.
- Assistive-technology evidence: confirmation the product has been tested with real assistive technology (screen readers, keyboard, voice), not only automated tools.
- Process evidence: how accessibility is built into your design and development workflow, so conformance is sustained across releases.
- Named accountable person for accessibility on your side of the engagement.
What evaluation teams actually look for
A credible, honest position scores better than an implausible one. The common failure is a supplier claiming full conformance that an evaluator can disprove in five minutes with a screen reader. What earns trust:
- Independence of the evidence. A conformance report produced or validated by a party with no commercial interest in passing carries far more weight than a self-assessment.
- Honesty about known issues. Stated non-conformances with dated remediation plans read as competence, not weakness.
- Coverage of the real product. Evidence for the specific build being supplied, not a generic marketing claim about the platform.
- Process, not just snapshot. Evidence that accessibility survives the next release, because procurement is buying an ongoing relationship.
Automated tools are not enough
Automated scanners catch only a fraction of WCAG criteria, typically around 30 to 40 per cent, and cannot reliably judge meaningful alt text, keyboard operation, focus order or complex components. A checklist that relies on a single automated pass will not stand up to a government evaluation. See why in manual versus automated accessibility testing.
If you need to get ready quickly, the fastest credible path is an independent WCAG 2.2 AA audit, remediation of high-severity findings, and a VPAT or ACR as the evidence artefact. For the agency-side requirements this maps to, see preparing for 2026 government accessibility requirements and accessibility requirements for NSW Government procurement.
Common questions about WCAG 2.2 for government suppliers
Plain answers to the questions suppliers ask before responding to a tender.
Is a self-assessment enough for government procurement?
Usually not for higher-value or higher-risk engagements. A self-assessment can be a starting point, but agencies increasingly require independent evidence: a VPAT or Accessibility Conformance Report produced or validated by a party with no commercial interest in passing. Independent conformance evidence carries far more weight in evaluation than a vendor's own claim.
What conformance level do government suppliers need?
WCAG 2.2 Level AA is the standard expectation for Australian government procurement. Level AA means meeting all Level A and Level AA success criteria. Level AAA is rarely required site-wide; some AAA criteria may apply selectively where the content type warrants it. See WCAG levels compared.
What is the difference between a VPAT and an audit?
An audit is the assessment activity: testing a product against WCAG 2.2 and recording findings. A VPAT (or Accessibility Conformance Report) is the standardised document that reports the result, criterion by criterion, for procurement. Suppliers typically commission an audit, remediate the findings, then produce a VPAT or ACR as the evidence artefact buyers ask for.
How can a supplier prepare quickly?
Commission an independent WCAG 2.2 AA audit of the product you are supplying, remediate the high-severity findings, document any remaining issues honestly with dated remediation plans, and produce a VPAT or ACR plus a public accessibility statement. Being able to show honest known-issues with a credible plan often scores better than an implausible claim of perfect conformance.
Need to evidence WCAG 2.2 AA for a tender?
We audit the product you are supplying, help you remediate, and produce the VPAT or Accessibility Conformance Report your buyer requires.
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