Aletheiaby Lonia AI

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Aletheia in Germany

Germany transposed the European Accessibility Act as the Barrierefreiheitsstärkungsgesetz, enforced by designated market surveillance authorities, on top of the EU-wide duty to make reasonable accommodation for disabled employees.

Aletheia is a user-side accessibility tool. It rebuilds inaccessible web pages and documents on the reader's own device, so a disabled employee or student is not waiting on a publisher, a vendor, or a remediation programme to finish. That is what makes it useful to a German institution now, rather than at the end of a compliance schedule.

The regulatory landscape in Germany

Aletheia does not make a third-party site compliant and does not relieve an institution of its own obligations. This section is context for a buyer, not legal advice, and each instrument below is named with its source.

Accessibility instruments that apply in Germany, with the source for each.
Instrument What it requires Source
Barrierefreiheitsstärkungsgesetz (BFSG) The German transposition of the European Accessibility Act, in force since 28 June 2025. It applies accessibility requirements to covered products and services placed on the German market and designates the market surveillance authority that enforces them. Barrierefreiheitsstärkungsgesetz (BFSG), Federal Law Gazette I 2021, p. 2970
BFSG penalties The BFSG provides for administrative fines for non-compliance, to a maximum of EUR 100,000. Barrierefreiheitsstärkungsgesetz (BFSG), Federal Law Gazette I 2021, p. 2970
Reasonable accommodation duty Requires employers to take appropriate measures to enable a person with a disability to have access to, participate in, or advance in employment, unless that would impose a disproportionate burden. This duty runs continuously and is independent of the EAA compliance schedule. Council Directive 2000/78/EC establishing a general framework for equal treatment in employment and occupation, Article 5

What Aletheia offers a German institutional buyer

The accommodation duty applies to the disabled employee a German employer has today. Aletheia gives that person a tool that works on their own device now, regardless of where the employer's own remediation programme has reached.

The specific thing Aletheia is good at is the gap between when access is owed and when it is delivered. An institution running a multi-year remediation programme still has a disabled employee or student today, reading a scanned PDF that no one has tagged yet, or a form with no labels. Aletheia is an accommodation that can be given to that person immediately: it runs on their own device, it does not require the publisher to act, and it does not require the institution to have finished anything.

  • An accommodation you can grant today. A seat can be assigned to a specific person who needs it, without waiting on the remediation queue.
  • Nothing leaves the device by default. Documents are processed in the reader's browser and stored in a local library on their device. That keeps the data-protection footprint of an accommodation small, which matters when the person receiving it is identifiable as disabled.
  • Procurement-ready documentation. A VPAT, an EN 301 549 mapping, a pre-completed HECVAT response, a DPA template, a sub-processor list, a DPIA, scoped SCCs, and a Transfer Impact Assessment are all published rather than sent on request.
  • Honest conformance reporting. Aletheia is partially conformant with WCAG 2.2 Level AA and says so, with the criteria it has not finished proving named individually.

Pricing in Germany

Aletheia's published per-seat pricing is in United States dollars, and billing is in United States dollars. Aletheia does not currently publish a EUR price list or bill in EUR. For a quote in local currency, including any applicable tax treatment, contact sales.

The published USD baseline, for reference:

  • Campus (schools and higher education, volume pricing sized by enrollment): from $12.99 per seat per month at the first band, minimum 50 seats. See Campus for the full band table.
  • Enterprise (employers, healthcare, government, large nonprofits, graduated pricing sized by seat count): from $24.99 per seat per month at the first band, minimum 25 seats. See Enterprise for the full band table.

Accessibility of Aletheia itself, for German buyers

Aletheia exists to remove accessibility barriers from other people's content, so the tool has to meet the standard it helps people enforce. It is partially conformant with WCAG 2.2 Level AA. 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.

Aletheia's EAA Conformance Statement names the German market surveillance authority route in its enforcement section, and the EU Accessibility Statement follows the Commission Implementing Decision (EU) 2018/1523 template used in German public sector procurement.

The statements that apply here, in the form a reviewer in Germany is most likely to want:

If you find an accessibility barrier in Aletheia, tell us at support@lonia.ai. Accessibility reports are treated as defects, not feature requests, and we aim to respond within five business days.

Other wave-one markets

Procurement

Compliance documents

Everything a security and procurement review needs, in one place. Read each document in the browser, or download the tagged PDF where one is provided.

  • HECVAT 4.1.6 Response

    A pre-completed Higher Education Community Vendor Assessment Toolkit response: all 332 questions answered honestly across security, IT accessibility, AI governance, and privacy, scoped to the Campus and Enterprise institutional offering. Read online, or download the tagged PDF or the XLSX for a vendor-tracking system. Both downloads carry a fingerprint of the source revision they were generated from, and the site build fails if either falls behind that source.

    Download tagged PDF

  • Security Whitepaper

    Identity, encryption at rest and in transit, row-level security, WORM audit logging, retention, deletion, and sub-processors.

    Download tagged PDF

  • Data Processing Agreement (DPA) template

    The Controller and Processor terms for an institutional deployment, with annexes for processing details, measures, sub-processors, and transfers.

    Download tagged PDF

  • Institutional Terms of Service template

    The commercial terms for a Campus or Enterprise deployment: service level agreement, support terms, data ownership, renewal, ACH billing, termination, indemnification, and limitation of liability.

    Download tagged PDF

  • Sub-processor List

    The authoritative list of third-party services that process personal data on Lonia AI's behalf, with regions, data categories, and contract instruments, plus the update-on-change and notification policy.

  • Data Protection Impact Assessment (DPIA)

    The GDPR Article 35 assessment: description of processing, the on-device, Enhanced AI, and bring-your-own-key data flows, necessity and proportionality, risks to data subject rights and their mitigations, cross-border transfer analysis, and review cadence.

    Download tagged PDF

  • Scoped Standard Contractual Clauses (SCCs)

    The scoped adoption of the European Commission SCCs (Commission Implementing Decision (EU) 2021/914, Module 2) for the Lonia-mediated Enhanced AI image path used by Personal and Family consumer users, with roles, transfer purpose, supplementary measures, and duration.

    Download tagged PDF

  • Transfer Impact Assessment (TIA)

    The post-Schrems II assessment of the covered transfer to OpenRouter: transfer description, United States surveillance law analysis, practical risk, supplementary measures, residual risk, and ongoing monitoring.

    Download tagged PDF

  • VPAT Accessibility Report

    Criterion-level conformance against WCAG 2.2 Level A and AA and the Revised Section 508 standards.

    Download tagged PDF

  • European Accessibility Act (EAA) Conformance Statement

    Conformance basis, known exceptions, and EU enforcement procedures under Directive 2019/882.

  • EN 301 549 Conformance Mapping

    Clause-by-clause mapping of Aletheia against the harmonised European accessibility standard.

  • EU Accessibility Statement

    The accessibility statement in the mandated template of Commission Implementing Decision (EU) 2018/1523: compliance status, non-accessible content, preparation, feedback, and enforcement procedure for EU public sector procurement.

  • Privacy Policy

    On-device processing, account data handling, and the Institutional Deployment section covering Controller and Processor roles.

  • Cookies and Tracking Statement

    The cookie and tracking posture: no tracking cookies on the marketing site, only strictly necessary first-party storage in the product, and how that is treated under the ePrivacy Directive, with a runtime audit of the marketing site.

The HECVAT response is also downloadable as an Excel workbook (XLSX) from the HECVAT page, for import into a vendor-management tracking system.

Buying Aletheia for an institution in Germany?

Tell us the seat count and the sector and we will come back with a quote, the documents your procurement team needs, and answers on local currency and tax treatment.