Accessibility guide

Do Accessibility Overlays Work? An Honest Answer

Accessibility overlays are widgets you add to a site that promise to make it accessible automatically, often with a small accessibility icon in the corner. They are heavily marketed and widely misunderstood. This guide gives the honest, source-backed answer: overlays do not make a site compliant, and relying on them can increase your risk.

Reviewed by the EAA Navigator team

TL;DR

  • An overlay is a third-party script (such as accessiBe, AudioEye, UserWay or EqualWeb) that claims to detect and fix accessibility issues automatically.
  • Automated tools detect only about 30 to 40 per cent of WCAG issues; the rest require human testing, so an overlay cannot make a site conformant.
  • The Overlay Fact Sheet, signed by more than 1,000 accessibility professionals, rejects overlays as a compliance solution, and overlay-equipped sites are still sued.
  • In 2025 the FTC finalised a $1,000,000 order against accessiBe for deceptive claims that its product makes sites compliant. Treat overlays as marketing, not compliance.
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In this guide

What this covers

  • What an accessibility overlay actually is and what it claims to do.
  • Why automated-only fixing cannot deliver compliance.
  • The independent and regulatory evidence against overlays as a compliance solution.
  • What to do instead if you want a site that genuinely works for disabled users.

What matters

Why overlays fall short

  • Automated coverage is limited: automated tools catch only about 30 to 40 per cent of WCAG issues. Things like meaningful alt text, logical reading order and usable forms need human judgement.
  • Overlays sit on top of the problem: they do not fix the underlying code, so the barriers remain for users who turn the widget off or use their own assistive technology.
  • They are still litigated: overlay-equipped sites continue to receive complaints and lawsuits, and the DOJ has said overlays do not equal ADA compliance.
  • Regulators have acted: the Overlay Fact Sheet (signed by 1,000+ professionals) rejects overlays, and in 2025 the FTC finalised a $1,000,000 order against accessiBe over deceptive "AI makes you compliant" claims.

Across web accessibility, Level AA of WCAG 2.2 is the working target, and for the EU it is incorporated into the harmonised standard EN 301 549.

What to do

What to do next

  1. Do not treat an overlay as evidence of compliance — it is not, regardless of the vendor’s marketing.
  2. Commission a manual accessibility audit against WCAG 2.1 AA (or 2.2 AA) to find the issues automated tools miss.
  3. Fix issues in your own code and content: contrast, alt text, form labels, keyboard operation and focus order.
  4. Publish an honest accessibility statement with a feedback route, rather than an overlay badge.
  5. If you already run an overlay, keep auditing and remediating the underlying site; the widget does not remove that obligation.

For the standard itself, see the WCAG explainer; to put it into practice, work through the WCAG 2.2 AA checklist.

FAQ

Common questions

Do accessibility overlays make my site compliant?
No. Overlays cannot make a site conformant. Automated tools detect only about 30 to 40 per cent of WCAG issues, and the rest require human testing. The DOJ has said overlays do not equal ADA compliance, and overlay-equipped sites continue to be sued.
What is the Overlay Fact Sheet?
It is a public statement at overlayfactsheet.com, signed by more than 1,000 accessibility professionals and disabled users, documenting why overlay and widget products do not deliver accessibility or compliance and can introduce new barriers.
Did accessiBe get fined?
In 2025 the US Federal Trade Commission finalised a $1,000,000 order against accessiBe over deceptive advertising claims that its product could make any website compliant. It is a clear signal that "AI makes you compliant" marketing does not hold up.
What should I do instead of using an overlay?
Test your site properly — automated checks plus manual keyboard and screen-reader testing, or a professional audit — then fix the issues in your own code and content. Publish an honest accessibility statement with a way for users to report problems.

Make your site accessible

Start with the WCAG 2.2 AA checklist, then work through the guides to fix what you find.

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This is guidance, not legal advice

This guide is here to help you understand web accessibility and how WCAG, the EAA and the ADA apply in practice. It is not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Web Content Accessibility Guidelines (WCAG) 2.2 (W3C Recommendation)retrieved 9 Jun 2026
  2. [2]WCAG overview (W3C Web Accessibility Initiative)retrieved 9 Jun 2026
  3. [3]Directive (EU) 2019/882 — European Accessibility Act (EUR-Lex)retrieved 9 Jun 2026
  4. [4]EN 301 549 v3.2.1 — harmonised ICT accessibility standard (ETSI)retrieved 9 Jun 2026
  5. [5]US DOJ ADA Title II web accessibility rule fact sheetretrieved 9 Jun 2026
  6. [6]WebAIM Million 2025 — accessibility of the top 1,000,000 home pagesretrieved 9 Jun 2026
  7. [7]Overlay Fact Sheet — why overlays do not deliver complianceretrieved 9 Jun 2026

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Do Accessibility Overlays Work? The Honest Answer | EAA Navigator · EAA Navigator