What the European Commission says
On its web accessibility page, last updated on 23 June 2026, the European Commission writes that overlays and other tools that do not make the website itself meet the criteria of the standard (EN 301 549 V3.2.1) are not an appropriate solution. Its advice is to fix problems at the source and to involve people with disabilities in testing.
Why disability organisations are cautious
In a joint statement of 17 May 2023, the European Disability Forum and the International Association of Accessibility Professionals list the reasons: an overlay cannot repair an inaccessible site, it can interfere with the screen reader or the settings a person already uses, it repeats functions that browsers and operating systems offer anyway, and it may reveal that a visitor has a disability. The responsibility stays with the site owner.
The accessiBe case in the United States
In January 2025 the US Federal Trade Commission announced an order against accessiBe, the maker of the accessWidget overlay. According to the FTC, the company claimed its product could make any website compliant with WCAG without evidence, and presented articles and reviews as independent opinions without disclosing its ties to their authors. The final order, approved on 22 April 2025, requires a payment of USD 1 million and forbids such claims without supporting evidence.
Does any law require a widget?
We read the European Accessibility Act (Directive 2019/882) and the provisions of the national laws that implement it in Slovenia, Germany, Spain, France and Italy that deal with services, information duties and supervision. None of them requires an overlay or a toolbar. What they require is that the service itself is perceivable, operable, understandable and robust, and that the terms and conditions explain how it meets the requirements.
Germany's act describes how the authorities check a service: with a technology-neutral method that looks at how the service actually works: the whole path in the usual order, forms, error messages and behaviour with assistive technologies.
What to do with an existing widget
- Do not count it towards conformity, and do not say on the site that it makes the site accessible.
- Test the main task with a screen reader once with the widget on and once off. If it gets in the way, remove it.
- Fix the problems in the code: alternative text, labels, contrast, keyboard access, focus order.
- Mention the widget in the accessibility statement only as an extra, never as the solution.
Sitequiry recognises twelve common overlay products by their script and generic toolbar buttons by their label, and reports them as information. A widget never changes the result of any WCAG criterion in our report.
Frequently asked questions
Does an overlay protect me from fines?
No law we checked accepts a widget instead of an accessible service. Authorities test the service itself.
Is every accessibility button bad?
A button that only offers settings, without claiming to fix the site, can be a convenience. It must not block the keyboard or a screen reader, and the site has to be accessible without it.
Who signed the Overlay Fact Sheet?
It is a community statement by accessibility practitioners, not an official document. When we opened it on 21 October 2026 it listed 1,048 signatories.
Sources
- European Commission: Web accessibility (section "Accessibility overlays"), updated 23 Jun 2026
- European Disability Forum and IAAP: Joint statement on accessibility overlays (17 May 2023)
- US FTC: Order requires online marketer to pay $1 million (3 Jan 2025)
- US FTC: FTC approves final order requiring accessiBe to pay $1 million (22 Apr 2025)
- Overlay Fact Sheet (community statement)
- Directive (EU) 2019/882 (European Accessibility Act)
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