Xymex is committed to making Lucy usable by as many people as possible. This statement describes how Lucy measures up against the accessibility requirements of the European Accessibility Act (Directive (EU) 2019/882), as given technical form by EN 301 549 and the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.
We claim partial conformance. The gaps we currently know about are listed below by name. We would rather tell you exactly where Lucy falls short than claim a level of conformance we have not verified.
1. Scope
This statement applies to the Lucy application for iPhone, iPad, and Mac, distributed through the Apple App Store, and to this website at lucy.xymex.app.
2. What Lucy supports today
The following are implemented and exercised by an automated accessibility test suite that runs on every change, plus manual checks on physical devices:
- VoiceOver. Controls, transcript rows, and status surfaces carry explicit labels; interactive elements carry hints and values where the label alone would not convey state. Headings are marked as headings so rotor navigation works.
- Dynamic Type, including the accessibility sizes. Layouts adapt at the largest accessibility text sizes rather than clipping or truncating. Screens are checked against the smallest supported display at the largest text size, because that combination is where text fails first.
- Reduce Motion. Animations and transitions respect the system setting.
- Dark mode and system contrast settings are honoured throughout.
- No time limits. Nothing in Lucy expires, times out, or requires a response within a fixed period.
- No reliance on colour alone. Status is conveyed by text and shape as well as colour.
- Full offline operation. Lucy does not require an account, a network connection, or any interaction with a third-party service to do its job, which removes a common class of accessibility barrier.
3. Known gaps
These are real, current, and specific. Each is something we have measured rather than estimated.
3.1 VoiceOver and interface text are not fully translated
Lucy ships in eight languages: English, German, Spanish, French, Italian, Dutch, Portuguese (Brazil), and Romanian. 81 interface strings are missing a translation in at least one of those languages and fall back to English. A VoiceOver user working in a non-English language will therefore hear some labels read out in English.
Affected: EN 301 549 clause 11 / WCAG 3.1.2 (Language of Parts). Impact: moderate — the control remains operable and its meaning is usually clear from context, but the reading is in the wrong language.
3.2 System permission prompts appear in English
The iOS prompts asking permission to use the microphone, Face ID, and speech recognition are currently supplied in English only. Users running Lucy in another language will see those three system dialogs in English.
Affected: WCAG 3.1.2. Impact: moderate, and limited to first run.
3.3 Search results are not fully exposed to VoiceOver
On the search results screen, some elements do not currently expose their accessibility information to assistive technology in the way the rest of the app does. Search results remain reachable and readable on screen, but VoiceOver navigation of that particular screen is less precise than elsewhere in Lucy.
Affected: EN 301 549 clause 11 / WCAG 4.1.2 (Name, Role, Value). Impact: moderate, on one screen.
3.4 Not every screen has been audited at the largest text sizes
Our automated checks cover the screens a person moves through in normal use. A small number of less-travelled screens — chiefly diagnostic and developer-facing surfaces — have not yet been verified at the largest accessibility text sizes.
Affected: WCAG 1.4.4 (Resize Text). Impact: low.
3.5 Transcription accuracy is not uniform across languages
Lucy transcribes speech on your device, and accuracy varies by language and by recording conditions. This is a limitation of automatic speech recognition rather than of the interface, but it matters for anyone relying on transcription as an accessibility aid: Lucy's transcripts are not a substitute for professional captioning where accuracy is essential. Measured error rates per language are published in the app and in our accuracy report.
4. How we test
- An automated accessibility suite runs on every code change, on every supported screen. It walks the interface at the largest accessibility text sizes and asserts that controls are labelled and remain present and operable.
- Manual verification with VoiceOver on physical iPhone and Mac hardware, not a simulator alone.
- Layouts are reviewed at the largest text size on the smallest supported screen, which is where text fails first.
A limitation of that automation, stated plainly: the automated checks confirm a control is present and operable at large text sizes. They do not confirm that its text is fully legible — a label that is clipped or truncated can still pass them. Legibility is verified by eye, which is why gap 3.4 above exists for screens that have not yet had that manual pass.
We do not currently commission an independent third-party accessibility audit. If we do, we will say so here and publish the result.
5. Feedback
If you hit an accessibility barrier in Lucy — including anything not listed above — please tell us at support@xymex.com. Describe what you were trying to do, the assistive technology and settings you were using, and the device. We read every message.
We aim to respond within five working days. If you are not satisfied with our response, you may escalate to the market surveillance authority responsible for the European Accessibility Act in your EU member state.
6. Status of this statement
This statement was prepared on 5 August 2026 through a self-assessment of Lucy against EN 301 549 and WCAG 2.1 Level AA. It reflects the version of Lucy current at that date and will be revised as the gaps above are closed or as new ones are found.