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Home » The Risk of Overlay Accessibility Tools: Why True Compliance Matters

The Risk of Overlay Accessibility Tools: Why True Compliance Matters

on June 24, 2025 at 2:35pm |Updated on June 24, 2025 at 4:14pm European Accessibility Act, Overlays Do Not Deliver Compliance, Enforcement date 28 June 2025, EU Logo, Access by Design logo

As the European Accessibility Act (EAA) deadline approaches, many businesses are scrambling for fast fixes. Some accessibility tools have been marketed as a simple, one-click solution to achieve compliance. However, these tools often create more problems than they solve. In reality, true compliance requires a much deeper and more effective approach.

What Are Overlay Accessibility Tools?

Overlay accessibility tools are software plugins or scripts that attempt to retrofit accessibility features onto a website. They often include elements like text resizing, colour contrast adjustments, and screen reader toggles. These tools are marketed as instant fixes, but they do not address the actual code or structure of a website.

The danger is that many business owners are misled into thinking their site is compliant when it is not. The European Accessibility Act does not recognise overlays as a valid path to compliance. Relying on them can leave you vulnerable to complaints, legal action, and reputational damage.

Why Overlays Fall Short

The core issue is that overlays sit on top of existing content without fixing the underlying problems. A screen reader user, for example, will still encounter unlabelled buttons, missing alt text, keyboard traps, and inaccessible forms. These are structural issues that overlays cannot repair.

Compliance means getting things right at the foundation. If a form is not labelled correctly, or a menu cannot be navigated with a keyboard, no overlay will fix that. These are things that have to be coded correctly and tested properly. Relying on surface-level accessibility tools only gives a false sense of security.

In many cases, overlays actually interfere with assistive technology. There have been numerous complaints from disabled users who found these tools actively made the website harder to use. So not only are they ineffective, they can make things worse.

The Path to Real Compliance

Achieving compliance involves a structured approach:

  • Accessibility audit: A comprehensive review of your website against WCAG guidelines
  • User testing: Involving disabled testers to explore real-world usability barriers
  • Fixing the code: Addressing issues like poor heading structure, ARIA misuse, contrast failures, and inaccessible navigation
  • Accessibility statement: Publishing a legally valid statement that outlines known issues and your roadmap to full compliance

This process takes time and expertise, but it leads to genuine improvements. Not just for legal compliance, but for all your users. A properly coded website loads faster, performs better in search results, and provides a smoother experience for everyone.

The Consequences of Shortcut Solutions

Some companies have learned this lesson the hard way. There have been multiple cases where organisations using overlays were still sued under accessibility legislation. When real users could not access the content, the existence of an overlay was not accepted as a defence.

Legal frameworks around the world, including the European Accessibility Act and the Americans with Disabilities Act, are increasingly focused on real-world usability. If your website cannot be used by a blind person with a screen reader, or a motor-impaired user navigating by keyboard, you are at risk. Accessibility tools alone will not protect you from that liability.

In fact, using the wrong tools may be worse than doing nothing. It shows you are aware of accessibility but have chosen a non-compliant solution. That increases your exposure rather than reducing it.

What Real Compliance Looks Like

We often hear from businesses who have installed overlays, received poor results, and now want to do things properly. The good news is that it is never too late to start. We work with companies of all sizes to rebuild trust and create websites that work for everyone.

Our approach is based on lived experience. Our testers include screen reader users, people with cognitive impairments, and others who rely on accessible websites every day. When they test your site, they are not looking at it through a checklist. They are using it as a real person would — and that is where true compliance begins.

We then follow up with a technical audit, detailed recommendations, and support throughout the process. We also create a compliant accessibility statement that outlines your progress, making it clear to regulators that you are taking the right steps.

Start With a Real Assessment

If you are not sure whether your site is compliant, we are happy to help. We can run a quick scan and tell you honestly where you stand. From there, we can guide you towards full compliance without relying on accessibility tools that do not deliver.

The deadline for the European Accessibility Act is almost here. There is still time to act — but only if you take the right steps now.

Choose real compliance. Choose inclusion. Choose to do it properly.