Overlay Report: a widget is not compliance

Who says overlays do not work

The editors of the WCAG and ARIA specifications, contributors to the JAWS and NVDA screen readers, in-house accessibility staff at Google, Microsoft and GitHub, disability rights lawyers, and blind people who use the web every day. Fifty of the 1,029 signatories:

Matt KingChair, W3C ARIA Authoring Practices Task Force and W3C ARIA and Assistive Technologies Community Group
Marco Zeheformerly of Freedom Scientific, Mozilla, NVDA and open web contributor, accessibility veteran
Lainey Feingoldlawyer and author, Law Office of Lainey Feingold
Dirk GinaderUX Engineer, Google
Karl GrovesDigital Accessibility Consultant at AFixt and Founder of Eventably
Jeremy KeithFounder, Clearleft
Detlev FischerManaging Director of DIAS GmbH, W3C AGWG invited expert
Christian VoglerProfessor and Director, Technology Access Program, Gallaudet University
James NurthenAccessibility Engineer & co-chair ARIA Working Group
Bill Denglertotally blind computer science student and code contributor to the NVDA screen reader, Swarthmore College, Philadelphia
Haben GirmaHuman Rights Lawyer
Dominic MazzoniSoftware Engineer - Chrome Accessibility, Google
Jared SmithAssociate Director, WebAIM
Ethan Marcotteweb designer, author of “Responsive Web Design”
Joschi KuphalCPWA & CEO, tollwerk
Georgios KouroupetroglouProfessor of Digital Accessibility and Assistive Technology, National and Kapodistrian University of Athens
Melanie SumnerW3C WAI-ARIA Working Group invited expert; Co-editor, Accessible Name and Description Specification
Derek RiemerFrontend web application Developer, NVDA screen reader contributor
Matt CampbellChief Technology Officer, Pneuma Solutions
Sarah HigleyAccessibility Specialist & Software Developer, Microsoft
Dr. Keith NewtonTechnical Program Manager - Accessibility, eBay
Jan McSorleyVP of Accessibility, Pearson Assessments
Jennifer StricklandSenior HCD + Accessibility Engineer at MITRE, Accessibility Consultant at Level Access
Ben TillyerHead of Digital Accessibility, University of Oxford
Charles HallInvited Expert W3C AGWG
Sina BahramPresident, Prime Access Consulting, Inc.
Alex CooperSoftware Engineer, Digital Inclusion, American Foundation for the Blind
Anna E. CookSenior Inclusive Designer, Microsoft
Carie FisherSr. Accessibility consultant, Deque
Miriam SuzanneAgency Co-Founder & W3C Invited Expert
Ashley FirthGlobal Head of Front-end Development, Octopus Energy
Steve FaulknerChief Accessibility Officer, TPGi
James ScholesDirector of Digital Accessibility, Prime Access Consulting, Inc.
Matt ObeeStaff Accessibility Designer, GitHub
Eric BaileyThe A11Y Project Maintainer
Peter QualeLead Accessibility Consultant, Target Corp.
Sylvie DuchateauWeb Accessibility Consultant, Access42
Léonie WatsonDirector, TetraLogical
Amy MasonAccess Technology Specialist, San Francisco Lighthouse for the Blind
Scott VinkleAccessibility Specialist, Shopify
Gaynor KeaneProduct Management Manager, Salesforce
Fredrik FischerCWAE, Accessibility Consultant and Project Officer at Hilfsgemeinschaft der Blinden und Sehschwachen Österreichs.
Alastair CampbellDirector of Accessibility, Nomensa
Pavel Pomerantsevweb accessibility engineer, Squarespace
Karli YeomanAccessibility Engineer, Expedia Group
Lori SamuelsAccessibility Director, NBCUniversal
Markku HakkinenDirector of Accessibility Standards & Inclusive Technology, ETS
Jen SmithDirector, Visa Accessibility
Sheri Byrne-HaberSenior accessibility evangelist
Joe YangSenior UX Designer – Accessibility, ServiceNow

Source for every name and title: the Overlay Fact Sheet, maintained by Karl Groves.

Each person’s employer is the affiliation they gave when signing.

Why they fail

An overlay is third-party JavaScript that rewrites your page in the visitor's browser. Four reasons that approach cannot reach compliance.

01

Conformance is all or nothing

WCAG conformance means every applicable success criterion is met. There is no partial credit. Vendors document that their scripts cannot repair every issue, so by their own paperwork the site does not conform.

02

The hard parts stay broken

Automated repair is unreliable for image alt text, form labels, error handling, focus control and keyboard access. It does not touch PDF, canvas, SVG or media at all, and it loses track of React, Vue and Angular views that change after load.

03

The widget is redundant

Bigger text, higher contrast and a reading mask already exist in the operating system and the browser. Anyone who needs them has them configured for every site, not just yours. The panel adds a second set of controls that fights the first.

04

It creates a GDPR problem

To auto-enable screen reader mode, an overlay has to detect that assistive technology is running. That reveals the visitor has a disability, which is sensitive personal data. Some overlays then persist it across every other site running the same script.

Regulators and courts have looked at this

None of them concluded that an overlay produces compliance.

United States
The Federal Trade Commission ordered accessiBe to pay $1 million over deceptive claims that its AI product could make any website compliant, and over undisclosed paid reviews.
Germany
BFIT-Bund, the federal and state monitoring bodies for accessible IT, published a joint assessment advising against the use of overlay tools.
European Union
The European Disability Forum and the IAAP jointly stated that overlays do not guarantee compliance with European legislation.
Courts
In Murphy v. Eyebobs, the filing stated that sole reliance on accessiBe would not be sufficient to ensure full and equal access to a website.
Advocacy
The National Federation of the Blind, the largest US organisation of blind people, banned accessiBe from its convention and sponsorship programme.
Research
WebAIM found 67% of practitioners rate overlays not at all or not very effective. Among respondents with disabilities that rose to 72%.

What actually works

Every approach below fixes the problem where it lives, in your own code and content. They are ordered by how much of the work lands on your team, least first. Most organisations combine two or three. The last row is the one this page argues against.

Approaches to web accessibility, compared. Named products are examples, not rankings. Scroll sideways to see every column.
Approach	What it does	Fixes the source	Who does the work	Best for
Continuous remediation	Scans the site, fixes the issues in your source, then re-checks after every deploy so a fix does not quietly disappear. Leaves an audit trail you can hand to a lawyer or a procurement team. HelpBob (opens in a new tab), and the remediation tiers of some audit firms	Yes	Automated, you approve changes	Most teams, and anyone shipping code weekly
Specialist audit	A person tests with real assistive technology and reports every finding by severity, with guidance on the fix. Deque (opens in a new tab), TPGi (opens in a new tab), TetraLogical (opens in a new tab), Level Access (opens in a new tab), Nomensa (opens in a new tab), Access42 (opens in a new tab), tollwerk (opens in a new tab)	Yes, you implement	External consultancy	Conformance claims, VPATs, legal exposure
Testing tools in CI	Automated checks on every build, so regressions are caught before they reach production. axe DevTools (opens in a new tab), Pa11y (opens in a new tab), Lighthouse (opens in a new tab), IBM Equal Access (opens in a new tab)	Yes, you implement	Your developers	Teams with engineering capacity
Accessible components	Build on libraries that get keyboard behaviour, focus and ARIA right by default, so most issues never appear. Radix Primitives (opens in a new tab), React Aria (opens in a new tab), GOV.UK Frontend (opens in a new tab)	Yes, at the root	Your developers	New builds and rewrites
Testing with disabled users	Paid sessions with screen reader and switch users, who find the problems no tool and no checklist will surface. Fable (opens in a new tab), Knowbility AccessWorks (opens in a new tab), Assistiv Labs (opens in a new tab)	Finds what tools miss	Paid testers, moderated	Validating a redesign before launch
Monitoring platform	Tracks issues across a large site over time and shows whether the trend is going the right way. Siteimprove (opens in a new tab), axe Monitor (opens in a new tab)	Reports only	Your team acts on the report	Large estates with many content editors
Training the team	Teaches designers, developers and editors to stop producing the issues in the first place. Deque University (opens in a new tab), WebAIM (opens in a new tab), IAAP certification (opens in a new tab)	Yes, prevents them	Your team, once	Anyone doing this more than once
Accessibility overlay	Injects a script that rewrites the rendered page in the visitor's browser and adds a settings widget.	No	The vendor, in theory	Nothing described on this page

Products are named as examples of each category, in no particular order. Inclusion is editorial and unpaid.

Two ways to go from here

Start where the work is smallest

If you ship code regularly, continuous remediation is usually the shortest path: it fixes the source, survives the next deploy, and leaves the audit trail you will be asked for. An audit on top of it covers what no tool can judge.

Compare the approaches

Get listed in the table

If you audit, remediate or build tooling that fixes accessibility at the source, you can appear above. Listing is free and editorial. There is no paid placement.

No overlay or accessibility widget, under any brand
No claims of automatic compliance with any law or standard
Fixes change the source, not just the rendered page
Scope and pricing stated openly

Request a listing

A widget is not compliance.