Accessibility Statement

Mario Zunino & C. S.r.l.

Official statement pursuant to EU Directive 2019/882 (EAA)

Technical Certification Code

CERT-EAA-1778535699906

Keep for future verification • Uniquely identifies this assessment

Publication date: 11/05/2026 • Standard: WCAG 2.1/AA • Validity: 12 months

Conformity status: Partially Compliant • Pages analyzed: 15 • Last verification: 11/05/2026

Important information for reading

Nature of the evaluation: This document constitutes a technical certification based on automated analysis tools. It does not replace a legal certification of regulatory compliance, which requires additional manual verifications by qualified experts and accredited auditors
Continuous evaluation: This document represents the current state in the ongoing process of accessibility improvement
Indicative timelines: All timelines are indicative and subject to resource availability and technical constraints
Best effort principle: The organization operates according to standards of reasonableness and proportionality of interventions
Methodological limitations: Automated evaluations require integration with manual testing and user feedback for completeness
Dynamic updates: Substantial changes to the site will result in corresponding updates to the statement

Official Conformity Statement

This website is partially compliant with the accessibility requirements set forth in WCAG 2.1 Level AA Guidelines. Specific areas for improvement have been identified and are subject to gradual optimization according to a sustainable implementation strategy.

Statement date:
11/05/2026

Last technical verification:
11/05/2026

Statement validity:
12 months from issue date

Next update:
Within 12 months or upon substantial changes

Executive Summary and Key Metrics

Strategic Overview: This section provides an immediate overview of the website's accessibility status, actions taken, and improvement roadmap. The data presented reflects the organization's commitment to the systematic process of digital accessibility improvement, highlighting both the progress already achieved and the optimization areas identified to ensure an increasingly inclusive user experience.

Conformity Status

Partial

Continuous improvement active

Applied Standard

WCAG 2.1

Level AA + EAA

Analyzed Sample

representative pages

Methodology

Integrated

Automatic + Manual

✓ Positive aspects identified

The analysis highlighted 7 unique WCAG test types passed, demonstrating that the site has already implemented various accessibility best practices. Overall, 69 checks were passed across all analyzed pages.

The success rate of 59.0% indicates an established commitment to digital accessibility.

Unique Improvement Areas

Types of intervention needed ( total occurrences)

Critical Violations

Total accessibility blocks

59.0%

WCAG Compliance Score

Formula: 7 unique tests / (7 unique tests + 38 unique issues)

Contrasts

Chromatic improvements

Images

Text alternatives

UNIQUE Tests Passed

69 total with repetitions

High Priority

Priority interventions for user impact

Technical Evaluation Summary

Methodological approach applied: Automated technical evaluation on 15 representative pages, using an integrated suite of recognized tools for WCAG compliance verification

Analysis tools used: Multiple scanners with complementary technologies to maximize coverage and accuracy of the evaluation

Evaluation results:

✓ 7 UNIQUE WCAG test types passed (distinct criteria actually compliant)
Overall total: 69 tests passed out of 69 total checks (includes repetitions for each analyzed page)
38 unique problem types identified ( total instances)
Distribution by severity: 11 critical, 22 high priority, 5 medium priority
WCAG coverage: 15 criteria out of 50 verified (30%)

Implementation strategy: Gradual and sustainable approach to interventions, prioritized by user impact and technical feasibility

Data transparency: All technical details, quantitative metrics and verification logs are available upon request for support, audit and continuous improvement purposes

Organization Identification Data

Organization and website identification information
Field	Value
Name	Mario Zunino & C. S.r.l.
Website Evaluated	https://esterel.it/it/
Accessibility Manager	Mario Zunino & C. S.r.l.
Institutional Contacts	MARIOZUNINO.PEC@MAILDOC.IT
Reference Regulations	EU Directive 2019/882 (EAA), WCAG 2.1 AA, EN 301 549

Technical Evaluation Metadata

The following metadata ensure complete traceability, unique identification, and verifiability of the evaluation process conducted, ensuring compliance with international standards for digital accessibility auditing.

Complete accessibility evaluation metadata
Technical Field	Value
Certification Code	`CERT-EAA-1778535699906`
Verification Date and Time	11/05/2026
Conformity Standard	WCAG 2.1 Level AA, EN 301 549 v3.2.1
Sample Pages	15 representative pages
Temporal Validity	12 months from verification
Technology Stack	Standard web stack • CMS: Headless CMS
Publication Mode	"Accessibility" link from homepage (AgID Guidelines)
Update Frequency	Annual or upon substantial changes
Technical Contact	MARIOZUNINO.PEC@MAILDOC.IT

Methodology and Analysis Tools

This section describes the systematic and rigorous methodological approach adopted for the digital accessibility evaluation. The methodology combines automated analysis using internationally recognized tools with specialized manual verifications, ensuring broad coverage and accuracy in identifying areas for improvement.

Integrated methodological framework

Characteristics of the evaluation conducted:

Automated tools used: WAVE (WebAIM), axe-core (Deque Systems), Lighthouse (Google), Pa11y, complementary specialized scanners
Sampling criteria: Homepage, main informative sections, critical interactive functions, essential user paths, multimedia content, forms and online services
Evaluation coverage: Automated analysis (30% WCAG criteria covered) with 4 specialized scanners
Check periodicity: Complete annual verification, semi-annual monitoring, immediate testing after significant updates
Conformity standards: WCAG 2.1 Level AA, EN 301 549, EAA Directive 2019/882

Tool Suite Used

The evaluation was conducted using a coordinated combination of complementary automated tools to maximize the coverage of compliance tests:

Pa11y: HTML5 and ARIA validation, WCAG compliance criteria verification through advanced structural analysis engine
axe-core (Deque Systems): Industry-leading testing engine, used by developers and international organizations for automated accessibility verification
Lighthouse (Google): Integrated performance, SEO and accessibility audit with standardized metrics and specific recommendations
QualWeb: Advanced automated validation suite implementing ACT Rules and WCAG Techniques, providing complete and detailed coverage of accessibility guidelines

Data Processing and Normalization Process

Processing phases:

Multi-tool acquisition: Parallel execution of complementary scanners on representative sample
Format normalization: Output standardization for homogeneity and comparability of results
Intelligent deduplication: Duplicate elimination by WCAG criterion for accurate counting
Severity classification: Ordering by user experience impact and intervention priority
P.O.U.R. mapping: Organization according to WCAG principles (Perceivable, Operable, Understandable, Robust)

Sample Analyzed and Representativeness

Evaluation sample structure:

Main URL: https://esterel.it/it/

Processed pages: 15 representative pages of user experience

Specific detail of included pages:

Page: https://esterel.it/it/
Page: https://esterel.it/it/content/4-dal-1961
Page: https://esterel.it/it/222-i-fondamentali
Page: https://esterel.it/it/12-prodotti-per-capelli
Page: https://esterel.it/it/18-trattamenti-cura-dei-capelli
Page: https://esterel.it/it/50-prodotti-anticaduta
Page: https://esterel.it/it/176-anticaduta-androgenetica-alopecia-androgenetica-femminile-maschile
Page: https://esterel.it/it/177-anticaduta-post-parto
Page: https://esterel.it/it/178-anticaduta-stagionale
Page: https://esterel.it/it/179-anticaduta-areata-da-stress
Page: https://esterel.it/it/180-anticaduta-anti-eta
Page: https://esterel.it/it/151-soin-hydratant
Page: https://esterel.it/it/28-linee-capelli
Page: https://esterel.it/it/90-olio-di-argan-per-capelli
Page: https://esterel.it/it/181-solari-per-capelli

Representativeness criteria: The sample is designed to cover the most common navigation paths, critical functionalities and typical user interaction patterns on the site.

Methodological Limitations and Necessary Integrations

Transparency about automated evaluation limits:

It is essential to recognize that automated tests, while constituting a solid and objective foundation, cover approximately 30-40% of total WCAG criteria. The following areas necessarily require specialized manual verifications:

Contextual perception: Contrast evaluation in real-use conditions and complex visual contexts
Cognitive comprehension: Content clarity for users with cognitive or learning difficulties
Complex navigation: Keyboard usability in advanced interactive scenarios and multi-step workflows
Assistive compatibility: Actual functioning with various assistive technologies in real scenarios
Integrated user experience: Holistic evaluation of perceived accessibility by users with disabilities

Recommendation: This automated evaluation must be integrated with specialized manual tests and, ideally, with testing sessions conducted directly by users with various types of disabilities for a complete evaluation of actual accessibility.

Detailed Evaluation Results

The analysis of results is structured by thematic areas to facilitate understanding of intervention priorities and optimize improvement planning. Each area represents a key domain of web accessibility and aggregates related WCAG criteria to identify systemic patterns and streamline interventions.

General Results Overview

Data presentation approach: Results are presented according to a constructive logic that highlights improvement opportunities rather than criticalities. Each "identified element" represents a specific opportunity to optimize user experience and increase the inclusivity of the digital service.

Note on calculation methodology: The numbers reported represent the unique types of problems identified, not the total number of occurrences. For example, a contrast problem present in the footer will appear on all pages, but is counted only once since it requires a single correction intervention that will resolve all instances.

In this analysis: 38 unique problems correspond to total instances across all analyzed pages.

Detailed analysis by accessibility thematic areas
Thematic Area	Elements	Priority	WCAG Criterion	Intervention Strategy
Chromatic Contrasts Optimization of contrast ratios for universal readability	3 elements	High	WCAG 1.4.3 Minimum contrast	Gradual color palette optimization Systematic adjustment of chromatic ratios to ensure optimal readability on all devices
Alternative Texts Implementation of alternative descriptions for multimedia content	2 elements	Medium	WCAG 1.1.1 Non-text content	Alternative description integration Creation of descriptive and meaningful alternative texts for all informative images
Form Labels Enhancement of label-input associations for greater clarity	5 elements	High	WCAG 1.3.1 Info and relationships	Semantic association improvement Optimization of programmatic relationships between labels and input fields
Keyboard Navigation Refinement of accessibility through keyboard controls	0 elements	✓ OK	WCAG 2.1.1 Keyboard accessibility	Tab order optimization Improvement of sequential navigation flow and focus indicators
Links and Connections Link optimization for clarity and comprehensibility	4 elements	Medium	WCAG 2.4.4 Link purpose	Link text improvement Descriptive texts for links, avoid "click here" or generic links
Semantic Structure Improvement of content hierarchy and structure	4 elements	Medium	WCAG 1.3.1 Information and relationships	Heading hierarchy correction Correct structure of H1-H6 titles and ARIA landmarks
Other Elements Various improvements for complete compliance	29 elements	Low	Various WCAG Multiple criteria	Various optimizations Minor improvements for accessibility completeness

Tests Passed by Thematic Area

Analysis of accessibility checks that are compliant with WCAG 2.1 standards.

Detail of tests passed by accessibility category
Thematic Area	Tests Passed	Percentage	Description
Chromatic Contrasts	1	1.4%	Tests passed for minimum text/background contrast and graphic elements
Alternative Texts	3	4.3%	Tests passed for alternative texts and image descriptions
Form Labels	5	7.2%	Tests passed for form labels and input associations
Keyboard Navigation	5	7.2%	Tests passed for keyboard accessibility and tab order
Links and Connections	2	2.9%	Tests passed for descriptive links and navigation context
Semantic Structure	11	15.9%	Tests passed for headings, ARIA landmarks and document structure
TOTAL TESTS PASSED	69	100%	Overall total of conformity tests passed

Quantitative Distribution by Priority

High Priority

Elements with significant impact on user experience

Medium Priority

Recommended improvements for incremental optimization

Low Priority

Refinements for accessibility excellence

Applied Prioritization Methodology

Priority Classification Criteria:

User Impact: Severity of barriers for people with different types of disabilities
Occurrence Frequency: Problem prevalence in the navigation experience
Ease of Correction: Technical complexity and resources required for intervention
Regulatory Compliance: Relevance for WCAG and EAA standards compliance
Incremental Benefit: Added value for overall user experience

Important Methodological Note: The numbers presented represent "technical elements identified for optimization" rather than "errors" or "violations". This terminology reflects the constructive approach to continuous improvement, where each identified element constitutes a specific opportunity to improve inclusivity and usability of the digital service. Quantification facilitates intervention prioritization and progress measurement over time.

Improvement Plan and Timeline

Continuous Improvement Strategy: The organization has adopted a systematic strategy for digital accessibility improvement through a gradual, sustainable and technically grounded approach. Interventions are planned, prioritized and implemented according to objective user impact criteria, compatible with available resources and in compliance with regulatory timelines.

Regulatory Temporal Framework

EAA Reference: According to Article 32 of EU Directive 2019/882 (European Accessibility Act), for existing digital services not subject to substantial modifications, the deadline for full compliance is set to June 28, 2030.

Note on Timelines: Substantial modifications to the site, significant technological updates or regulatory developments may result in earlier compliance timelines than the general deadline.

Planned Interventions Roadmap

Detailed timeline of improvement phases
Phase	Timeline	Main Objectives	Specific Interventions
Phase 1 - Quick Wins	0-6 months	Immediate high-impact optimizations (8 priority interventions)	• Color contrast adjustments (3 types) • Alt text integration for images (2 types) • Form labeling corrections (5 types)
Phase 2 - Structural	6-18 months	Systemic architectural improvements (5 interventions)	• Keyboard navigation optimization (0 types) • HTML semantic structure enhancement (4 types) • Advanced ARIA implementation (29 types)
Phase 3 - Advanced	18-36 months	Advanced features and thorough testing (33 critical interventions)	• Resolution of 11 critical accessibility issues • Resolution of 22 high priority issues • Testing with real users and compliance validation
Phase 4 - Maintenance	Ongoing	Continuous monitoring and improvement	• Periodic automated audits • Updates for regulatory developments • Internal team training

Implementation Strategy by Priority Areas

Immediate Focus (0-6 months) - 3 contrast types:

Systematic analysis of existing color palette
Implementation of an accessible design system
Continuous automated contrast ratio testing
Validation with visually impaired users

Intermediate Phase (6-12 months) - 2 multimedia types:

Complete audit of all informative images
Creation of guidelines for effective alt text
Team training for accessible content production
Quality control workflow implementation

Operational Safeguard Clauses:

Implementation Flexibility: Timelines are indicative and may require adjustments to ensure technical quality and sustainability of interventions
System Compatibility: Some interventions may require extended timelines for compatibility with legacy architectures and third-party integrations
Resource Availability: Implementation proceeds in accordance with actually allocable technical, human and economic resources
Technical Constraints: Architectural limitations or external dependencies may affect the timing of specific interventions
Dynamic Prioritization: The order of interventions may be adjusted based on user feedback or regulatory developments

Guiding Principle: The organization operates according to the principle of "best technically and economically sustainable effort", committing to progressive accessibility improvement through a methodologically rigorous, gradual approach oriented towards concrete results for end users.

Disproportionate Burden Assessment

The European Accessibility Act (EU Directive 2019/882) allows organizations to declare disproportionate burden when compliance would entail costs, technical complexity or organizational efforts that are unreasonable relative to the organization's size and expected benefits. Such assessment must be objective, documented, periodically reviewed and transparently communicated.

Burden Assessment Methodology

Applied Assessment Criteria:

Organizational Size: Actually available human, technical and financial resources
Intervention Cost Estimate: Detailed technical-economic analysis of required adaptations
Expected Benefits: Assessment of positive impact for users with disabilities
Technical Alternatives: Availability of less costly alternative solutions
Operational Sustainability: Impact on continuity of essential services
Proportionality: Balance between costs and benefits in the specific context

Current Assessment Status: Currently, no burdens have been identified that could be qualified as disproportionate according to applicable regulatory and methodological criteria. The organization commits to pursuing gradual compliance on all accessibility criteria, in accordance with available resources and the outlined sustainable implementation strategy.

Identified Technical and Operational Limitations

Managed Operational Limitations:

Third-Party Services: Widgets, plugins or integrated external services that may not fully comply with standards. Active commitment to urge suppliers towards more accessible solutions
Legacy Systems in Transition: Digital infrastructure components undergoing gradual migration to modern technologies compliant with current standards
Historical Content Archives: Multimedia and documentary materials produced before current standards adoption, undergoing progressive review
Complex Advanced Features: Elements requiring significant architectural redesign, planned for subsequent development phases
Critical Dependencies: Essential services integrated with external systems for which accessibility improvement negotiations are ongoing

Management Approach: All limitations are subject to continuous monitoring and will be addressed according to defined priorities, availability of sustainable technical solutions and gradual resource allocation. Alternative access methods are provided for each limitation where technically possible.

Periodic Review Process

Periodic Review Process: The organization annually reviews the disproportionate burden assessment considering: technological developments, resource variations, user feedback, regulatory changes, new market solutions available.

Alternative Accessible Solutions

In compliance with EAA (European Accessibility Act) principles, the organization provides effective alternative solutions to ensure equitable access to information and services even in the presence of residual barriers. These alternatives are free, functionally equivalent and available within reasonable timeframes.

Alternative Solutions Principles

Guaranteed Equivalence Criteria:

Functional Equivalence: Same informational content and same functionalities as the digital service
Total Gratuity: No additional cost to the user for accessing alternatives
Timeliness: Delivery within indicated timeframes or timely communication of any delays
Service Quality: Quality standards equivalent to the main digital service
Information Completeness: No reduction or omission of essential content

Available Alternative Services Catalog

Alternative solutions for universal access to content and services
Service Type	Alternative Method	Request Method	Timeline
General Information and Content	Personalized email assistance with detailed responses and customized documents	MARIOZUNINO.PEC@MAILDOC.IT	≤ 5 working days
Non-Accessible Documents	Simplified HTML version, accessible Word or requested alternative format	MARIOZUNINO.PEC@MAILDOC.IT	≤ 7 working days
Online Forms and Procedures	Personalized guided assistance for completing paperwork and procedures	MARIOZUNINO.PEC@MAILDOC.IT	Appointment ≤ 48h
Multimedia Content	Complete text transcriptions, detailed audio descriptions, alternative formats	MARIOZUNINO.PEC@MAILDOC.IT	≤ 10 working days
Complex Interactive Services	Dedicated telephone support or video-assistance for guided navigation	MARIOZUNINO.PEC@MAILDOC.IT	By appointment

Request and Management Process

Optimized Request Method:

Submit Request: Detailed email specifying the service, content or functionality of interest
Useful Information to Include:
- Specific URL of problematic page or section
- Clear description of difficulty encountered
- Preferred alternative format (if applicable)
- Assistive technologies used
- Preferred contact method for response
Automatic Confirmation: Confirmation receipt within 24 hours with case number
Processing: Assignment and processing start within 48 working hours
Solution Delivery: Sending alternative solution within specified timeframes
Feedback and Follow-up: Opportunity to provide feedback for continuous improvement

Operational Conditions: Alternative solutions are provided in accordance with actually available resources. Particularly complex requests may require additional time that will be communicated promptly. The organization commits to providing equivalent solutions within technical and organizational possibilities, always prioritizing the best possible user experience.

User Involvement and Feedback

Active involvement of users with disabilities is a fundamental pillar for comprehensive digital accessibility assessment. While automated tests and technical verifications identify objective non-conformities, only testing with real users evaluates actual usability and solution adequacy in daily use contexts.

Multi-Channel Engagement Strategy

Structured Engagement Approach:

Continuous Feedback Collection: Always-active system for reports, suggestions and experiential evaluations
Constructive Dialogue: Collaborative approach to identify practicable and sustainable solutions
Participatory Prioritization: Systematic consideration of feedback in intervention planning
Progress Transparency: Communication of interventions implemented in response to received reports
Methodological Inclusivity: Involvement of users with different types of disabilities and technological skills

Active Participation Channels and Methods

Engagement and improvement contribution opportunities
Activity	Method	Status	Contact
Spontaneous Reports	Dedicated email with personalized response, case tracking and progress updates	Active	MARIOZUNINO.PEC@MAILDOC.IT
Correction Validation	Personalized follow-up with reporters to verify effectiveness of implemented interventions	On Request	MARIOZUNINO.PEC@MAILDOC.IT
Collaborative Testing Sessions	Structured involvement for evaluation of significant improvements and new features	In Planning	MARIOZUNINO.PEC@MAILDOC.IT
Periodic Surveys	Structured evaluations on user experience, alternative services and improvement priorities	Under Evaluation	MARIOZUNINO.PEC@MAILDOC.IT
Project Consultations	Involvement in design phases of new features or significant redesigns	For Future Projects	MARIOZUNINO.PEC@MAILDOC.IT

Effective Reporting Guide

Your feedback is valuable! Every report concretely contributes to accessibility improvement. To help us provide you with the most effective response possible, consider including:

Location

Specific problematic URL
Specific section or element
Path to reach it

Technical Context

Browser and version used
Operating system
Assistive technologies employed

Description

Problem encountered
Expected behavior
Impact on usage

Suggestions

Proposed solutions
Workarounds used
Contact preferences

Structured Management Process

Our commitment to every report:

Receipt (≤ 24 hours): Automatic confirmation with unique case number
Evaluation (≤ 5 days): In-depth technical analysis and priority classification
Initial Response (≤ 7 days): Acknowledgment communication with estimated timelines
Implementation: Interventions according to priority, complexity and available resources
Final Feedback: Communication of completed intervention or status update
Follow-up (optional): Satisfaction verification and effectiveness feedback collection

Contacts and Appeal Procedure

This section provides all necessary information to contact the organization on accessibility matters, request assistance, report issues or activate appeal procedures according to current regulations.

Institutional Accessibility References

Complete information for accessibility contacts
Reference	Details
Accessibility Manager	Mario Zunino & C. S.r.l.
Main Email	MARIOZUNINO.PEC@MAILDOC.IT
Standard Response Time	Within 5 working days For complete written reports
Communication Language	English (EN) Primary language for official communications
Preferred Methods	• Email: For detailed reports and documentation • Phone: For urgent matters or immediate clarifications

Official AgID Appeal Procedure

Regulatory Appeal Right

When to Activate: In case of unsatisfactory, inadequate or no response from the organization within 30 days from the initial report, a formal complaint can be submitted to AgID (Agency for Digital Italy) according to art. 3-quinquies of Law January 9, 2004, n. 4.

Submission Methods

Official Channel: AgID website or dedicated PEC
Required Documentation: Original report and received response
Required Information: Detailed description, evidence, service impact

AgID Timelines

Investigation: Response within 30 days of receipt
Inspection Powers: Activation of procedures if necessary
Measures: Adoption of measures to ensure compliance

Organization's Commitments to Users

Our Service Principles:

Active Listening

Every report is carefully evaluated and considered for continuous improvement

Transparency

Clear communication on timelines, methods and intervention progress status

Improvement

Systematic use of feedback to progressively optimize accessibility

Rights Protection

Recognition of universal right to digital service access

Alternative Solutions

Provision of alternative methods when necessary to ensure access

Compliance

Constant commitment to regulatory compliance and industry best practices

Validity and Updates: This statement is subject to periodic updates based on actually implemented and verified progress. Information reflects current status and is subject to change without notice due to operational, regulatory or technological developments. The organization constantly operates according to principles of continuous improvement, transparency and "best possible effort" compatible with available resources.

Document Revision History

This section ensures complete traceability of all changes made to the statement, ensuring transparency in document evolution and accountability for updates made.

Complete chronological record of document changes
Date	Responsible	Change Type	Version	Detailed Description
11/05/2026	Mario Zunino & C. S.r.l.	First Release	1.0	Initial publication of accessibility statement compliant with EAA regulations and AgID Guidelines

Versioning System: Each substantial update involves version number increment and detailed change recording. Minor updates (editorial corrections, date updates) maintain the main version with decimal increment (e.g., 1.1, 1.2).

Glossary and FAQ

This section provides clear definitions of technical terms and answers to common accessibility questions, making the document understandable to all readers and facilitating communication between technicians, decision-makers and users.

Essential Definitions

Digital Accessibility Ability of websites, apps and digital documents to be effectively used by people with different physical, sensory, cognitive or technological abilities. Includes full compatibility with assistive technologies such as screen readers, magnification software, voice commands and alternative control devices.
EAA (European Accessibility Act) EU Directive 2019/882 establishing mandatory accessibility requirements for digital products and services in the European Union. Progressively effective from 2025, it requires compliance with defined standards to ensure universal access to digital services.
WCAG (Web Content Accessibility Guidelines) W3C international standard defining detailed web accessibility criteria. Structured in 3 levels: A (basic), AA (standard for most contexts), AAA (advanced). Version 2.1 includes improvements for mobile devices and cognitive accessibility.
P.O.U.R. (WCAG Principles) The four fundamental WCAG principles: Perceivable (content presentable in different ways), Operable (interface usable by everyone), Understandable (clear information and operation), Robust (compatibility with different and future assistive technologies).
Assistive Technologies Hardware and software devices used by people with disabilities to access digital content. Include screen readers (NVDA, JAWS, VoiceOver), braille displays, magnification software, voice recognition, alternative keyboards and control switches.
Compliance State of adherence to established regulatory and technical requirements. For web accessibility, it implies satisfying applicable WCAG criteria and current national/European regulations. Compliance can be total, partial or absent.
Screen Reader Software that converts digital content into voice or braille output, allowing blind or visually impaired people to navigate and interact with websites and applications. Requires content to be properly structured and coded.
WCAG Success Criterion A specific, testable and verifiable requirement of the WCAG guidelines. Each criterion has an identification code (e.g., 1.4.3 for color contrast) and belongs to the 4 P.O.U.R. principles: Perceivable, Operable, Understandable, Robust.
Disproportionate Burden EAA regulatory exception when financial, technical or organizational costs significantly exceed expected benefits, considering the organization's size and resources. Requires objective documentation and does not exempt from providing equivalent alternatives.
Accessibility Audit Systematic compliance evaluation against standards through automated testing (~30-40% of criteria), specialist manual checks (navigation, comprehensibility, interactions) and ideally testing with real users with various disabilities.
Color Contrast Mathematical ratio between text and background luminosity. WCAG requires minimum 4.5:1 for normal text, 3:1 for large text (18pt+ or 14pt+ bold). Essential for visually impaired users, those with color deficiencies or in difficult lighting conditions.
Alt Text (Alternative Text) Concise textual description of images accessible to screen readers and displayed if images don't load. Must convey the same meaning as the visual element. For decorative images it should be empty (alt="").
Focus Indicator Visual highlighting that shows which element is active during keyboard navigation. Must have minimum 3:1 contrast against background, always be visible and clearly distinguishable. Critical for mouse-free navigation.
Semantic Structure HTML organization that uses appropriate elements for meaning (header, nav, main, section, article) as well as appearance. Facilitates page structure understanding by assistive technologies and search engines.
ARIA (Accessible Rich Internet Applications) Set of HTML attributes that provide additional information about dynamic/interactive elements for assistive technologies. Includes roles (role), properties (aria-label, aria-describedby) and states (aria-expanded, aria-selected).

Frequently Asked Questions

Why has digital accessibility become mandatory? Accessibility is a fundamental right that guarantees equal opportunities for the 15% of the European population with disabilities. The EAA legislation (2025) makes this principle legally binding, with possible penalties for non-compliance, but the primary goal remains social inclusion and equality of opportunity in accessing digital services.
How much does it cost to implement digital accessibility? Costs vary significantly: considering accessibility from design, the increase is typically 5-10% of the budget. For adaptations to existing sites, it can reach 20-50%. The investment pays off through wider audience, better SEO, reduced legal risk and overall usability improvement.
Do automated tests guarantee complete accessibility? No, they only detect 30-40% of issues. Also essential are: specialist manual tests for keyboard navigation, content comprehensibility, complex interactions; testing with different assistive technologies; validation with real users with disabilities to verify actual accessibility and perceived usability.
What happens if an organization is not fully compliant? The regulations promote continuous improvement rather than immediate penalties. Important to demonstrate concrete commitment: documented improvement plans, gradual implementation, transparency about limitations, effective alternative solutions, constructive dialogue with users.
How can I report an accessibility problem? By sending an email to the address indicated in the contacts section, describing the problem encountered, the affected page, the browser used and any assistive technologies employed.
Are alternative solutions truly equivalent? Yes, by law they must be functionally equivalent: same content, same quality, same completeness, free. They may require more delivery time but must not limit access to information or services. Quality and completeness are guaranteed.
What are the regulatory timelines for compliance? According to EAA, for existing digital services not substantially modified, the deadline is June 28, 2030. Substantial modifications to the site result in earlier deadlines. The approach is gradual and sustainable improvement rather than immediate adaptation.

This glossary is periodically expanded. For specific questions or additional clarifications, contact the accessibility manager using the references in the contacts section.

Regulatory and Technical References

This section lists all regulatory, technical and methodological references used for the preparation of this statement, providing the complete legal and technical basis for the evaluation conducted.

European and national regulations

EU Directive 2019/882 of 17 April 2019 on accessibility requirements for products and services (European Accessibility Act - EAA)
EU Directive 2016/2102 of 26 October 2016 on the accessibility of websites and mobile applications of public sector bodies
Law 9 January 2004, n. 4 "Provisions to facilitate access for disabled persons to IT tools" (Stanca Law) and subsequent amendments
Legislative Decree 10 August 2018, n. 106 "Implementation of EU Directive 2016/2102 on the accessibility of websites and mobile applications of public sector bodies"
Ministerial Decree 20 March 2013 "Amendments to Annex A of the Decree of 8 July 2005 of the Minister for Innovation and Technologies"

International technical standards

WCAG 2.1 (Web Content Accessibility Guidelines) - W3C Guidelines for Web Content Accessibility, version 2.1, level AA
EN 301 549 V3.2.1 (2021-03) - "Accessibility requirements for ICT products and services" - European standard for ICT accessibility
ISO/IEC 40500:2012 - International standard corresponding to WCAG 2.0
ISO 14289-1:2014 - Document management applications - Electronic document file format enhancement for accessibility - Part 1: Use of ISO 32000-1 (PDF/UA-1)
WAI-ARIA 1.1 Specification - Accessible Rich Internet Applications (WAI-ARIA) 1.1

Guidelines and methodological documents

AgID Guidelines on accessibility of IT tools - Agency for Digital Italy
Accessibility monitoring methodology - Commission Implementing Decision EU 2018/1524
Understanding WCAG 2.1 and Techniques for WCAG 2.1 - W3C Web Accessibility Initiative
ARIA Authoring Practices Guide (APG) - W3C WAI
European Disability Forum (EDF) - Recommendations for EAA implementation

Testing tools and methodologies used

Testing and evaluation tools used in this analysis
Tool	Developer	Type	Specific Purpose
Pa11y	Team Pa11y	CLI/API Scanner	HTML5, ARIA validation and WCAG compliance via advanced engine
axe-core	Deque Systems	Automated engine	Industry-leading accessibility testing with extensive WCAG criteria coverage
Lighthouse	Google	Integrated audit	Performance, SEO and accessibility evaluation with standardized metrics
QualWeb	Universidade de Lisboa	Complete evaluation suite	Complete WCAG, ACT Rules and accessibility best practices evaluation

Support resources and best practices

W3C Resources

Web Accessibility Initiative (WAI)
WCAG 2.1 Understanding Documents
ARIA Specifications and Practices
Accessibility Testing Resources

Institutions and Organizations

AgID - Agency for Digital Italy
European Disability Forum (EDF)
European Commission - Digital Single Market
ETSI - European Telecommunications Standards Institute

Specialized Technical Resources

WebAIM - Articles and practical guides
A11Y Project - Community-driven resources
Inclusive Design Principles
Color Contrast Analyzers and Testing Tools

Available technical documentation

Additional documentation available on motivated request:

Technical Reports

Detailed testing tool logs
Raw data in JSON/CSV format
Complete quantitative metrics

Methodologies

Manual evaluation checklists
Applied testing plans
Sampling criteria used

In-depth Analysis

Breakdown by WCAG criterion
Temporal comparative analysis
Impact and prioritization studies

Request method: Technical documentation available for audits, research, technical support or inspections through contacts indicated in the dedicated section.

Validity and updates of references

Validity and updates of references: All regulatory and technical references are current as of the publication date of this statement. The organization monitors regulatory developments and technical standards for timely document updates in case of substantial changes to the reference regulations.

Accessibility Audit Metadata

The following metadata ensure complete traceability, unique identification and verifiability of the evaluation process conducted, ensuring compliance with international standards for digital accessibility auditing.

Complete accessibility evaluation metadata
Technical Field	Value
Technical Certification Code	`CERT-EAA-1778535699906`
Audit Conducting Entity	Principi S.r.l.
Technical Manager	Andrea Vadacchino
Assessment Date	11/05/2026
Reference Standard	WCAG 2.1 Level AA - EN 301 549 v3.2.1
Applied Methodology	WCAG-EM + Multi-Scanner Automated Testing
Automated Assessment Tools	pa11y, axe-core, lighthouse, qualweb
Accessibility Statement Manager	Mario Zunino & C. S.r.l.
Accessibility Email Contact	MARIOZUNINO.PEC@MAILDOC.IT
Total Pages Analyzed	15
Overall Compliance Rate	59.0% - Partially Compliant

Audit conduct information

Evaluated organization: Mario Zunino & C. S.r.l.

Evaluated website: https://esterel.it/it/

Conducted by: Andrea Vadacchino - Principi S.r.l.

Validation method: Multi-scanner automated testing with expert review of results

Accuracy level: Assessment compliant with international standards with extensive WCAG criteria coverage

Additional notes: Audit conducted according to international best practices to ensure maximum accuracy and completeness

Official Document - Accessibility Statement

Drafted in conformity with EU Directive 2019/882 (European Accessibility Act)
Reference standard: WCAG 2.1 level AA, EN 301 549 v3.2.1
Publication date: 11/05/2026
Statement validity: 12 months from issue date

This document constitutes an official statement pursuant to applicable regulations
The organization operates according to the principle of best possible effort compatible with available resources

Organization:
Mario Zunino & C. S.r.l.

Last update:
11/05/2026

Next review:
Within 12 months

Certification Code:
CERT-EAA-1778535699906

LEGAL CLAUSES:
This statement is subject to periodic review and may be updated without notice due to operational, regulatory or technological changes.
The information reflects the state at the time of publication. The organization reserves the right to modify
timelines and procedures in accordance with available resources and regulatory constraints that may arise.