Accessibility Statement — MINOMO

What this Statement is and why it exists

This Accessibility Statement describes the level of conformance of MINOMO’s services with the accessibility requirements set out in European legislation, the accessibility features we have already implemented, the limitations we are aware of, and how you can report difficulties using the service or request specific assistance.

The publication of this Statement is provided for by Directive (EU) 2019/882 on the accessibility of products and services (the so-called European Accessibility Act, EAA), transposed in Italy by Italian Legislative Decree no. 82 of 27 May 2022 and in Romania by Legea nr. 232/2022, applicable to a range of services including e-commerce from 28 June 2025.

MINOMO does not fall within the category of essential public services subject to stricter accessibility obligations under Directive (EU) 2016/2102 on public sector websites, but we voluntarily adopt the same frame of reference because we consider it consistent with the values of the project and with our ambition to be a genuinely proximity service — accessible, that is, to anyone who lives in the city.

Which services this applies to

This Statement applies to:

• the showcase website at minomo.io and its public sections (Atlas, blog, legal documents), and the public pages of merchants and City Agents;
• the MINOMO consumer application, available as a PWA at app.minomo.io, on the App Store (iOS) and on Google Play (Android), including the civic services (municipal communications, consultations, issue reports) and the assistant MINA;
• the panels for merchants, City Agents, Country Managers, distributors, municipalities (municipal panel) and administrators;
• the municipal pages published by MINOMO on municipalities’ own domains. A municipality that is an Italian public administration publishes its own accessibility statement under Law 4/2004 and the AgID guidelines; MINOMO gives it the technical information it needs.

The conformance audit focuses first on the interfaces intended for the general public (showcase website, app and civic services, municipal pages). The panels come next.

Reference standard

We adopt as our reference standard the Web Content Accessibility Guidelines 2.1 from the W3C, conformance level AA, incorporated into the European harmonised standard EN 301 549 v3.2.1. The standard covers the four fundamental principles of accessibility:

• Perceivable — content is presented in ways that users can perceive, including through assistive technologies (screen readers, captions, text alternatives to images);
• Operable — interface components are operable by keyboard navigation, with adequate time, avoiding seizure triggers;
• Understandable — text and interactions are readable and predictable;
• Robust — content can be reliably interpreted by the wide variety of user agents available, including assistive technologies.

Current conformance status (October 2026)

At the time of this update, the MINOMO service is partially conformant with WCAG 2.1 AA requirements. The table below summarises the status by area. We give no dates for full conformance until the detailed audits are complete: we will update this Statement as each one concludes.

Area	Status
Showcase website minomo.io (landing, blog, legal documents, Atlas)	Substantial conformance with WCAG 2.1 AA criteria; detailed audit not yet complete
App app.minomo.io and native iOS / Android apps	Partial conformance: keyboard navigation functional, colour contrast met in principal views. Some interactive components (bottom sheet, maps, modals) present known gaps.
Civic services in the app (municipal communications, consultations, issue reports)	Audit not yet carried out. The reports map is an interactive component with the limits described below.
Municipal pages	Simple pages, designed for WCAG 2.1 AA criteria; audit not yet carried out. The reports map, which appears only when there are reports, is an interactive component with the limits described below.
Panels (merchants, City Agents, Country Managers, distributors, municipalities, administration)	Audit not yet complete. Principal features are operable by keyboard but not all WCAG criteria have been measured.

The status is assessed through a combination of:

• internal self-assessment carried out by our technical team, based on WCAG 2.1 AA criteria;
• automated tools (Axe DevTools, WAVE, Lighthouse);
• manual testing with keyboard, screen reader (VoiceOver on macOS/iOS, NVDA on Windows), 200% zoom, high contrast.

Areas declared “partial conformance” are not unusable: it means that individual criteria are not yet met or specific components require revision. When we identify an actual blocker, we treat it as a priority incident.

Accessibility features implemented

Among the design and implementation choices we have already adopted:

• Semantic HTML structure with correct use of headings (h1–h4), lists, tables, and ARIA landmarks;
• Accessible labelling of buttons, links, and input fields;
• Colour contrast met for body text (minimum ratio 4.5:1 WCAG AA);
• Keyboard navigation across all public pages of the showcase website and the principal views of the consumer PWA;
• Declared language for each page (<html lang="…">) to enable correct pronunciation by screen readers;
• Text alternatives on significant images (merchant avatars, Atlas POI photos, editorial illustrations);
• Reduced animations in response to the operating system’s prefers-reduced-motion preference;
• Compatibility with text resizing up to 200% without loss of content;
• Accessible forms with clear labels, explicit error indication, and confirmations readable by screen readers.

Known limitations

We set out here the accessibility limitations we are aware of and are actively working on. We will update this section with each significant release.

• Atlas map, POI maps and issue-report maps (in the app and on municipal pages): cartographic navigation is currently mouse- and touch-driven. We are working on full keyboard controls and an alternative list view for all displayed items;
• Consumer PWA bottom sheet: the component that opens from the bottom of the screen for details and quick actions presents gaps in focus management when opened or closed by touch gestures. Fix planned for the next release;
• Animated loyalty cards: some animations are reduced but cannot be fully disabled; we are introducing a user option to disable them even in the absence of the system flag;
• Chat with MINA: the conversational experience is accessible by keyboard, but POI citations and quick suggestions (chips) are under review to improve the screen reader experience;
• Attached PDF documents: the few PDFs available are accessible in their main text but some tabular elements lack full semantic structure. We are migrating relevant content to accessible HTML pages.

If you find a limitation we have not listed here, please let us know: we will add your report to our public register.

Feedback, reports, and alternative assistance

If you encounter a barrier when using MINOMO — a component that is not operable, information that is not perceivable, a feature you cannot reach with your assistive technology — please write to us. Our dedicated point of contact is:

• Email: [email protected]
• Postal address: AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, 500051 Brașov, România

When reporting, please include:

1. the page or feature where you encountered the problem (URL if possible);
2. a description of the problem (what you were trying to do, what happened);
3. your assistive technology (if relevant: name of the screen reader, browser, operating system);
4. a contact address for our reply, if you would like one.

We commit to:

• providing a response within 15 working days of receipt;
• offering you, where possible, an alternative means of accessing the information or feature you need, whilst we resolve the issue (for example, by providing a merchant’s details in an accessible format by email);
• updating the status of this Statement when the fix is in production.

Enforcement procedure

If you consider that our response to your report is inadequate, you may contact the supervisory authority in the country where you use the service:

• Italy: AgID — Agenzia per l’Italia Digitale, the national authority responsible for digital accessibility;
• Romania: the authority designated under Legea nr. 232/2022;
• Other EU countries: the national authority designated in implementation of Directive (EU) 2019/882.

Changes to this Statement

We will update this Statement at least once a year, or whenever there are significant changes in conformance status or known limitations. The date and version at the top of the document always reflect the most recent update.

Version	Date	Changes
1.1	7 October 2026	The Statement now also covers the civic services, the municipal panel and the municipal pages. Removed the target dates that had expired and the entry on native apps “under development”, which are already in the stores.
1.0	15 May 2026	First publication of the Accessibility Statement in line with the EAA (Directive (EU) 2019/882) and the launch of the WCAG 2.1 AA programme.

Contact

• Accessibility: [email protected]
• General support: [email protected]
• General enquiries: [email protected]
• Address: AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, 500051 Brașov, România