Do Accessibility Overlays Make a Website Compliant? What the FTC Found
Not by themselves, and the FTC has said so in one case. In April 2025 it finalized an order against accessiBe after finding that the claim its plug-in could make any website WCAG-compliant was deceptive. Here is what the order says, what an overlay can and cannot change, and where the real fixes go.
By George Shvaya · · 6 min read
An accessibility overlay is a script you add to a site, usually one line, that loads a toolbar or automated fixes in the visitor’s browser. The pitch is speed: one install instead of a remediation project. The question owners actually need answered is whether it does the job.
What the FTC order says
On April 22, 2025, the Federal Trade Commission approved a final order requiring accessiBe to pay $1 million. According to the FTC, the company had claimed its “plug-in accessWidget can make any website compliant with Web Content Accessibility Guidelines (WCAG).” The complaint alleged those WCAG claims were false, misleading or unsubstantiated, and that third-party articles and reviews were deceptively formatted to look independent without disclosing the company’s material connections to them.
The final order:
- bars representing that its automated products “can make any website WCAG-compliant” without evidence to support the claim;
- bars claiming the products can keep a site compliant over time without supporting evidence;
- bars presenting reviews, blog posts or articles as independent opinions when they are not;
- requires a $1 million payment.
Two limits on what that means. It is one order about one company’s marketing. And it does not make overlays illegal. What it establishes is narrower and still useful: a public finding that an automated plug-in’s promise of WCAG compliance for any site was deceptive.
What an overlay can and cannot change
The constraint is in how the technology works. An overlay is a script that runs in the visitor’s browser after your page loads, and it modifies the page that browser received. It does not change your source: the templates and components your developer maintains, the content stored in your CMS, the PDFs you upload, or content embedded from third parties. The next visitor gets the same source and the script runs again.
That matters because WCAG success criteria are about what you publish. Alt text that describes an image well, labels that say what a field is for, link text that makes sense out of context: these depend on knowing what the content means, which is why they are reliably fixed where the content is authored.
What actually needs fixing, and where
WebAIM’s 2026 Million report tested the top one million home pages and found detectable WCAG 2 failures on 95.9% of them, an average of 56.1 errors per page. The six most common errors are template problems with known fixes:
| Error | Share of home pages | Where the fix goes |
|---|---|---|
| Low contrast text | 83.9% | Change the color tokens in your stylesheet so text meets 4.5:1 (3:1 for large text). |
| Missing alternative text for images | 53.1% | Write alt text where the image is authored, in the CMS field or component; empty alt for decorative images. |
| Missing form input labels | 51% | Give every field a visible label element tied to it in the form component. |
| Empty links | 46.3% | Add text or an accessible name to icon-only links in the shared header, footer and card components. |
| Empty buttons | 30.6% | Give icon buttons (menus, close, search) an accessible name in the button component. |
| Missing document language | 13.5% | Set the lang attribute on the html element in the site layout, once. |
The contrast thresholds come from WCAG success criterion 1.4.3 in the W3C specification.
The same pattern shows up in our own research. When we ran axe-core on 95 California county and city homepages, links without discernible text and color contrast were the two most common failures; the full results are in our California government website accessibility study.
Running an overlay and not sure what is underneath?
Our free audit tests your source templates against WCAG 2.2 AA and shows which fixes belong in code, component by component.
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If you already have an overlay
- Run a scan with the overlay disabled to see what your source actually ships. Our accessibility checker reads the HTML your server returns.
- Fix the shared components first: colors, form fields, buttons, header and footer links.
- Test with a keyboard and a screen reader to confirm the widget does not get in the way.
- Work through the WCAG 2.2 checklist for the criteria scanners cannot judge.
- Decide afterwards whether the widget still adds anything for your visitors.
Frequently asked questions
What did the FTC decide about accessiBe?
On April 22, 2025 the FTC approved a final order requiring accessiBe to pay $1 million. The order bars the company from claiming its automated products can make any website WCAG-compliant, or keep a site compliant over time, without evidence, and from presenting paid reviews or articles as independent.
Are accessibility overlays illegal?
No. The FTC order concerned specific marketing claims, namely that a plug-in could make any website WCAG-compliant, and undisclosed paid reviews. It did not ban overlays. The practical point is that an automated plug-in claim of guaranteed WCAG compliance was found deceptive.
Can I keep an overlay while I fix my site?
You can, but treat it as optional and fix the source anyway. Missing alt text, unlabeled fields, low contrast and empty links live in your templates and content, and the reliable fix is in those templates. Test that any widget does not interfere with screen readers or keyboard use.
What should I fix first?
The most common failures WebAIM found in 2026: low contrast text, missing alternative text, missing form labels, empty links, empty buttons and missing document language. They are usually caused by a few shared components, so fixing those components fixes most pages.
About the work
Webvello is a web development and AI search company founded in 2024, based in Roseville, California, with 50+ projects across 37+ cities. Our accessibility audits and remediation fix issues in the code and content where they start, and our builds ship with accessibility in the components from day one.
This page is general information, not legal advice. Sources are linked in each section and were checked on October 17, 2026.
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