The day before Global Accessibility Awareness Day in May 2023, the European Disability Forum (EDF) and the International Association of Accessibility Professionals (IAAP) issued a joint statement regarding accessibility overlays.
The statement is aimed at people involved with the web – whether as a website owner, designer, or developer – who are not familiar with digital accessibility, to help them understand the limitations of accessibility overlays.
There are two broad types of overlay solutions in this field:
- Those which offer additional tools for website users, such as text-to-speech, screen magnification and colour adaptations.
- Those which try to automatically ‘repair’ accessibility problems directly on a website when it is used.
While they may seem like good ideas, the joint statement highlights some significant problems with accessibility overlays:
- The additional tools offered by overlays already exist in modern browsers and operating systems. At best, they duplicate functionality that is already available to users; at worst they override a user’s preferred device and browser setup.
- AI-powered accessibility fixes are not always reliable and can interfere with assistive technology.
- There are privacy concerns surrounding overlays which automatically detect the use of assistive technology on a user’s device, if there is no way of opting out of that tracking.
Perhaps the key takeaway from the statement is that overlays do not make a website accessible or compliant with European accessibility legislation.
It’s vital that this message reaches those people working in digital who are not well versed in digital accessibility. I have looked at the marketing websites for some of the ‘big players’, and they clearly mention EAA/EN301549 compliance and WCAG compliance.
Yet, here is an independent, pan-European non-governmental organisation, defending the interests of millions upon millions of persons with disabilities, making it clear that accessibility overlays don’t guarantee compliance with European legislation. It’s worth noting that the EDF was a key consultant on the formulation of the European Accessibility Act.
There is no quick fix, accessibility cure-all. In my opinion, well-intentioned people risk being misled into purchasing a SaaS subscription that will not live up to its promises. So what should they do instead?
- Use a free tool such as Lighthouse or axe DevTools, or follow these easy checks from W3C’s Web Accessibility Initiative, to get a sense of how well your website scores for accessibility.
- Reach out to people with disabilities and ask how easy or hard it is for them to use your website – making sure to recompense them for their time and effort.
- If you are comfortable with making technical adjustments to your website, make the recommended changes, then re-check to see how things are progressing.
- Otherwise, take your findings and engage with a digital accessibility expert to help you with an actionable remediation plan.
Update: in December 2023, the European Commission also released guidance on accessibility overlays. They emphasised: “Claims that a website can be made fully compliant without manual intervention are not realistic, since no automated tool can cover all the WCAG 2.1 level A and AA criteria.”