What is an accessibility overlay?
An overlay is third-party JavaScript that runs on top of a site's own code. Vendors describe two kinds of function, often in one product:
- A preferences toolbar. A button opens a panel where visitors can change text size, contrast, spacing, cursor size, or turn on reading aids. accessiBe describes "session-based UI modifications" [1]; UserWay describes "user personalization" with "100+ user personalization tools" [2].
- Automatic remediation. In general terms, this means a script that scans the page and changes it at runtime, for example adding ARIA attributes or alternative text, so assistive technology is given different information than the site's own code provides. In vendors' own words: accessiBe describes "ongoing scans & fixes every 24 hrs" [1]; UserWay describes "Automated Remediation Technology" that can "automatically and continuously fix many common accessibility issues directly within your website or application in real time, with in-platform insight on applied remediations, supported by human-in-the-loop oversight" [2].
AudioEye's Automated plan lists "Automated Fixes" and "Automated tools addressing ~50% accessibility issues" [3]. Its pricing page doesn't say how those fixes are delivered; ask AudioEye directly.
Many overlay plans also bundle monitoring, manual audits, VPAT documents or litigation-support services. Those are separate offerings and are worth evaluating on their own terms.
What overlays can't do
The European Disability Forum (EDF) and the International Association of Accessibility Professionals (IAAP) set out the limits in a 2023 joint statement [4]. In summary:
- Most toolbar features duplicate what people already have. The statement says most overlay functionality copies features "that already exist in today's browsers and operating systems" [4]. People who rely on zoom, high contrast or a screen reader have usually configured them already.
- Runtime repair isn't reliable and can interfere. The statement describes automatic repair as "not always reliable" and says overlay technology "can interfere with the user's assistive technology and override user settings" [4].
- They don't make a site compliant. The statement's view is that overlays "do not make the website accessible or compliant with European accessibility legislation" and aren't a substitute for fixing the site [4].
- Some detect assistive technology. The statement notes that some overlays detect when assistive technology is running, which it flags as a privacy concern where there's no way to opt out, because assistive-technology use is often linked to disability [4].
The Overlay Fact Sheet, a statement signed by accessibility practitioners, specification contributors and users with disabilities, asks site owners to remediate issues "at the source of the original error" rather than rely on overlays [5].
There's also a structural limit that applies to any automation, overlays included. Many WCAG success criteria need human judgment: whether alt text describes an image, whether a heading is meaningful, whether a task can actually be completed. Our WCAG 2.2 checklist shows which criteria automated rules can address, and even those only partly.
The FTC order against accessiBe
In January 2025, the FTC announced a complaint and proposed consent order against accessiBe. The complaint alleged that accessiBe misrepresented that its AI-powered tool, accessWidget, could make any website compliant with WCAG, and that it formatted third-party articles and reviews to appear independent without disclosing its material connections [6].
On April 22, 2025, the Commission approved the final order by a 3–0 vote. Per the FTC, it requires accessiBe to pay $1 million and bars it from representing that its automated products can make any website WCAG-compliant, or ensure continued compliance over time, unless it has the evidence to support such claims. It also prohibits misrepresenting that reviews or endorsers are independent [7][8].
What this does and doesn't mean:
- It's a consent order settling the FTC's allegations about marketing claims. It's not a technical evaluation of every overlay product.
- It applies to accessiBe. Other vendors weren't parties.
- Its central point applies to any vendor, us included: a claim that software makes a site WCAG-compliant needs evidence.
Why "fix it in the code" is the standard advice
Accessibility that lives in your own HTML, CSS and JavaScript:
- works for every visitor with the assistive technology and settings they already use, without a toolbar;
- doesn't depend on a third-party script loading correctly on each visit;
- stays fixed if you change vendors.
That's why accessibility organizations point owners to remediation at the source [4][5]. The hard part has never been the fix itself. It's knowing what to fix and whether it worked.
The evidence-first alternative
Testing gives you that evidence. A practical program has three layers, each answering a different question (we explain them in depth in the three layers of accessibility testing):
| Layer | Answers | Tools |
|---|---|---|
| Automated scanning | Which detectable rules does each page break? | Free: axe DevTools extension, WAVE, Lighthouse. Platforms: many, including Accessible |
| Task testing | Can someone using a keyboard or screen reader actually finish sign-in, search, checkout? | Manual testing with NVDA, JAWS, VoiceOver (how to); simulated journeys such as Accessible's |
| Real-user monitoring | Which barriers did real visitors actually meet, on which pages, how often? | Accessible's monitoring (free on one domain) |
Then fix in code, re-test, and keep the dated record of what you tested, found and fixed. If anyone asks, that record is what you can show. It's evidence of the work, not a guarantee of compliance.
Moving off an overlay? Test with it turned off. Otherwise your results describe the overlay's runtime changes, not your code. Start with your highest-value task, fix what blocks it, and work outward.
Sources
- accessWidget Pricing (opens in a new tab). accessiBe. Accessed October 18, 2026.
- UserWay Pricing (opens in a new tab). UserWay. Accessed October 18, 2026.
- Plans & Pricing (opens in a new tab). AudioEye. Accessed October 18, 2026.
- European Disability Forum and International Association of Accessibility Professionals joint statement on accessibility overlays (opens in a new tab). EDF, May 17, 2023.
- Overlay Fact Sheet (opens in a new tab). Accessed October 18, 2026.
- FTC Order Requires Online Marketer to Pay $1 Million for Deceptive Claims that its AI Product Could Make Websites Compliant with Accessibility Guidelines (opens in a new tab). Federal Trade Commission, January 3, 2025.
- FTC Approves Final Order Requiring accessiBe to pay $1 Million (opens in a new tab). Federal Trade Commission, April 22, 2025.
- In the Matter of accessiBe Inc., Decision and Order (PDF) (opens in a new tab). Federal Trade Commission, File No. 222-3156.