A resource for ADA-defense counsel

The accessibility documentation your client can hand to counsel.

When a Shopify merchant receives an ADA Title III website-accessibility demand letter or complaint, one of the first questions is practical: what has the store actually done about accessibility, and is any of it written down and dated? This page explains, plainly, the documentation a merchant can assemble and share with their own attorney. It is written so you can forward it to a client.

What this is, and is not. Paperfort produces accessibility documentation — a timestamped automated WCAG 2.2 AA audit report, a VPAT 2.5 (ACR), and a hosted accessibility statement. Paperfort is not a law firm, does not provide legal advice, and makes no claim about case outcomes, “ADA compliance,” or lawsuit prevention. Whether and how any document is useful in a matter is a decision for the merchant and their counsel.

Three documents a merchant can put in a defense file.

Each is documentation the merchant owns and can forward to you. None of them is a legal conclusion, and none of them is offered by Paperfort as one.

1. A timestamped automated WCAG 2.2 AA audit report (PDF)
A dated, paginated report of an automated axe-core scan of the storefront against WCAG 2.2 Level AA. It lists findings, severities, and the pages tested, with the scan date on every page. It records what an automated scan found on a specific date — not a certification of full conformance.
2. A completed VPAT 2.5 (Accessibility Conformance Report)
A VPAT 2.5 (published by ITI), completed with the scan results, describing how the storefront measures against WCAG 2.2, Section 508, and EN 301 549. Once filled in, a VPAT is called an Accessibility Conformance Report (ACR). It is the standardized format procurement and enterprise buyers request.
3. A hosted accessibility statement on the merchant’s own domain
A public, plain-language page on the store’s own domain describing its accessibility commitment, the standard it is working toward (WCAG 2.2 AA), and a real feedback channel a user can contact. It is dated and updated when the store re-scans.

Why merchants assemble this documentation.

In our experience talking to sued merchants, the recurring problem is not that the store ignored accessibility — it is that nothing was written down. The documentation gives a client three concrete things to show their attorney.

  • A dated record of testing. The audit report shows the storefront was scanned against WCAG 2.2 AA on a specific date, with the findings listed.
  • A prioritized remediation plan. Findings are ordered by severity, so the merchant and their developer have a documented sequence of work — and a record of what has been fixed since.
  • A standardized conformance format. The VPAT 2.5 (ACR) is the format enterprise, procurement, and government buyers recognize, independent of any single matter.
  • A public statement with a feedback channel. The hosted accessibility statement gives users a documented way to report barriers directly to the store.

Whether any of this is relevant, sufficient, or advisable in a given matter is a question for the merchant’s counsel. Paperfort does not offer that judgment and does not claim the documentation changes legal exposure.

What the documentation does not do.

We state the limits plainly so neither you nor your client over-reads the artifacts.

It is not a compliance certificate.
A VPAT and an audit report are conformance documentation. They describe how a storefront measures against a standard on a date; they do not certify ADA compliance and Paperfort issues no such certification.
It is not a guarantee against litigation or enforcement.
Paperfort makes no claim that documentation prevents lawsuits, demand letters, or regulatory action. We do not market the documents as protection.
It is automated-only.
Automated scans detect roughly 30–50% of WCAG issues (an industry baseline reported by tooling vendors such as Deque). The report documents what the automated axe-core scan finds and flags where a qualified professional should review further. It is not a manual expert audit.
It is not legal advice.
Paperfort is not a law firm. Nothing on this page or in the documentation is legal advice, and using it does not create an attorney-client or any advisory relationship with Paperfort.

A short note you can forward to a sued merchant.

If your client runs a Shopify store and has no accessibility documentation on file, you are welcome to copy the note below into an email. It is plain-language and makes no promises.

If you have not had your storefront tested for accessibility, it is worth getting documentation in order: a dated WCAG 2.2 AA audit report, a VPAT 2.5 conformance report, and a published accessibility statement on your domain. Paperfort generates those three documents from an automated scan in about a week. It is documentation, not legal advice, and it does not by itself resolve any claim — but it gives us a written, dated record of where the store stands and a prioritized plan for fixes. Send me whatever you receive so we can decide how it fits the matter.

Suggested note from counsel to client — adapt freely

The merchant can start with the $249 one-time audit bundle (about a seven-day turnaround) or a monthly plan that re-scans and keeps the statement page current. There is no Paperfort account required for you, and nothing to install on your end.

The litigation backdrop, in sourced figures.

For the full sourced reference, see our 2025 ADA website-accessibility litigation data page. A few figures for orientation:

  • 3,117 federal ADA Title III website-accessibility lawsuits filed in 2025, up about 27% year over year (Seyfarth Shaw).
  • ≈70% of accessibility-lawsuit targets are e-commerce businesses (UsableNet).
  • $1,000,000 — the consumer-redress order the FTC required overlay vendor accessiBe to pay over deceptive “ADA compliant” claims (FTC File No. 222-3156), a reminder that “compliance” marketing is itself scrutinized.
  • 30–50% of WCAG issues are detectable by automated scans — the honest limit of any automated tool, including Paperfort.

Answers

For counsel: common questions.

Last reviewed June 2026. Paperfort produces accessibility documentation — not legal advice, and not a promise of any outcome.

Is Paperfort a law firm or does it provide legal advice?
No. Paperfort is not a law firm and does not provide legal advice or representation. It produces accessibility documentation — a timestamped automated WCAG 2.2 AA audit report, a VPAT 2.5 conformance report, and a hosted accessibility statement — that a merchant can share with their own counsel. How that documentation is used in any matter is a decision for the merchant and their attorney.
What documentation can a sued Shopify merchant give to their attorney?
Three artifacts that show the merchant has tested and is acting on accessibility: a timestamped, paginated automated WCAG 2.2 AA audit report listing findings and severities; a completed VPAT 2.5 (Accessibility Conformance Report) describing how the storefront measures against WCAG 2.2, Section 508, and EN 301 549; and a hosted accessibility statement page on the merchant’s own domain with a feedback channel. Counsel decides relevance and use.
Does this documentation prove ADA compliance or prevent a lawsuit?
No. The audit and VPAT are conformance documentation, not a compliance certificate and not a guarantee against litigation or regulatory action. Automated scans detect roughly 30 to 50 percent of WCAG issues, so the report documents what an automated axe-core scan finds and flags where a qualified professional should review further. Paperfort makes no claim that documentation prevents lawsuits or establishes legal compliance.
How quickly can a merchant get the documentation?
The $249 audit bundle is delivered in about seven days and includes all three documents plus a prioritized remediation plan. Subscription plans ($29 to $149 per month) add monthly re-scans and an auto-updated statement page so the documentation stays current and dated.
Why does a timestamp on the audit matter?
Each Paperfort audit report and VPAT is dated, so the merchant has a record of when the storefront was scanned and what was found on that date, along with a record of remediation work that followed. Whether and how a dated record is useful in a given matter is a question for the merchant’s attorney; Paperfort does not offer that judgment.

Paperfort produces defensible documentation and a prioritized remediation plan. It is not a law firm and does not provide legal advice; it does not guarantee lawsuit prevention or automatic ADA/WCAG compliance. Automated scans detect roughly 30–50% of WCAG issues; Paperfort documents what an automated axe-core scan finds and flags where a qualified professional should review further. This page is a resource for attorneys and merchants; it is not legal advice and does not create an attorney-client relationship with Paperfort.