European Accessibility Act (EAA) Conformance Statement

Introduction

Aletheia by Lonia AI is committed to making its products usable by everyone, including people who rely on assistive technology. This statement sets out how Aletheia conforms with the European Accessibility Act (Directive 2019/882) and with WCAG 2.2 Level AA. Accessibility is the reason Aletheia exists, so the tool holds itself to the standard it helps people enforce on other content.

Scope

This statement covers the following, together referred to as Aletheia:

• The Aletheia web application, where users process and remediate web pages and documents.
• The Aletheia marketing website at this domain.
• The institutional administration dashboards used by Campus and Enterprise account administrators.

Conformance status

The formal conformance basis for this statement is WCAG 2.2 Level AA together with EN 301 549 V3.2.1, the harmonised European standard in force as of the publication date.

Aletheia targets full conformance with WCAG 2.2 Level AA. As of the review date, Aletheia is partially conformant. Partially conformant means that most requirements of the standard are met and that the known exceptions, where content does not yet fully conform, are listed in the section below. Self-evaluation. No third-party accessibility audit has been conducted, and no SOC 2 or comparable certification is claimed. A formal audit by an independent third party is planned and has not yet been carried out.

5 WCAG 2.2 success criteria are recorded as Partially Supports in the VPAT rather than Supports: 1.3.1 Info and Relationships (Level A), 1.3.2 Meaningful Sequence (Level A), 2.4.1 Bypass Blocks (Level A), 1.4.10 Reflow (Level AA), 2.4.11 Focus Not Obscured (Minimum) (Level AA). Each is listed with its reason in the section below.

Technical mapping

For a clause-by-clause view of how Aletheia maps against EN 301 549, including the applicable chapters and each WCAG 2.2 Level AA success criterion, read the EN 301 549 Conformance Mapping. It also records preparation for EN 301 549 V4.1.1, expected to be referenced in the Official Journal in October 2026.

For EU public sector procurement, Aletheia also publishes an EU Accessibility Statement in the mandated template of Commission Implementing Decision (EU) 2018/1523. That statement follows the Web Accessibility Directive template order; this conformance statement addresses the European Accessibility Act (Directive 2019/882). Both documents co-exist.

Known non-conformances

The following limitations are known and are being worked on. They are listed so that users and buyers can make an informed decision.

• Screen reader compatibility of exported tagged PDF files is still under testing. Formal test evidence with NVDA and JAWS against exported PDF output is pending.
• Exported tagged PDF files carry proper structure tags, alternative text, and outlines for Latin-script content. Non-Latin scripts may show fallback characters in the current build. Plain text export preserves all Unicode content without loss and can be used where non-Latin scripts must be retained exactly.
• 3.3.7 Redundant Entry is met in the marketing flows; a full review of every multi-step flow in the web application and administration dashboards is still pending.
• Product documentation is expanding, and older articles may not yet follow the same heading discipline as newer ones.
• No prerecorded or live synchronised media is present on any surface. Any future media will ship with captions and audio description alongside the media itself.

Aletheia publishes a Voluntary Product Accessibility Template (VPAT) in the ITI VPAT 2.5 format, mapping conformance against every WCAG 2.2 Level A and Level AA success criterion and the Revised Section 508 standards. Read the VPAT accessibility report, or download the tagged PDF.

Compatibility

Aletheia is built to work with current versions of major standards-compliant browsers on desktop and on mobile, and to function at a viewport width of 320 pixels and above. It is designed to be operated with a keyboard alone, and it respects the operating system setting for reduced motion.

Testing to date has been carried out on Chrome on Windows 11 with the NVDA screen reader and on Chrome on Android with the TalkBack screen reader. JAWS is a target of support and has not yet been exercised in a testing session. The platforms listed under "Platforms not tested" below have not been tested at all, and this statement makes no compatibility claim about them.

Testing methodology

This statement is based on the following evaluation methods. Two separate automated evidence records exist, one per surface, and each is named with the artifact that backs it so neither is mistaken for the other.

• Aletheia marketing website (this site): axe-core 4.12.1, October 16, 2026, covering all 31 public routes of the site revision named beside it. Zero violations at every severity across the full WCAG 2.0, 2.1, and 2.2 Level A and AA rule sets plus axe best-practice rules. The results axe records as incomplete rather than pass or fail are colour-contrast checks that axe cannot compute against the site's background gradient; they are resolved separately by measuring the rendered pixels, and that resolution is committed alongside the sweep. Evidence: test-results/axe/m17-2026-10-16/ One JSON record per route plus _aggregate.json, committed to this repository. Each record carries the page title the origin served at scan time, so a reader can confirm the sweep ran against Aletheia and not against another site sharing the preview port. Site revision c2b6329aa097.
• Aletheia web application and admin dashboards: axe-core, September 20, 2026, covering 73 runs across desktop and mobile viewports, including the Settings route that carries the data-export control. Zero violations. Evidence: test-results/axe/a11-2026-09-20/ in the Aletheia application repository. Held in the application repository and not committed here, which is why it is named separately from the marketing-site record. The batches before it were a13-2026-09-20 and a12-2026-09-19; five tracked batches exist since the July 14, 2026 sweep, and this record cites the latest.
• Manual testing: Manual testing is carried out by the Lonia AI product team on Windows 11 with NVDA and on Android with TalkBack, iteratively during development rather than as a single scheduled audit, continuously since May 2026. It covers targeted keyboard navigation, WCAG 2.2 Level AA colour contrast, responsive layout, high-contrast mode, and confirming that each accessibility setting changes real behaviour. The fix commits in the Aletheia application repository are the audit trail; there is no separate manual-testing report and none is claimed.
• Manual checks of semantic structure, focus order, contrast, and form labeling, on the platforms named above and no others.

A formal audit by an independent third party is planned and has not yet been completed. This statement will be updated when that audit is available.

Feedback and contact

If you find an accessibility barrier in Aletheia, or need information from Aletheia in an accessible format that is not currently provided, please tell us. Aletheia treats accessibility issues as defects, not feature requests.

Please include the page or feature where the issue occurred, the assistive technology you were using, and what you expected to happen. We aim to respond to accessibility feedback within five business days.

Enforcement procedure

The European Accessibility Act is enforced by national authorities in each European Union Member State. If you contact us about an accessibility barrier and you are not satisfied with our response, you can contact the accessibility enforcement or market surveillance authority designated in your Member State. Examples include:

• France: the Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF).
• Germany: the market surveillance authority designated under the Barrierefreiheitsstärkungsgesetz (BFSG).
• Sweden: the Swedish Post and Telecom Authority (Post- och telestyrelsen, PTS).
• Netherlands: the Netherlands Authority for Consumers and Markets (Autoriteit Consument en Markt, ACM).

The European Commission publishes information on the European Accessibility Act and the authorities responsible for enforcing it in each Member State.

Preparation of this statement

This statement was prepared by Lonia AI on the basis of a self-evaluation of Aletheia against WCAG 2.2 Level AA and EN 301 549 V3.2.1, using automated testing with axe-core and manual testing as described above. A third-party audit is planned. The statement is written so that it can be amended when EN 301 549 V4.1.1, which references WCAG 2.2 AA, is cited in the Official Journal of the European Union.

Review

This statement was last reviewed on October 4, 2026. It is reviewed at least once a year and on every major product release.

Change history