Does an accessibility overlay make my website ADA compliant?

No. Where the ADA rules name a technical standard for web content it is WCAG, and an overlay leaves your site’s own code unchanged. It can adjust how a page looks for a visitor and inject guesses at runtime; it cannot evaluate or repair the majority of WCAG criteria, which need a person to judge.

Why did the FTC order accessiBe to pay $1 million?

The FTC alleged that accessiBe claimed its accessWidget could make any website WCAG-compliant, that the claim was false, misleading or unsubstantiated, and that it presented paid reviews as independent. The final order, approved April 22, 2025, requires a $1 million payment and bars the company from making the compliance claim without evidence to support it.

Will procurement accept an overlay as our VPAT?

Generally not. A VPAT/ACR is a per-criterion evaluation of the product, attributed to whoever signed it. An overlay is a script installed on the page, and installing one says nothing about how the page’s own code performs against each criterion.

What should we do if we already have an overlay installed?

Have the site audited by hand. The audit reports the state of your own code, which is what a complaint, a customer or a reviewer looks at, and it tells you plainly what the widget is and is not covering. Then fix the code and document the work.

Do screen reader users want an overlay?

Screen reader and magnification users already run assistive technology with its own settings, and a script that changes the page under them can conflict with it, which is why overlays draw so much criticism from the people they are sold as helping. A visitor-side display preference that changes nothing in the page’s structure is a different thing from a script that rewrites it.

Do Accessibility Overlays Make a Website ADA Compliant?

By Andrew Szigety, DHS Trusted Tester (TT‑2606‑09221). Published September 6, 2026.

An overlay does not make a website conform to WCAG, the technical standard the ADA rules point to where they name one. It is a script that adds a settings panel and tries to patch the page in the visitor’s browser, and it leaves the site’s own code exactly as it was. In April 2025 the Federal Trade Commission finalized an order requiring accessiBe to pay $1 million over the claim that its widget could make any website WCAG-compliant, and the order bars the company from repeating that claim without evidence. A procurement team asking for a conformance report generally does not accept an installed widget as one.

Key Takeaway

An overlay is not remediation and it is not evidence. Your accessibility position is the state of your own code and the documents that describe it: an audit, a remediation plan, and a conformance report.

What an Overlay Actually Does

Most overlay products have two parts. The first is a panel visitors can open to change contrast, text size, spacing, cursor size, or to pause animation. The second, in most products, is an automated layer that scans the page as it loads and injects guesses: alt text generated from the image, ARIA labels on unlabeled controls, a re-ordered tab sequence, a “screen reader mode.” Both run in the visitor’s browser after the page arrives. Neither changes the HTML your server sends, the templates your developers maintain, or the documents linked from the page.

What It Cannot Do

Decide most of the standard. Of the 55 WCAG 2.2 A and AA success criteria, an automated tool can return a reliable pass or fail on about six. Whether alt text describes the image, whether the reading order makes sense, whether an error message tells the user what to do, whether a custom component works from the keyboard: each is a judgment, and a script that cannot make the judgment cannot fix the failure.
Guess safely. Injected alt text that says “image” or misidentifies a product, and ARIA that contradicts the page’s own markup, are new failures rather than repairs. Screen reader users already run software with its own settings, and a script that rewrites the page under them can conflict with it.
Produce the document. An overlay yields no ACR, no remediation plan and no record of what was tested. Those are the three things a buyer, a complaint or a reviewer asks for.
Reach what is not on the page. PDFs, native apps, third-party embeds and video captions sit outside the script’s reach.

6 of 55

WCAG 2.2 A and AA criteria an automated tool can decide on its own

What the FTC Said

In January 2025 the Federal Trade Commission announced a proposed order against accessiBe over the marketing of its accessWidget product, and on April 22, 2025 it approved the order as final. The complaint alleged that the company claimed the widget could make any website WCAG-compliant, that the claim was false, misleading or unsubstantiated, and that it formatted paid reviews to look independent. The order requires a $1 million payment and bars accessiBe from representing that its automated products can make any website WCAG-compliant, or keep it compliant over time, unless it has evidence to support the claim. The order is specific to one company. The reasoning applies to the category.

What Buyers and Reviewers Accept Instead

A current conformance report from an evaluation that names its method and its evaluator, with Partially Supports rows and specific remarks rather than a column of unexamined Supports.
A remediation plan and evidence of progress: findings organized by fix location, and re-tests showing what now passes.
An accessibility statement with a way for people to report a barrier and get a response.

For vendors selling to state and local government, the Title II rule makes this concrete: contracted content is the entity’s own, and the entity has to be able to show it meets WCAG 2.1 AA. A widget on the login page does not show that.

Is There Any Legitimate Use?

A display-preferences panel that lets a visitor raise contrast or enlarge text, stores the choice in their own browser, and changes nothing in the page’s structure is a convenience some readers like. Described as a convenience, it is harmless. The problems begin with the second half of most products, the automatic rewriting, and with the claim that either half amounts to compliance. If a vendor’s pitch includes the word “compliant,” that is the sentence to ask for evidence of.

Where Harbor Fits

Harbor performs the manual audit: every unique template, by hand, with a keyboard and a screen reader, against all 55 criteria. What comes back is a remediation plan your developers work from, follow-up reviews as fixes land, and a signed VPAT/ACR from a named evaluator. If you have an overlay installed, the audit will say plainly what it is and is not covering, and the report describes your own code with the widget out of the picture. Overlays are absent from Harbor’s named comparison of audit providers for the same reason: they are a different product.

Common Questions

Does an accessibility overlay make my website ADA compliant?: No. Where the ADA rules name a technical standard for web content it is WCAG, and an overlay leaves your site’s own code unchanged. It can adjust how a page looks for a visitor and inject guesses at runtime; it cannot evaluate or repair the majority of WCAG criteria, which need a person to judge.
Why did the FTC order accessiBe to pay $1 million?: The FTC alleged that accessiBe claimed its accessWidget could make any website WCAG-compliant, that the claim was false, misleading or unsubstantiated, and that it presented paid reviews as independent. The final order, approved April 22, 2025, requires a $1 million payment and bars the company from making the compliance claim without evidence to support it.
Will procurement accept an overlay as our VPAT?: Generally not. A VPAT/ACR is a per-criterion evaluation of the product, attributed to whoever signed it. An overlay is a script installed on the page, and installing one says nothing about how the page’s own code performs against each criterion.
What should we do if we already have an overlay installed?: Have the site audited by hand. The audit reports the state of your own code, which is what a complaint, a customer or a reviewer looks at, and it tells you plainly what the widget is and is not covering. Then fix the code and document the work.
Do screen reader users want an overlay?: Screen reader and magnification users already run assistive technology with its own settings, and a script that changes the page under them can conflict with it, which is why overlays draw so much criticism from the people they are sold as helping. A visitor-side display preference that changes nothing in the page’s structure is a different thing from a script that rewrites it.