An accessibility overlay is a script that adds a toolbar and automatic adjustments to a site without changing its underlying code. Overlays cannot guarantee conformance with WCAG, and in April 2025 the US Federal Trade Commission finalised an order barring one vendor from claiming its tool makes sites compliant without evidence. Fixing the code is what counts.
General information, not legal advice.
What is an accessibility overlay?
An overlay is a piece of JavaScript you add to your website. It shows visitors a toolbar, for example to change text size or contrast, and tries to adjust the page automatically in the visitor’s browser. It does not change the HTML, CSS or code that your site is built from.
Why does an overlay not make a site compliant?
Standards such as WCAG and EN 301 549 describe how the content and code you publish should behave: whether a keyboard user can reach every control, whether a screen reader announces a form field with a sensible label, whether images have meaningful descriptions. Conformance is a property of that content.
Automated adjustments can change some things, but they cannot supply meaning. No script can know what a picture is for or whether a page’s headings describe its structure, and the problems that need that judgement are often the ones that matter most. Automated tools, including AccessBadger’s, find only part of what WCAG covers.
What did the US Federal Trade Commission decide?
In January 2025 the FTC announced a proposed order against accessiBe, the maker of the accessWidget overlay, and it finalised the order on 22 April 2025. The FTC alleged that the company’s claim that accessWidget “can make any website compliant with Web Content Accessibility Guidelines” was false, misleading or unsubstantiated, and that it presented third-party articles and reviews as independent opinions without disclosing its connection to them.
The order requires accessiBe to pay $1 million and bars it from claiming that its automated products can make any website WCAG compliant, or keep it compliant over time, unless it has evidence to support the claim. As is usual in settlements of this kind, the company did not admit wrongdoing, and the order binds that company only. It is a useful reminder that a vendor’s promise of compliance is not evidence of it.
How do overlays, code fixes and AccessBadger compare?
| Feature | Overlay | Fixing your code | AccessBadger |
|---|---|---|---|
| What it does | Adds a toolbar and adjusts the page in the visitor’s browser | Changes the page itself so it works for everyone | Finds issues, explains how to fix them and tracks progress |
| Changes your source code? | No | Yes | No. Your developers make the fixes |
| Can it show conformance to a standard? | Not on its own | Yes, once issues are fixed and verified by testing | No. A clean scan is evidence of effort, not proof |
| Helps you keep checking? | Varies by vendor | Only if you test regularly | Weekly scans, blocker alerts and a record of each scan |
What should I do instead?
- Scan your site to find out where it stands. The free EAA accessibility scan takes under a minute.
- Fix the issues in your code, starting with blockers. Accessibility reports give each issue a severity, the WCAG criterion and fix guidance.
- Test the key journeys by hand with a keyboard and a screen reader.
- Publish your accessibility information and give visitors a way to report problems, for example with the feedback widget.
- Keep watching. Accessibility monitoring rescans every week and emails you when new blockers appear.
For the legal background, read the European Accessibility Act compliance guide.