Legal Documentation
Sustainable Digital Assets Inc.
Accessibility Statement
sdafintech.com — Sustainable Digital Assets Inc.
Prepared under the European Accessibility Act (Directive (EU) 2019/882) and EN 301 549 V3.2.1 (WCAG 2.1 Level AA)
1. Introduction and Commitment
Sustainable Digital Assets Inc. (“SDA”, “we”, “our”) is committed to making its digital services accessible to as many people as possible, including users who rely on assistive technologies. This accessibility statement applies to the website operated at https://sdafintech.com and to any subdomain or sub-route published under it that is made available to the public.
We have designed and continue to develop sdafintech.com with the objective of meeting the technical requirements of EN 301 549 V3.2.1 (Accessibility requirements for ICT products and services), which incorporates Web Content Accessibility Guidelines (WCAG) 2.1 at conformance Level AA. These standards establish the baseline accessibility framework required by:
- Directive (EU) 2019/882 (“European Accessibility Act” or “EAA”), applicable since 28 June 2025 to consumer-facing financial e-commerce services, including the offering of crypto-assets to retail consumers within the EU under Regulation (EU) 2023/1114 (“MiCA”)
- Directive (EU) 2016/2102 (“Web Accessibility Directive”), where the website provides information relevant to interactions with public-sector regulatory bodies
- The accessibility principles embedded in MiCA Article 6 and the consumer-protection objectives of MiCA Title II
Where any provision of MiCA, the EAA, or applicable national implementing legislation imposes a stricter accessibility obligation than the one declared here, that stricter obligation prevails.
2. Conformance Status
sdafintech.com is partially compliant with EN 301 549 V3.2.1 (WCAG 2.1 Level AA).
“Partial compliance” means that some parts of the content do not yet fully conform to the accessibility standard. These parts are identified in Section 3 below, together with the reason for non-compliance and, where applicable, the remediation plan.
We have not yet commissioned an independent third-party accessibility audit. The conformance level above is the result of an internal self-assessment (see Section 4). An external audit is planned and the conformance claim will be updated to reflect its findings.
3. Inaccessible Content
The following content on sdafintech.com is currently not fully accessible. We group the items by the reason permitted under Article 5 of the EAA and the corresponding national implementations: (a) non-conformance with WCAG 2.1 Level AA that we intend to remediate, (b) disproportionate burden, and (c) content outside the scope of the applicable accessibility legislation.
3.a. Non-conformance with WCAG 2.1 Level AA
The following items do not yet meet WCAG 2.1 AA. Each was identified by the audit described in Section 4 (Lighthouse v13.3.0 on ten representative pages plus a strict jsx-a11y static review across all components). Indicative element counts are reported alongside each item. All are scheduled for remediation under Section 6.
- Document language not declared on the root element. The
<html>element is emitted without alangattribute, so screen readers cannot select the correct pronunciation engine. This was observed on all ten pages audited and is the highest single-fix lever available. WCAG success criterion affected: 3.1.1 (Language of Page). - Links without a discernible accessible name. Icon-only links — predominantly the social-media icon rail in the site footer (Telegram, Discord, LinkedIn, X, Reddit, GitHub, Medium and similar) and a number of card-style links that wrap an icon and a graphic rather than text — do not yet carry an
aria-labelor visually hidden text equivalent. Approximately 77 elements across the ten audited pages. WCAG success criteria affected: 2.4.4 (Link Purpose, In Context), 4.1.2 (Name, Role, Value). - Buttons without an accessible name. The header includes at least one icon-only button (the mobile-menu toggle and related affordances) emitted without an
aria-label. Observed on every page audited. WCAG success criterion affected: 4.1.2 (Name, Role, Value). - Heading hierarchy not strictly descending. Approximately 13 headings across seven of the ten audited pages skip a level (for example, an
h4appearing where anh3would be expected under the page'sh2sections), and one instance comes from a third-party screen-reader-region heading emitted by an embedded Highcharts chart. WCAG success criteria affected: 1.3.1 (Info and Relationships), 2.4.6 (Headings and Labels). - Colour-contrast failures on accent and overlay text. Approximately 101 elements, concentrated on three pages, fall below the WCAG 1.4.3 contrast threshold. The most common pattern is mid-grey text (#999/#B3B3B3/#777) rendered on near-black backgrounds at the small label sizes used for meta-data and disabled controls. WCAG success criteria affected: 1.4.3 (Contrast — Minimum), 1.4.11 (Non-text Contrast).
- SVG icons with role “img” lacking text alternatives. Approximately 9 inline SVG icons on two pages declare
role="img"but provide no<title>oraria-label. WCAG success criterion affected: 1.1.1 (Non-text Content). - Click handlers on non-interactive elements without keyboard equivalents. The strict
jsx-a11yreview identified 13 issues across 7 components (notably the payment comparison table, quick-start cards, wallet selection grid, team cards, the contact-form custom submit affordance, the ESG-page accordion, and a list on the media-links page) where a<div>or other non-interactive element carries anonClickhandler without a matchingonKeyDown/role/tabindexpair. WCAG success criteria affected: 2.1.1 (Keyboard), 4.1.2 (Name, Role, Value). - PDF documents. Several binding legal instruments are published primarily as signed PDFs — including the LEI certificate, the KYC & AML policy, and the executed token purchase agreements. The MiCA white paper is published in tagged XHTML+iXBRL (which is screen-reader-compatible); the other PDFs do not yet include a fully tagged equivalent, and the
<object>embed on the LEI certificate page does not yet carry anaria-label. WCAG success criteria affected: 1.1.1 (Non-text Content), 1.3.1 (Info and Relationships), 1.3.2 (Meaningful Sequence), 4.1.2 (Name, Role, Value). - Motion and animation. Decorative slide-in/fade-in animations are used on card and section elements throughout the site (the
CardDiv slide-inwrapper and related utilities). These do not yet consistently respect theprefers-reduced-motionuser setting. Manual review item — not directly tested by Lighthouse. WCAG success criterion affected: 2.3.3 (Animation from Interactions). - Decorative emoji as visual markers. Section headings and callout boxes use emoji (e.g. “⚠️”, “📢”, “🌱”) without a consistent
aria-hiddenattribute and accompanying text-equivalent. Manual review item — Lighthouse does not flag this directly but assistive technologies announce the literal Unicode names. WCAG success criterion affected: 1.1.1 (Non-text Content). - Complex tabular data. The tokenomics allocation table and the refund-method table use standard
<table>markup but do not yet includescopeattributes or<caption>elements for assistive-technology navigation of multi-row, multi-column relationships. WCAG success criterion affected: 1.3.1 (Info and Relationships). - Form labelling and error messages. The contact form is visually labelled but the static review flagged a non-native interactive affordance on its submit path, and the form has not yet been re-audited end-to-end for programmatic label association and accessible-name consistency under assistive technologies. WCAG success criteria affected: 3.3.1 (Error Identification), 3.3.2 (Labels or Instructions), 4.1.2 (Name, Role, Value).
3.b. Disproportionate Burden
At present, no items on sdafintech.com are claimed under the “disproportionate burden” exemption permitted by Article 5 of the EAA. We will document any such claim here, together with the underlying assessment, if and when one is made.
3.c. Content Outside the Scope of the Applicable Legislation
The following content is not covered by the accessibility obligations applicable to sdafintech.com:
- Third-party embedded content. Videos and social-media posts referenced on the Media & Resources page (including content hosted on YouTube, X/Twitter, LinkedIn, Instagram, Reddit, Bitcointalk, Bluesky, Nostr, Hive, Minds, Farcaster, and similar platforms) remain under the editorial control of their respective publishers; their accessibility features depend on each host platform.
- Historic versions in the archive. Superseded documents preserved in the whitepaper archive are retained in their originally published form to preserve the historical record of representations made to investors, as required by MiCA. New accessibility remediation is applied only to current-effective versions.
- Documents signed by external parties. Signed instruments (executed token purchase agreements, signed KYC attestations, third-party audit reports) cannot be re-tagged after signature without breaking signature integrity. Where this applies, an accessible HTML or XHTML rendering of the same content is provided alongside the signed PDF wherever feasible.
- Pre-recorded media published before 28 June 2025. Pre-recorded media published before the EAA entry-into-force date is outside the scope of the EAA's media obligations, although we make best efforts to provide captions and transcripts where reasonably available.
4. Preparation of this Statement
This statement was prepared on: 12 May 2026.
Methodology: This statement is based on a self-assessment carried out by the internal product and engineering teams of Sustainable Digital Assets Inc. The following work was performed:
- Automated DOM-level audit using Google Lighthouse v13.3.0 (Headless Chrome 148) against ten representative pages covering each page template — home, token-sale, tokenomics, contact, the documentation index, the KYC/AML policy page, the LEI certificate viewer (PDF-embed template), the legal hub, the MiCA withdrawal-rights page, and this accessibility statement itself.
- Static JSX analysis across all React components and Next.js pages using ESLint with the
eslint-plugin-jsx-a11yruleset configured tostrict, focused on non-interactive elements with click handlers, keyboard-event coverage, accessible names and redundant ARIA roles. - Manual review of contrast pairings in the dark-theme palette (neon-green #2CFF05 and mid-grey #B3B3B3/#999/#777 against #000/#0B0B0B/#0d0d0d backgrounds), of the use of decorative emoji as section markers, of the use of motion utilities (slide-in / fade-in animations), and of heading hierarchy across templates.
Observed Lighthouse accessibility scores (Google Lighthouse v13.3.0, 12 May 2026) across the ten pages tested ranged from 78 to 84 out of 100, with a median of 82. The non-conformance items in Section 3.a above are drawn directly from this audit together with the static and manual reviews described in this section.
Last reviewed: 12 May 2026.
Next scheduled review: Within twelve months of the last review, and after any substantial change to the site architecture or any change to a critical user journey (purchase flow, KYC onboarding, withdrawal exercise, whitepaper publication).
5. Multimedia and Documents
Video content. sdafintech.com itself does not host any first-party video player. Embedded references to video content (e.g. coverage by exchanges and educational outlets) are served by their respective publishers. Where captions exist on the source platform they pass through unchanged.
Audio content. sdafintech.com does not host any first-party audio content.
PDF documents. Where a PDF is the canonical binding instrument (the signed white paper, signed KYC/AML policy, signed token purchase agreement, LEI certificate), we publish an accessible HTML or XHTML equivalent where feasible. The MiCA white paper is published as a fully tagged XHTML+iXBRL document at /legal/mica/whitepaper. If you need an alternative format of any other document, please contact us using the channels below.
Language. The primary publication language of sdafintech.com is English. Selected consumer-protection documents (notably the withdrawal-rights page) commit to additional Finnish and Swedish coverage; the localised versions are part of the improvement plan in Section 6 and are not yet fully published. If you need a specific document in Finnish or Swedish in the meantime, please contact us.
6. Improvement Plan
We treat accessibility as a continuous-improvement obligation. The following items are scheduled for action; target dates are indicative and may be updated as remediation work proceeds:
| Action | Scope / WCAG criterion | Target |
|---|---|---|
| Commission independent third-party WCAG 2.1 AA audit | Full site, all critical user journeys | Q4 2026 |
Declare document language on the root <html> element (custom Next.js _document.js with lang="en") | 3.1.1 | Q2 2026 |
| Add accessible names to all icon-only links and buttons (footer social rail, header menu toggle, card-style affordances) | 2.4.4, 4.1.2 | Q2 2026 |
Add keyboard equivalents (or convert to native interactive elements) for non-interactive components with onClick | 2.1.1, 4.1.2 | Q3 2026 |
| Repair heading hierarchy across affected templates | 1.3.1, 2.4.6 | Q3 2026 |
Publish tagged HTML/XHTML equivalents of all binding PDFs and add aria-label to PDF <object> embeds | 1.1.1, 1.3.1, 4.1.2 | Q3 2026 |
Apply prefers-reduced-motion globally | 2.3.3 | Q3 2026 |
| Systematic contrast audit of dark-theme accent palette | 1.4.3, 1.4.11 | Q3 2026 |
| Normalise decorative-emoji handling site-wide (aria-hidden) | 1.1.1 | Q3 2026 |
| Add table captions and scope attributes | 1.3.1 | Q3 2026 |
| Form-labelling and error-message audit (contact form, KYC flow) | 3.3.1, 3.3.2, 4.1.2 | Q4 2026 |
| Publish Finnish and Swedish translations of consumer-protection pages | Localisation commitment | Q1 2027 |
| Re-audit and republish this statement after the third-party audit | All | Within 30 days of receipt of the auditor's report |
7. Feedback and Contact Information
If you encounter an accessibility barrier on sdafintech.com, need information in an alternative format, or have any other accessibility question, please get in touch. We aim to acknowledge every accessibility request within 5 working days and to provide a substantive reply (including any alternative format) within 15 working days.
Accessibility Contact
Email: legal@sdafintech.com (please put “Accessibility” in the subject line)
Languages accepted: English (primary), Finnish, Swedish
Postal address (for formal notices):
Sustainable Digital Assets Inc.Attn: Accessibility Coordinator
Huggins House, P.O. Box 187
Old Manor Estate, Gingerland
Nevis, West Indies
When contacting us, please describe the barrier you encountered, the page URL where you encountered it, and (if comfortable) the assistive technology or browser configuration you were using. This information helps us reproduce and remediate the issue more quickly.
8. Enforcement Procedure
If after contacting us you are not satisfied with our response, you may escalate the matter to the national accessibility enforcement authority designated by your EU member state under Article 14 of the European Accessibility Act, or to the equivalent national equality / consumer-protection body. Contact details for the designated authority in each member state are maintained by the European Commission.
Crypto-asset-specific consumer complaints relating to MiCA compliance may, in addition, be addressed to the relevant national competent authority that received SDA's MiCA white paper notification, or to your local financial-services ombudsman.
Nothing in this statement limits any statutory right of redress you may have under applicable consumer-protection law.