Accessibility Overlays Barrier-free with one click?
A few months ago, we commented in a blog article on the Accessibility Enhancement Act, which came into force at the beginning of June 2025. As is often the case with compliance legislation, players are now emerging everywhere who want to capitalize on the uncertainty created by this change. In this article, we would like to draw attention to a scam that we ourselves have observed in various places recently.
At the end of May, the annual re:publica conference took place in Berlin, where we were represented by a small delegation of visitors. In addition to numerous presentations that focused primarily on the shift to the right in society and the topic of artificial intelligence, I was personally interested in a presentation that shed light on the changes brought about by the Accessibility Enhancement Act. We are naturally interested in how other service providers in the NGO environment assess the issue. Do our assessments coincide with those of others?
However, the thrust of this presentation was different. At the beginning, the audience was warned in no uncertain terms about who is now at risk of being prosecuted for lack of accessibility. This was followed by a rather vague, personal reference to the topic (“the brother of a friend of an acquaintance has a walking disability, which opened my eyes”) and then a product was presented as the solution. So instead of information, we got a marketing presentation. Colleagues who recently attended the TYPO3 Camp in central Germany also reported on a presentation with a similar structure that took the same approach.
What exactly is it about?
Many public institutions were already required to ensure accessibility under the Barrier-Free Information Technology Ordinance (BITV). The new law now obliges additional providers to make their websites accessible. This includes paid services such as online shops, but donation functions, paid material orders, and event registrations could also be affected. If accessibility requirements are not met, there is a risk of warnings being issued – which is expensive and damages reputation. So far, so plausible.
So what can you do to protect yourself? Isn't there a way to make your own website accessible? And as cost-effectively as possible?
“Of course,” reply resourceful companies that have recognized this issue as a business opportunity. “We offer you an accessibility widget that you can integrate into any website in just a few simple steps.”
At first glance, the functions of these widgets don't sound too bad. With a single click, website visitors can open a menu that provides numerous accessibility adjustments. Font sizes can be adjusted, contrasts or spacing increased, or animations deactivated. Depending on the version, the tool is even advertised as being able to scan the website for problems or supplement missing alternative texts with AI. All this is available for a small subscription fee. The fact that there is no guarantee that the site will become accessible as a result is only mentioned in passing. But at least we've come a long way, right?
What's wrong with that?
However, these promotional events, disguised as informational presentations, fail to mention the term by which such tools are known in relevant circles: ‘accessibility overlays’. The fact that the term is not mentioned is certainly not because it inadequately describes the function. Rather, I have the impression that the interested audience is being denied information about where they can find out more about this topic – independently of a provider with financial interests. In any case, the statement in the above-mentioned re:publica presentation (‘there is only one other provider for what we do, but they are based in the USA’) is not true.
If you enter ‘accessibility overlay’ in a search engine of your choice, you will quickly find pages that deal with these tools from the perspective of people with disabilities. Examples include the German Association for the Blind and Visually Impaired, the Federal Monitoring Agency for Accessibility in Information Technology, and the Overlay Factsheet website, which has been endorsed by numerous international UX and accessibility professionals. What they all have in common is that they are highly critical of the concept. Their reasons can be summarised in three main points:
1. Accessibility must be considered from the outset of a project.
The requirements for accessibility are much more complex than overlays suggest. It's not just a matter of a few better contrasts or spacing. If you take a closer look at the catalogue of test steps for a BITV test, you will quickly realise that such widgets only cover a handful of them at best.
To name just a few of the other points: consistent navigation structures, understandable wording, semantic HTML markup, accessible form labels and error messages, keyboard operability – none of these can be corrected retrospectively by a widget.
Fonts, contrasts and spacing are also the lowest hanging fruits of accessibility. At best, an overlay widget simplifies the least complex part of the adjustments. However, a website that is otherwise inaccessible will remain so even after integrating a widget.
We can guarantee that.
2. Overlays do not add any functions that are not already mapped elsewhere.
Those who require high contrast, specific colour schemes or larger font sizes can adjust all these settings in their own browser – and do so in such a way that they apply equally to all websites (not just those that have a specific widget integrated). BITV test step 11.7 explicitly checks that colours and fonts specified by users are not overridden by the website. People usually already have a read-aloud function installed – or use the voice output that many operating systems now provide.
The target audience for these widgets therefore does not seem to be those affected, but rather uncertain website operators who otherwise have little contact with the topic of accessibility.
3. Accessibility – Widgets create new barriers
In principle, no website is obliged to provide additional accessibility features. However, if such features are integrated, it is essential that they themselves are accessible (see test step 5.2). Depending on how they are integrated, overlay tools may cause new problems on the website instead of removing barriers.
There are other points that speak against the use of such tools. For example, we have not yet mentioned data protection. Since such overlays are delivered via the servers of the respective providers, they can record who has visited which page and how often. Incidentally, this already applies to the integration; as a user, I do not even have to have activated the overlay for this to happen.
Conclusion
So our recommendation is: stay away from accessibility overlays. I call this digital indulgences: becoming accessible for just a few pounds a month sounds too good to be true, and it is. We can only hope that those listening to such presentations realise this and remain sceptical.
Instead of supposed one-click solutions, we support our customers in achieving real improvements in the accessibility of their online presence. Feel free to contact us for more information.