Are accessibility overlay widgets EAA compliant?
In short: No overlay can guarantee EAA compliance. The EAA and EN 301 549 expect the service itself to be accessible, measured against WCAG 2.1 AA. Overlays run a script on top of the page but leave the underlying HTML, CSS and ARIA unchanged, so the barriers in your code remain. Compliance comes from fixing the source.
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What an overlay does
An overlay is a third-party JavaScript snippet that adjusts the page in the visitor's browser — adding ARIA attributes, guessing alt text or offering a toolbar for contrast and font size. It runs after your page loads and does not change the code you ship.
Why that falls short
- Automated repair cannot know what an image, form or custom control means, so generated fixes are often wrong or incomplete.
- People who use assistive technology usually have their own settings already; an extra toolbar does not fix missing labels or keyboard traps.
- If the script fails to load, the page is back to its inaccessible state.
- In January 2025 the US FTC reached a $1 million settlement with accessiBe over claims that its overlay made websites compliant.
What to do instead
Scan your pages to find code-level issues, fix them in your templates and components, and cover what automation cannot see with manual keyboard and screen-reader testing. The result persists and can be described honestly in your accessibility statement.
Official sources
- ETSI — EN 301 549 V3.2.1 (PDF)
- W3C — Web Content Accessibility Guidelines (WCAG) 2.1
- Directive (EU) 2019/882 — European Accessibility Act (EUR-Lex)
See where your site stands
Our free automated scan checks your page against machine-testable WCAG 2.1 AA rules in about 20 seconds — no signup, no overlay.
Scan your site free →Can I keep an overlay while I fix my code?
Is NormHarbor an overlay?
General information, not legal advice. National transposition laws differ — consult a lawyer for a binding assessment of your business.
Related on NormHarbor: Overlay vs. code fix · Do accessibility overlays make you compliant? · accessiBe alternative · Free website scan
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