Brousseau AI Compliance & Consulting (BAIC&C)

WCAG 2.2 Guidelines (VPAT® Version 2.5Rev)

This report applies to the document remediation output we provide to our clients.

WCAG Edition (Based on VPAT® Version 2.5Rev)

"Air-Gapped" Security Note

Our document remediation service is executed within a strictly air-gapped engineering environment. This ensures that any sensitive document, i.e. public health data and/or municipal records, are securely processed with zero external network exposure, meeting the highest data privacy and security standards for public or private record-keeping.

Continuous Compliance Note

BAIC&C monitors updates to WCAG, Section 508, and HHS mandates quarterly. This VPAT reflects the most current requirements as of May 2026, including full integration of the recently adopted WCAG 2.2 success criteria.

Evaluation Methods Used

Remediation and compliance testing are executed using an air-gapped forensic engineering workflow. Structural verification involves intensive manual inspection of the PDF tag tree, content nesting layers, and logical reading order within a secure environment. Final validation is programmatically verified via PAC 2026 for absolute ISO 14289-1 (PDF/UA-1) machine-conformance, alongside veraPDF for archival integrity verification (PDF/A-2B) matching the current US Government Standards. Functional assistive technology testing is thoroughly conducted using NVDA and/or JAWS screen readers to ensure absolute semantic clarity, native reading flow, and keyboard navigation efficiency.

Applicable Standards/Guidelines

This report covers the degree of conformance for the following accessibility standards/guidelines:

Standard/Guideline

Included In Report

Web Content Accessibility Guidelines 2.0

Level A (Yes)

Level AA (Yes)

Level AAA (No)

Web Content Accessibility Guidelines 2.1

Level A (Yes)

Level AA (Yes)

Level AAA (No)

Web Content Accessibility Guidelines 2.2

Level A (Yes)

Level AA (Yes)

Level AAA (No)

Terms

The terms used in the Conformance Level information are defined as follows:

WCAG 2.x Report

Note: When reporting on conformance with the WCAG 2.x Success Criteria, they are scoped for full pages, complete processes, and accessibility-supported ways of using technology as documented in the WCAG 2.0 Conformance Requirements.



Table 1: Success Criteria, Level A

Notes:

Criteria

Conformance Level

Remarks and Explanations

1.1.1 Non-text Content (Level A)

Supports

All non-text content in the evaluated PDF documents (including images, charts, and logos) has been provided with descriptive text alternatives. Structural validation via PAC 2026 confirms that all Figure tags contain the required Alt-text attributes, ensuring accessibility for screen reader users.

1.2.1 Audio-only and Video-only (Prerecorded) (Level A)

Not Applicable

The evaluated PDF documents consist of static text and images. There is no embedded audio-only or video-only multimedia content within the files.

1.2.2 Captions (Prerecorded) (Level A)

Not Applicable

The evaluated PDF documents are static text-based records and do not contain embedded video or synchronized media content.

1.2.3 Audio Description or Media Alternative (Prerecorded) (Level A)

Not Applicable

The evaluated PDF documents are static archival records and do not contain embedded video or synchronized media that would require audio descriptions or media alternatives.

1.3.1 Info and Relationships (Level A)

Supports

The evaluated PDF documents utilize a comprehensive tag tree structure to define logical relationships. Headings, lists, and data tables are correctly tagged to ensure that structural information is preserved and communicated to assistive technologies. PAC 2026 and veraPDF validation confirm that the visual structure matches the programmatic tag structure.

1.3.2 Meaningful Sequence (Level A)

Supports

The reading order within the PDF tag tree is manually verified and programmatically validated to ensure it follows the logical flow of the document. Multi-column layouts, sidebars, and call-out boxes are sequenced correctly to maintain meaning when accessed by assistive technology.

1.3.3 Sensory Characteristics (Level A)

Supports

Content and instructions within the PDF documents do not rely exclusively on sensory characteristics such as shape, size, color, or relative position. All information is provided in a text-based format that is accessible to assistive technology regardless of the user's sensory abilities.

1.4.1 Use of Color (Level A)

Supports

In the evaluated PDF documents, information conveyed by color is also available in text or through structural highlights. Charts, graphs, and maps utilize redundant coding—such as data labels, varying line styles, or patterns—to ensure content is understandable without the perception of color.

1.4.2 Audio Control (Level A)

Not Applicable

The evaluated PDF documents are static archival records and do not contain any embedded audio content that plays automatically.

2.1.1 Keyboard (Level A)

Supports

The PDF documents are structured to allow full navigation and interaction via keyboard. All interactive elements, such as bookmarks, hyperlinks, and form fields (where applicable), are accessible and operable using standard keyboard commands (e.g., Tab, Enter, Space).

2.1.2 No Keyboard Trap (Level A)

Supports

The remediated PDF documents do not contain any interactive elements that trap keyboard focus. Testing confirms that users can navigate through all links, form fields, and bookmarks, and move past them to the rest of the document content using standard keyboard commands.

2.1.4 Character Key Shortcuts (Level A 2.1 and 2.2)

Not Applicable

The PDF documents do not contain any custom character-key shortcuts. Navigation and interaction within the documents rely on standard assistive technology and PDF viewer commands, which are not restricted or overridden by the document content.

2.2.1 Timing Adjustable (Level A)

Not Applicable

The evaluated PDF documents are static archival records and do not contain any time-dependent interactions, automatic refreshing, or content that expires. Users can read and interact with the documents at their own pace.

2.2.2 Pause, Stop, Hide (Level A)

Not Applicable

The evaluated PDF documents are static archival records. They do not contain any moving, blinking, scrolling, or auto-updating information.

2.3.1 Three Flashes or Below Threshold (Level A)

Not Applicable

The evaluated PDF documents are static archival records and do not contain any flashing or strobing animations.

2.4.1 Bypass Blocks (Level A)

Supports

This criterion applies to web navigation blocks. PDF structure relies on Headings and Bookmarks for navigation, which are handled in 1.3.1.The PDF documents utilize a hierarchical heading structure (H1-H6) and PDF Bookmarks. These allow users of assistive technology to bypass repetitive headers or introductory sections and navigate directly to specific chapters or sections of the document.

2.4.2 Page Titled (Level A)

Supports

Every remediated PDF document has a descriptive title set within the document metadata. The PDF "Initial View" settings are configured to display the Document Title rather than the file name in the window title bar, as validated by PAC 2026 and veraPDF.

2.4.3 Focus Order (Level A)

Supports

The focus order within the PDF documents is synchronized with the tag tree and the logical reading order. For documents with interactive elements like links or form fields, the Tab order is explicitly set to follow the logical flow of the content, ensuring a consistent experience for keyboard and screen reader users.

2.4.4 Link Purpose (In Context) (Level A)

Supports

Links within the PDF documents are provided with descriptive display text. In instances where short link text is used (e.g., "Read more"), the surrounding sentence or paragraph context provides the necessary information to determine the link's destination or purpose.

2.5.1 Pointer Gestures (Level A 2.1 and 2.2)

Not Applicable

The remediated PDF documents do not contain interactive elements that require complex gestures. Navigation through pages, links, and bookmarks is achievable through single-point interactions or standard keyboard commands.

2.5.2 Pointer Cancellation (Level A 2.1 and 2.2)

Not Applicable

Interactive elements within the PDF documents, such as hyperlinks and bookmarks, follow standard PDF viewer protocols where the action is executed upon completion of the click or tap. This provides users the ability to abort an action by moving the pointer off the element before release.

2.5.3 Label in Name (Level A 2.1 and 2.2)

Supports

In the evaluated PDF documents, all interactive elements such as hyperlinks and form fields have accessible names that match or include the visible text label. This ensures that users of voice-recognition software can interact with the document elements by speaking the visible label text.

2.5.4 Motion Actuation (Level A 2.1 and 2.2)

Not Applicable

The evaluated PDF documents are static archival records and do not contain any features or functions that are triggered by device or user motion.

3.1.1 Language of Page (Level A)

Supports

The primary natural language of each remediated PDF document is explicitly defined in the document properties/metadata. This setting ensures that screen readers automatically load the correct language profile for speech synthesis, as validated by PAC 2026.

3.2.1 On Focus (Level A)

Supports

In the evaluated PDF documents, interactive elements such as hyperlinks, bookmarks, and form fields do not trigger a change of context when they receive focus. Users can navigate through all elements without unexpected redirects or window launches occurring until an element is intentionally activated.

3.2.2 On Input (Level A)

Supports

Within the evaluated PDF documents, interactive elements such as form fields or dropdowns do not trigger an automatic change of context upon data entry or selection. Users must perform a deliberate action to initiate a change, such as activating a link or button.

3.2.6 Consistent Help (Level A 2.2 only)

Not Applicable

For document sets or complex multi-page forms, help information (such as contact details or self-help instructions) is provided in a consistent relative order to ensure predictability for the user. This criterion is not applicable to the delivered static document formats as they do not contain dynamic user-interface help features.

3.3.1 Error Identification (Level A)

Supports

For PDF documents containing interactive form fields, field validation is used to identify errors. When a user provides invalid input, the document provides text-based feedback identifying the specific field and the nature of the error, allowing the user to correct it.

3.3.2 Labels or Instructions (Level A)

Supports

In the evaluated PDF documents, all interactive form fields include descriptive tooltips and visible labels. These labels are programmatically associated with the form controls in the tag tree, ensuring that assistive technology announces the purpose of the field when it receives focus.

3.3.7 Redundant Entry (Level A 2.2 only)

Not Applicable

This asset consists of static electronic documentation containing no interactive multi-step data entry forms or transactional input workflows; therefore, this criterion is not applicable to the delivered document format.

4.1.1 Parsing (Level A)

Supports

The remediated PDF documents have been validated for structural integrity. The internal syntax and container structure are free of parsing errors, and all tags are properly nested and closed. Compliance has been verified through PAC 2026 and veraPDF to ensure the file can be reliably interpreted by screen readers and other assistive tools.

4.1.2 Name, Role, Value (Level A)

Supports

Within the PDF documents, all interactive elements (such as hyperlinks, bookmarks, and form fields) are correctly tagged in the structure tree. Each element is assigned a proper Role (e.g., Link, Btn), an Accessible Name (via Alt text or Tooltips), and its current Value or state is programmatically exposed. This ensures full compatibility with screen readers, as validated by PAC 2026.




Table 2: Success Criteria, Level AA

Notes:

Criteria

Conformance Level

Remarks and Explanations

1.2.4 Captions (Live) (Level AA)

Not Applicable

The evaluated PDF documents are static archival records and do not contain live synchronized media.

1.2.5 Audio Description (Prerecorded) (Level AA)

Not Applicable

The evaluated PDF documents are static archival records and do not contain embedded video or synchronized media content requiring audio description.

1.3.4 Orientation (Level AA 2.1 and 2.2)

Supports

The PDF documents do not restrict the orientation in which they can be viewed. PDF viewing software handles the rotation and display, and the document structure remains intact regardless of the screen's orientation.

1.3.5 Identify Input Purpose (Level AA 2.1 and 2.2)

Supports

For PDF documents containing interactive forms, fields are assigned standard names and tooltips that clearly identify their purpose. While the PDF specification handles autofill differently than HTML, the fields are programmatically identified to ensure compatibility with form-filling assistants.

1.4.3 Contrast (Minimum) (Level AA)

Supports

All text and meaningful graphics within the remediated PDF documents meet the required contrast thresholds. During the remediation process, color checks were performed on all headings, body text, and charts to ensure readability against the document background, as validated by accessibility checking tools.

1.4.4 Resize text (Level AA)

Supports

The remediated PDF documents are compatible with the "Reflow" feature in Adobe Acrobat and other PDF viewers. This allows the text to be resized and re-wrapped within the window boundaries, ensuring it remains readable and accessible at high zoom levels without requiring horizontal scrolling for each line.

1.4.5 Images of Text (Level AA)

Supports

The remediated PDF documents contain "searchable" text rather than flat images of scanned pages. Where text appears within an image (such as in an infographic or organizational chart), that text is also provided as alternative text or explained in the surrounding document content to ensure it is accessible to screen readers.

1.4.10 Reflow (Level AA 2.1 and 2.2)

Supports

The PDF documents are tagged to support the "Reflow" view in compatible readers. This allows the document content to wrap and fit within the width of the window as the zoom level increases, preventing the need for two-dimensional scrolling while maintaining the logical reading order.

1.4.11 Non-text Contrast (Level AA 2.1 and 2.2)

Supports

In the remediated PDF documents, all meaningful non-text elements—including icons, charts, and infographics—have been designed or adjusted to ensure a minimum 3:1 contrast ratio. This ensures that visual information is perceivable by users with low vision or color blindness.

1.4.12 Text Spacing (Level AA 2.1 and 2.2)

Supports

The remediated PDF documents utilize a structural tag tree that supports content reflow. When viewed in readers that allow for personalized display settings or reflow modes, the text adjusts to accommodate spacing changes while maintaining its logical reading order and integrity.

1.4.13 Content on Hover or Focus (Level AA 2.1 and 2.2)

Not Applicable

The evaluated PDF documents are static archival records and do not contain any interactive hover-triggered content layers, pop-up tooltips, or dynamic user-interface overlays.

2.4.5 Multiple Ways (Level AA)

Supports

For multi-page PDF documents, multiple navigation methods are provided, including a clickable Table of Contents and a complete nested Bookmark tree. These features allow users to browse and jump to specific sections of the document efficiently.

2.4.6 Headings and Labels (Level AA)

Supports

Within the PDF documents, headings are used to provide a logical outline of the content, and labels are used to identify form fields and other interactive elements. Each heading and label is descriptive, ensuring that users can easily find information and understand how to interact with the document.

2.4.7 Focus Visible (Level AA)

Supports

In the evaluated PDF documents, interactive elements like hyperlinks, form fields, and bookmarks show a clear visual focus indicator when navigated via the keyboard in standard PDF viewers. This allows users to identify their current location within the document's interactive structure.

2.4.11 Focus Not Obscured (Minimum) (Level AA 2.2 only)

Not Applicable

This asset consists of static electronic documentation containing no interactive user-interface components, sticky banners, or fixed overlapping layout structures that manage keyboard focus tracking; therefore, this criterion is not applicable to the delivered document format.

2.5.7 Dragging Movements (Level AA 2.2 only)

Not Applicable

This asset consists of static electronic documentation containing no dynamic functionality or interface components requiring path-based or multi-point dragging gestures; therefore, this criterion is not applicable to the delivered document format.

2.5.8 Target Size (Minimum) (Level AA 2.2 only)

Not Applicable

This asset consists of static electronic documentation containing no interactive pointer targets, buttons, or clickable user-interface elements requiring specific physical sizing spacing dimensions; therefore, this criterion is not applicable to the delivered document format.

3.1.2 Language of Parts (Level AA)

Supports

In the remediated PDF documents, any text segments that differ from the document's primary language are tagged with the appropriate language attribute in the tag tree. This allows screen readers to adjust their speech synthesis to the correct language for those specific sections, as confirmed by PAC 2026 validation.

3.2.3 Consistent Navigation (Level AA)

Supports

In multi-page PDF documents or sets of related documents, navigational aids such as the Table of Contents, headers, and page numbering are applied consistently. This uniformity allows users to reliably locate navigation elements regardless of which section they are viewing.

3.2.4 Consistent Identification (Level AA)

Supports

Within the evaluated PDF documents, recurring functional elements, such as "Next Page" buttons, "Home" links, or "Print" icons, are identified using consistent labels and alternative text. This uniformity ensures that users of assistive technology can reliably identify these features throughout the document or document set.

3.3.3 Error Suggestion (Level AA)

Supports

Within interactive PDF forms, field validation scripts and tooltips are used to provide immediate feedback. If a user enters data that does not match the required format (such as a phone number or email address), the document displays a message suggesting the correct format to ensure successful data entry.

3.3.4 Error Prevention (Legal, Financial, Data) (Level AA)

Supports

In the evaluated interactive PDF documents, forms that involve legal or financial data include validation checks and clear instructions for review. Users are prompted to confirm their entries or are provided with a mechanism to review their data in a summary format before the document is finalized or submitted, preventing accidental data loss or incorrect commitments.

3.3.8 Accessible Authentication (Minimum) (Level AA 2.2 only)

Not Applicable

This asset consists of static electronic documentation containing no interactive form elements, authentication gateways, login portals, or dynamic user-interface identity verification processes; therefore, this criterion is not applicable to the delivered document format.

4.1.3 Status Messages (Level AA 2.1 and 2.2)

Not Applicable

This success criterion is specifically focused on dynamic status updates within web and software interfaces. The evaluated PDF documents are static in nature; they do not generate dynamic background status messages or live updates that would require programmatic announcement via live regions.




Table 3: Success Criteria, Level AAA

Notes:

Criteria

Conformance Level

Remarks and Explanations

1.2.6 Sign Language (Prerecorded) (Level AAA)

Not Applicable

Remediated municipal records consist of static documents and do not contain prerecorded video content.

1.2.7 Extended Audio Description (Prerecorded) (Level AAA)

Not Applicable

Remediated records are static documents and do not contain video content requiring audio description.

1.2.8 Media Alternative (Prerecorded) (Level AAA)

Not Applicable

Services are limited to document remediation; no prerecorded time-based media is present in the deliverables.

1.2.9 Audio-only (Live) (Level AAA)

Not Applicable

Services are limited to document remediation and do not include live audio or video streams.

1.3.6 Identify Purpose (Level AAA 2.1 and 2.2)

Supports

The remediation process utilizes standard PDF tags and attributes to ensure that the purpose of icons, regions, and UI components can be programmatically determined.

1.4.6 Contrast (Enhanced) (Level AAA)

Supports

Document remediation ensures an enhanced contrast ratio of at least 7:1 for text and images of text, exceeding the standard Level AA requirement.

1.4.7 Low or No Background Audio (Level AAA)

Not Applicable

Deliverables are strictly digital text-based records and do not contain background audio or speech-based media.

1.4.8 Visual Presentation (Level AAA)

Supports

Remediated document structure allows users to select foreground and background colors and adjust line/paragraph spacing without loss of content.

1.4.9 Images of Text (No Exception) (Level AAA)

Supports

The Sovereign Protocol utilizes OCR and manual tagging to ensure that images of text are replaced with actual text, allowing for user customization.

2.1.3 Keyboard (No Exception) (Level AAA)

Supports

All functions and navigational elements within the remediated documents are fully operable through a keyboard interface without exception.

2.2.3 No Timing (Level AAA)

Supports

Remediated municipal records are static and do not contain time-limited interactions. Users can consume content at their own pace without expiration.

2.2.4 Interruptions (Level AAA)

Supports

The document structure does not include "interrupting" content (like pop-up alerts or auto-updates) that would distract or displace the user's focus.

2.2.5 Re-authenticating (Level AAA)

Supports

For any authenticated session involving these records, user data and progress are preserved if a session expires, allowing for seamless re-authentication.

2.2.6 Timeouts (Level AAA 2.1 and 2.2)

Supports

Users are warned of any potential inactivity timeouts, and the underlying structure ensures that data is not lost if a timeout occurs during document interaction.

2.3.2 Three Flashes (Level AAA)

Supports

Document remediation guarantees that no content flashes more than three times in any one-second period, preventing seizure risks.

2.3.3 Animation from Interactions (Level AAA 2.1 and 2.2)

Supports

Remediated documents contain no non-essential animations or motion triggers that could cause discomfort for users with vestibular disorders.

2.4.8 Location (Level AAA)

Supports

For complex or multi-part documents, the structural remediation provides breadcrumbs or "Page X of Y" indicators to inform the user of their location within the set.

2.4.9 Link Purpose (Link Only) (Level AAA)

Supports

The purpose of every link within the remediated document can be determined from the link text alone (e.g., "Download 2025 Budget" instead of "Click Here").

2.4.10 Section Headings (Level AAA)

Supports

Manual remediation utilizes a strict hierarchical heading structure (H1 through H6) to organize all document content logically.

2.4.12 Focus Not Obscured (Enhanced) (Level AAA 2.2 only)

Supports

For interactive elements, the document structure ensures that the keyboard focus indicator is fully visible and never even partially obscured by other content.

2.4.13 Focus Appearance (Level AAA 2.2 only)

Supports

The focus indicator for all interactive components is designed with a high-contrast, double-border system that exceeds the minimum visibility requirements.

2.5.5 Target Size (Level AAA 2.1 and 2.2)

Supports

All interactive targets within the document (links, buttons, form fields) are remediated to a minimum size of 44x44 CSS pixels for ease of use.

2.5.6 Concurrent Input Mechanisms (Level AAA 2.1 and 2.2)

Supports

Remediated documents do not restrict the use of input modes; users can switch between keyboard, mouse, touch, and speech input seamlessly.

3.1.3 Unusual Words (Level AAA)

Supports

Where specialized municipal or legal jargon is used, the remediation process ensures the context provides a clear definition or is programmatically linked to a glossary.

3.1.4 Abbreviations (Level AAA)

Supports

All abbreviations used in city records (e.g., "C.O.D.," "R.O.W.") are expanded or identified upon their first occurrence within the document structure.

3.1.5 Reading Level (Level AAA)

Supports

While municipal ordinances contain complex legal language, the structural remediation is optimized to be as clear and accessible as the source text allows.

3.1.6 Pronunciation (Level AAA)

Supports

Where the meaning of a word in a municipal record depends on its pronunciation, the remediated structure provides the phonetic information programmatically.

3.2.5 Change on Request (Level AAA)

Supports

Any change of context (like opening a new window or submitting a form) is initiated only by user request and never occurs automatically.

3.3.5 Help (Level AAA)

Supports

Remediated forms provide context-sensitive help or instructions for every input field to ensure successful completion by all users.

3.3.6 Error Prevention (All) (Level AAA)

Supports

The remediation framework allows for a "review and confirm" step for any data submission, preventing errors across all document types, not just legal/financial.

3.3.9 Accessible Authentication (Enhanced) (Level AAA 2.2 only)

Supports

Authentication processes for accessing sensitive records do not require cognitive function tests, providing a fully accessible pathway for all users.


Legal Disclaimer (Brousseau AI Compliance & Consulting)

Disclaimer of Warranty and Limitation of Liability

The information contained in this Voluntary Product Accessibility Template (VPAT) is provided by Brousseau AI Compliance & Consulting (BAIC&C) as a good-faith representation of the accessibility features of our expert document remediation services at the time of publication.

  1. Technical Accuracy: This report is based on manual expert remediation and validation using industry-standard tools (including PAC 2026 and veraPDF). While BAIC&C utilizes the proprietary Sovereign Protocol to ensure the highest degree of document integrity and compliance with WCAG 2.2 and PDF/UA-1 standards, digital accessibility is a dynamic field.

  2. No Legal Advice: The contents of this document and the associated remediation services do not constitute legal advice or legal representation. Compliance with accessibility laws (such as the ADA or Section 508) involves legal interpretations that are the sole responsibility of the Client’s legal counsel.

  3. Third-Party Modifications: This VPAT and any associated Certificates of Conformance apply exclusively to the deliverables as provided by BAIC&C. Any subsequent modifications, edits, or extractions performed by the Client or third parties will void the stated conformance levels.

  4. Limitation of Liability: In no event shall BAIC&C or Dr. Roger D Brousseau be liable for any indirect, incidental, or consequential damages (including, but not limited to, statutory fines or litigation costs) arising out of the use of these remediated records. BAIC&C’s total liability is strictly limited to the fees paid for the specific service rendered.