Accessibility Statement - Sono AAC Communicator
Last updated: 25 May 2026
1. Scope
This accessibility statement applies to:
- The Sono AAC Communicator mobile application for Android and iOS.
- The Sono AAC Communicator promotional website, where published from the
plugins/communicator/promoproject.
Sono is a symbol-based augmentative and alternative communication (AAC) app. It is intended to help people communicate using images, sentence building, and text-to-speech.
1.1 European Accessibility Act (Directive (EU) 2019/882)
The European Accessibility Act (“EAA”) and its national implementations apply from 28 June 2025 to the products and services they cover. The table below is a preliminary assessment of Sono’s current features, not a determination of legal status.
| EAA category | Likely status for Sono | Notes |
|---|---|---|
| Consumer end-user equipment | Not applicable | Sono is software, not hardware. |
| E-commerce services | A consumer contract flow offered through a website or mobile app may bring that service into scope. Sono currently has no publisher-operated checkout or in-app purchase. | Re-evaluate the actual distribution and any future pricing or contract flow before relying on an exemption. |
| Services providing access to audiovisual media services | Not applicable | Sono is not an audiovisual media service. |
| Software primarily used for accessing audiovisual media services | Not applicable | Sono is not designed for AVMS access. |
| Other software / mobile applications | The EAA does not impose a general accessibility obligation on every mobile application. Its application to Sono depends on the service offered, distribution, and national law. | We aim to align with WCAG 2.2 AA and EN 301 549 as described in Section 2. Other laws or procurement requirements may also apply. |
Microenterprise consideration: Article 4(5) EAA contains an exemption for qualifying microenterprises providing services. Whether that exemption applies to the publisher and to a particular service has not been determined. We do not claim it here.
National law: The Croatian Zakon o zahtjevima za pristupačnost proizvoda i usluga (NN 89/2025, as amended by NN 114/2026) and other applicable national rules govern any legal obligations for Sono. This statement does not waive those obligations.
2. Commitment to Accessibility
We want Sono to be usable by people with a wide range of communication, motor, cognitive, visual, hearing, and learning needs.
Accessibility is especially important for an AAC app because users may rely on it for everyday communication. Our goal is to align Sono with:
- Web Content Accessibility Guidelines (WCAG) 2.2, Level AA, where applicable.
- EN 301 549, where applicable to mobile applications, software, and web content.
3. Conformance Status
Sono has not yet been shown to conform fully with WCAG 2.2 Level AA or the applicable accessibility requirements of EN 301 549. The known limitations below affect both the app and promotional website. This is a description of the current assessment, not a formal WCAG conformance claim.
This statement is based on an internal accessibility review carried out on 25 May 2026. The review included static code inspection against WCAG and EN 301 549 requirements. It has not yet been completed with a full manual audit using VoiceOver, TalkBack, external keyboard navigation, switch control, browser accessibility tooling, or usability testing with disabled users.
4. Accessibility Features
Sono includes several design and technical choices intended to support accessibility:
- Symbol-based communication with large visual targets.
- Text-to-speech output for composed messages.
- Offline-first operation after installation.
- Optional offline voice downloads.
- Support for multiple languages.
- Some semantic labels for symbol cards, sentence-strip controls, and selected states.
- Support for system-level text scaling in parts of the interface.
- Caretaker settings for personalising board layout, voice, display style, and symbol content.
These features help accessibility but do not yet guarantee full conformance.
5. Known Accessibility Limitations
The following limitations are known at the date of this statement.
5.1 Keyboard and Switch Access
Some interactive controls are implemented as custom touch targets and may not be reachable or operable with an external keyboard, switch control, or assistive technology activation gesture.
This affects parts of the symbol board, category navigation, sentence strip, settings selectors, games, whiteboard controls, and promotional website language selector.
Relevant requirements include WCAG 2.1.1 Keyboard, WCAG 2.4.7 Focus Visible, WCAG 4.1.2 Name, Role, Value, and the equivalent applicable EN 301 549 software requirements.
5.2 Games and Whiteboard
Some game interactions and the whiteboard drawing canvas rely on touch gestures. Equivalent keyboard, switch, or non-pointer alternatives are not yet provided for all game and whiteboard functions.
Relevant requirements include WCAG 2.1.1 Keyboard, WCAG 2.5.1 Pointer Gestures, and WCAG 4.1.2 Name, Role, Value.
5.3 Color Contrast
Some category colors, selected states, icon colors, and theme color options may not meet minimum contrast requirements for text or non-text UI components.
Relevant requirements include WCAG 1.4.3 Contrast (Minimum) and WCAG 1.4.11 Non-text Contrast.
5.4 Text Resizing and Reflow
Some labels and grid layouts use fixed sizes, one-line labels, or ellipsis. At large system text sizes, some text may be clipped, truncated, or harder to read.
Relevant requirements include WCAG 1.4.4 Resize Text and WCAG 1.4.10 Reflow.
5.5 Screen Reader Announcements
Some dynamic updates are visual only and may not be announced automatically by screen readers. This includes spoken-message confirmation banners, search-result count changes, and some loading or processing states.
Relevant requirement: WCAG 4.1.3 Status Messages.
5.6 Dialogs and Overlays
Some custom dialogs and overlays do not yet provide complete modal semantics, focus management, labelled dismiss controls, or predictable keyboard focus order.
Relevant requirements include WCAG 2.4.3 Focus Order, WCAG 2.4.7 Focus Visible, and WCAG 4.1.2 Name, Role, Value.
5.7 Caretaker Access Gate
Access to caretaker settings may require solving a simple math question. This may create an unnecessary cognitive barrier for some caretakers or users.
Relevant requirement: WCAG 3.3.8 Accessible Authentication (Minimum), where this interaction is treated as an authentication or access-control step.
5.8 Localisation of Accessible Names
Some accessibility labels and support text are currently hardcoded in English, even when the app is used in another language.
Relevant requirements include WCAG 3.1.2 Language of Parts and WCAG 4.1.2 Name, Role, Value.
5.9 Promotional Website Links and Language Selector
The promotional website language selector uses custom ARIA roles but does not yet provide complete keyboard interaction. Some app-store links may also be placeholders until final store listings are available.
Relevant requirements include WCAG 2.1.1 Keyboard, WCAG 2.4.4 Link Purpose, and WCAG 4.1.2 Name, Role, Value.
6. Alternatives and Workarounds
Where a feature is not yet fully accessible:
- Users may be able to use the main symbol board with touch input while keyboard and switch access is improved.
- Caretakers can adjust grid size, display style, voice, language, and symbol content to better match the user’s needs.
- Users who experience difficulty with games or whiteboard interactions can continue using the core communication board.
- Users and caretakers can contact us to request support, report a barrier, or ask for an alternative access path.
7. Planned Improvements
The current accessibility remediation priorities, owners, and target windows are below. All owners are the publisher (Matan Ljubas) unless stated otherwise. Target windows are indicative and will be revised as work progresses and as user feedback is received.
| # | Priority | Owner | Target window |
|---|---|---|---|
| 1 | Replace touch-only controls with accessible controls that support keyboard focus, activation, roles, names, selected states, disabled states, and visible focus indicators. | Publisher | Next two minor releases |
| 2 | Add complete semantics and keyboard alternatives for games and whiteboard tools where practical. | Publisher | Within 6 months of this statement |
| 3 | Centralise colour contrast handling so text and icons automatically choose an accessible foreground colour. | Publisher | Next minor release |
| 4 | Improve large-text support and reduce clipping in grids, tabs, chips, and sentence-building UI. | Publisher | Within 6 months of this statement |
| 5 | Add screen reader announcements for status messages, search results, loading states, and speech feedback. | Publisher | Within 6 months of this statement |
| 6 | Improve focus handling, modal semantics, and labelled close actions in custom overlays. | Publisher | Within 6 months of this statement |
| 7 | Replace or supplement the caretaker math gate with an accessible alternative under WCAG 3.3.8. | Publisher | Within 6 months of this statement |
| 8 | Localise accessibility labels and support text consistently across all supported languages. | Publisher | Within 12 months of this statement |
| 9 | Run a full manual audit with VoiceOver, TalkBack, external keyboard, and switch control, ideally including usability testing with AAC users. | Publisher (engaging external testers where feasible) | Within 12 months of this statement |
| 10 | Add automated and manual accessibility checks to the release process. | Publisher | Within 6 months of this statement |
If a procurement, commercial customer, or public-sector buyer requires a formal Accessibility Conformance Report or VPAT-style artefact ahead of these windows, we will prepare and share one on request — see Section 11.
8. Assessment Approach
This statement was prepared using self-evaluation.
The assessment included:
- Static inspection of Flutter widgets and promotional website code.
- Review against WCAG 2.2 success criteria.
- Review against applicable EN 301 549 software and web requirements.
flutter analyzefor the communicator package.
The assessment did not yet include:
- Full VoiceOver testing on iOS.
- Full TalkBack testing on Android.
- Full external keyboard testing.
- Switch control testing.
- Browser-based automated accessibility testing of the promotional website.
- User testing with disabled users or AAC users.
9. Feedback, Contact, and Escalation
We welcome feedback about accessibility barriers in Sono.
Primary contact:
Matan Ljubas 10A Ul. Joze Krstića, Zadar, Zadarska županija 23000, Croatia Email: lj.matan@gmail.com
Accessible alternative contact methods. If email is not accessible to you, you can also reach the publisher by post at the address above. If you need an alternative channel (for example because of a disability or because of assistive-technology compatibility), please indicate the channel you can use — by post, by asking a third party to email on your behalf, or by another reasonable means — and we will do our best to respond through a channel that works for you.
When reporting an accessibility issue, where possible please include:
- The device and operating system you are using;
- The app version, if known;
- The language selected in the app;
- The screen or feature where the issue occurred;
- The assistive technology used, if any;
- A short description of what happened and what you expected to happen.
Providing this information is not a precondition for us responding — we will work with whatever you can give us.
Response expectations. We aim to:
- Acknowledge accessibility feedback within seven (7) calendar days of receipt;
- Provide a substantive response, including an initial assessment and indicative remediation timing, within thirty (30) calendar days;
- Prioritise barriers that prevent communication, navigation, or core app use.
Where a barrier cannot be fixed quickly, we will, where reasonably possible, propose an interim workaround (see Section 6).
Escalation. If you are not satisfied with our response, you may contact the competent Croatian authority for the type of accessibility issue involved. Under Article 25(9) of the Croatian Zakon o zahtjevima za pristupačnost proizvoda i usluga, market inspectors of the State Inspectorate (Državni inspektorat) supervise in-scope e-commerce services. The Ombudsperson for Persons with Disabilities (Pravobranitelj za osobe s invaliditetom, posi.hr) can also provide guidance on disability rights. The applicable route depends on the service and complaint.
10. Review and Updates
This statement will be reviewed after significant accessibility changes and at least once per year.
Future updates should include the results of manual assistive-technology testing and any completed remediation work.
11. Accessibility Conformance Report (ACR / VPAT)
A formal Accessibility Conformance Report (also commonly referred to as a VPAT — Voluntary Product Accessibility Template) has not yet been published for Sono. Where a procurement, commercial customer, or public-sector buyer requires an ACR or VPAT-style artefact, the publisher can prepare one on request, reflecting the conformance status and known limitations described in Sections 3, 5, and 7 of this statement. Requests should be made via the contact details in Section 9 and should indicate the standard against which conformance is to be reported (for example WCAG 2.2 AA, EN 301 549, or Section 508 of the US Rehabilitation Act).
12. Formal Approval
This accessibility statement is approved by:
Matan Ljubas
Publisher of Sono AAC Communicator
This statement is intended to describe the current accessibility status of Sono AAC Communicator. It is not a guarantee of full legal compliance and does not replace legal advice for any specific jurisdiction, procurement process, or regulatory obligation.