The Skinny on Accessibility Overlays – Colorado Virtual Library

“Web accessibility, (…) is the inclusive practice of ensuring there are no barriers that prevent interaction with, or access to, websites on the World Wide Web by people with physical disabilities, situational disabilities, and socio-economic restrictions on bandwidth and speed. When sites are correctly designed, developed and edited, more users have equal access to information and functionality.” Wikipedia

With the introduction later this year of mandatory web accessibility compliance for all state and local governments, special districts, and any other instrumentality of state or local government and technology, many organizations are scrambling to make their websites accessible and compliant with WCAG 2.1 AA Content Accessibility Guidelines. As many of us are discovering, making existing web content accessible is hard but important work, and maintaining that level of commitment going forward continues to be hard and important work. With so much effort and resources being required to make the necessary work happen, some organizations might be tempted to consider an easy fix for the short or long term. One of the technology solutions out there is the use of an accessibility overlay that sits on top of your website, applying a script to the page which scans your code and automatically attempts to repair accessibility problems. But what is really happening behind the scenes, and is this the right choice? Will it actually be more harmful than helpful?

What is an Accessibility Overlay?

Overlays are a broad term for technologies that aim to improve the accessibility of a website. They are third-party tools, plugins, or widgets that apply third party source code – usually Java Script – to make improvements to the front end code of the website. They can momentarily address issues like color contrast, font style and size, text to voice, magnification, and other similar adjustments, and many claim that they are fully WCAG 2.1 AA compliant and will prevent ADA discrimination lawsuits. However, this does not play out in reality, and they often lead to significant barriers for the users they are claiming to help.

These tools use automated checkers to scan the webpage for items it finds are inaccessible and then generate alternative code that sits “on top” of the page. What’s important to know is that the overlay does not fix the problematic code on the page, instead, it creates a separate version of the code, masking the issue. Overlays can’t fix structural problems underneath your website. That’s why overlays aren’t a suitable replacement for doing accessibility work.

While many overlay providers promise quick fixes and that their products make websites more accessible, they actually often make sites harder to access for individuals who use assistive technology. In a 2021 WebAIM survey, 67% of respondents rated overlays, plugins, and widgets for accessibility as not effective. This increases to 72% within the group of respondents who have a disability. Not only are overlays deemed not effective, the A11Y Project describes overlays as “actively harmful, and a step backwards for digital accessibility efforts” (2021).

While the outward intent is to make sites more accessible, overlays are also promoted to protect businesses and companies from lawsuits. However, according to usablenet.com, in 2023 933 businesses with an accessibility widget or overlay on their website received a lawsuit. This is up by 62% from the 575 lawsuits relating to overlays in 2022.

What’s Wrong with Overlays?

Before looking at some technical issues with overlays, it is important to remember that most people who have a disability that keeps them from interacting with web resources in the standard way, already use assistive technology enabling them to do so. That is if a site is coded and designed with accessibility in mind. Many assistive accessibility features come standard with most operating systems these days and provide the ability to narrate what is on the screen, adjust color and size of fonts, use color filters to change contrast, and customize the keyboard to better suit the user’s individual needs. And for users with more specific needs, there are screen readers and other additional assistive technologies that can be used, providing access to all they do, whether it be on the web or using a software application. Adding an overlay to a website that is designed to do these modifications is redundant and often obstructive to users of assistive technology tools. Many individuals who use assistive technology find that overlays require atypical use of their technology or stop their technology from working. For example, masking or hiding content, which removes important context for understanding.

According to ShouldIUseAnAccessibilityOverlay.com, overlays and widgets aimed at making websites accessible actually make things worse. Overlays do not address access issues, such as missing or insufficient alternative text, non-descriptive link text, such as, “click here,” and lack of captions for videos or audio. Like many automated accessibility tools, these are accessibility practices that cannot be fixed without a human developer. Another important thing to realize is that covering up the inaccessibility issues within a website is not doing anyone any favors. It does not protect the site owner from litigation, it does not provide legally required accessibility practices and coding for the web resources, and it does not actually assist anyone who genuinely needs assistance in the way they need it. Some basic issues with using an overlay include:

Automated applications of text alternatives for images is not reliable.
Automated repair of field labels, error management, error handling, and focus control on forms is not reliable.
Repairs to the page can slow down the page load time or cause unexpected page changes for assistive technology users.
Do not repair content in Flash, Java, Silverlight, PDF, HTML 5, Canvas, SVG, or media files.
Full WCAG compliance cannot be achieved with an overlay.

By using overlays, a site owner is offering people with disabilities a different web experience with reduced functionality, which is in direct contradiction to the goals of digital inclusion.

What To Do Instead?

Accessibility on the web is a huge challenge for folks on both sides of the issue (content creators and content consumers), and there is no such thing as a one and done or a quick fix. It takes time, effort, and commitment to make our web world accessible, and as the technology changes (which it does rapidly), it feels like the goal posts keep moving. The best thing for any site owner to do is to make the necessary changes to policies and practices for their web presence, put effort into mitigating and correcting the inaccessible aspects of their site code, and learn more about the needs and experiences of the users that are consuming their content. In other words, listen to all members of the community you are aiming to serve.

What if all of the necessary compliance remediation work is not completed before the July 1, 2024 deadline? Many website owners will be in this situation come July 1, and let’s face it, perfection in compliance is really hard, if not impossible to achieve. That is why there are tools in place to help site owners remain compliant while the accessibility work is being completed. Every institution needs to have an up to date and transparent Accessibility Statement on their website that identifies where they are in their accessibility journey, and provides the necessary contact information for anyone who encounters barriers to the resources or information they are seeking. It is also helpful to have a strong and supportable accommodation plan or Equally Effective Alternative Access Plan (EEAAP) that clearly outlines the steps to be taken to provide the same information and services offered by a technology that is not accessible. The EEAAP does not need to be publicly posted, but it needs to be present so that all in the organization are aware of the accommodation steps outlined in it and are ready to make them happen when required. The idea is to keep all users engaged in the process and able to consume the resources they need, while the self help/self serve option is being made compliant.

To gain a better feel for the different needs of the communities that your organization serves, check out the Overlay Fact Sheet website. Here you will find a compilation of personal accounts of people who make use of assistive technology, and their experiences with overlays. There are other available resources on the web to help you better understand the challenges of the disabled community, providing greater insight into what members are experiencing now, and how to improve that experience going forward. The W3C website is a great place to start. Working with assistive technology or with someone who utilizes assistive technology can help you create an accessible web experience for all users.

The most important thing you can do is to include accessible design in everything you do going forward. It is the right and best thing to do.