The post-overlay buyer's guide

In April 2025, the FTC fined accessiBe $1 million for misleading accessibility compliance claims.

In the first half of 2025, 22.6% of US web accessibility lawsuits targeted sites that had an overlay widget installed.

If you are paying for an accessibility overlay, you are paying for something that probably does not work, and that statistically makes you a more attractive target for litigation, not less.

This is a guide for the marketer, compliance officer, or business owner who installed an overlay because someone told them it would solve accessibility, and is now not sure what to do.

The short version: switch the overlay off, do an honest scan, fix what you can, get a manual audit if you need one, and monitor it from there.

What overlays actually are

An accessibility overlay is a JavaScript widget you paste onto your site. It usually shows a small button in the bottom corner. Click it and a panel opens with toggles: increase font size, change contrast, "screen reader friendly mode," "epilepsy safe."

Overlay vendors sell these as compliance tools. The pitch is: paste this snippet, your site becomes WCAG-compliant. Some vendors even offer "lawsuit protection" or "compliance guarantees."

The reality is different.

What overlays don't do

An overlay can't change your site's underlying HTML. It can paint over the surface (change colours, adjust font sizes, add a contrast toggle), but it can't:

• - Add proper alt text where you didn't write any
• - Restructure broken heading hierarchies
• - Add labels to unlabelled form fields in a way that works with screen readers
• - Fix keyboard traps
• - Make a div that is pretending to be a button actually behave like one
• - Provide meaningful link text where "click here" exists

Most accessibility barriers are structural code issues. A widget that runs after the page loads cannot fix them.

The evidence

This is not our opinion. It is the position of the people overlays claim to help.

The FTC. In April 2025, the Federal Trade Commission ordered accessiBe to pay $1 million in fines, ban specific marketing claims, and notify all customers that the product does not make websites WCAG-compliant.

The National Federation of the Blind. "The NFB will not partner with companies that produce accessibility overlays. Such products do not make websites accessible."

The courts. Federal courts in the US have repeatedly rejected the argument that installing an overlay constitutes good-faith ADA compliance. The presence of an overlay is sometimes used as evidence against a site's good-faith defence.

The litigation statistics. In H1 2025, 22.6% of all US ADA web accessibility lawsuits were filed against sites that had an overlay installed. Plaintiffs' attorneys target overlay sites because the product often creates new accessibility issues (focus traps, interfering ARIA, broken keyboard navigation) on top of the existing ones.

The users. Screen reader users, when surveyed, overwhelmingly say they disable overlays when they encounter them. Many overlays interfere with the screen reader software the user has already configured to their preferences.

Why overlays are commercially attractive anyway

Overlay vendors sell to a specific buyer: someone who is afraid of being sued, does not have a developer on call, and wants a checkbox solution. Paste this snippet, pay £490 a year, be compliant. That is easier to say yes to than "audit your site, prioritise findings, schedule developer time, monitor the fix."

This is also why overlays cost £490 to £1,490 per year per site. They are priced like compliance insurance, not like a software widget.

The trouble is, the insurance does not pay out.

What to do instead

A practical migration path. None of this requires you to fix everything at once.

1. Run an honest scan. Switch the overlay off temporarily and scan your site as it actually is. Free scanners include Lumi (multi-engine), WAVE (single page), and axe DevTools (browser extension). This gives you a baseline. It will likely be confronting. That is the point.

2. Understand what the scan can and cannot tell you. Automated scans catch around 30 to 40 percent of real accessibility issues. They reliably catch missing alt text, contrast failures, missing labels, ARIA errors, and structural problems. They do not catch issues that need human judgement, like whether the alt text is meaningful or whether a page makes sense to a screen reader user. If your scan returns "0 issues" and you stop there, you have made the same mistake the overlay vendor made.

3. Prioritise. Not all accessibility issues are equally serious. Fix critical issues (things that completely block users) first. Then serious. Moderate and minor can be worked through over time. A good scanner sorts findings by severity for you.

4. Fix what you can in-house. Many issues are simple code changes: adding alt text, fixing labels, increasing contrast, restructuring headings. A developer can often work through dozens of findings in a day. Lumi's Pro and Agency plans include AI-generated before-and-after fixes for specific issues on your site, which we built because most teams are not accessibility specialists and should not have to be.

5. Get a manual audit for the things automation can't catch. For the 60 to 70 percent of issues automated tools miss (cognitive accessibility, screen reader usability, interaction quality, content meaningfulness), you need a human expert to test your site with actual assistive technology. This is what Livana does. The cost is typically £3,000 to £15,000, depending on scope. Compared to the cost of an ADA lawsuit settlement (median around $30,000 for demand letters, up to $400,000 for class actions), it is a sensible investment.

6. Monitor. Sites regress. A new feature ships, a new image goes up without alt text, a developer removes a focus indicator. Set up automated scanning on a schedule. Weekly is typical.

The cost question

The honest comparison, for a typical small site:

• - Overlay (accessiBe, UserWay, EqualWeb): £490 to £1,490 per year. Does not work.
• - Lumi Solo plus one manual audit: £348 a year (£29 x 12) plus £3,000 audit equals £3,348. Works.
• - Lumi Pro plus one manual audit: £708 a year (£59 x 12) plus £3,000 audit equals £3,708. Works.

The overlay is cheaper. It also does not work and does not reduce your legal risk. The real-compliance path costs more upfront, but it is also what would have been required to avoid the lawsuit in the first place.

One last thing

If you bought an overlay because you genuinely wanted to do the right thing for users with disabilities, that instinct is correct. The product you bought just does not deliver it.

Real accessibility is achievable, much of the work is straightforward, and the tooling has gotten dramatically better. We built Lumi for the small and mid-sized teams that need to do this work without spending £30,000 a year on enterprise platforms.

Run a free scan at lumi.livana.io to see what your site actually looks like. If you want a human to take a look afterwards, the Livana audit team is at livana.io.