Overlay Fact Sheet

Posted by A Life Worth Living | July 6, 2021

What is a web accessibility overlay?

Overlays are a broad term for technologies aim to improve the accessibility of a website. They apply third-party source code (typically JavaScript) to make improvements to the front-end code of the website.

Website add-on products claiming to improve accessibility go back to the late 1990s with products like Readspeaker and Browsealoud. They added text-to-speech capabilities to the website(s) on which they were installed.

Then similar products came to market that added more tools to their software. These allow user-based control of things like font-sizes and colors to improve readability.

Some newer overlay products aim to fix any problems in the site’s code that are preventing assistive technology from being used easily. They apply a script to the page which scans the code and automatically attempts to repair the problem.

Products like Userway, EqualWeb, AudioEye, User1st, MaxAccess, FACIL’iti, Purple Lens, and accessiBe are known as accessibility overlays. They are sometimes white labelled (sold under other names), so this is not a complete list of the type of products discussed on this page.

Strengths and weaknesses of overlay “widgets”

Overlay widgets are unnecessary and are poorly placed in the technology stack.

As stated above, some overlay products contain widgets which present a series of controls that modify the presentation of the page they’re on. Depending on the product, those changes may do things like change the page contrast, enlarge the size of the page’s text, or perform other changes to the page that are intended to improve the experience for users with disabilities.

To laypersons, these features may seem beneficial, but their practical value is largely overstated because the end users that these features claim to serve will already have the necessary features on their computer, either as a built-in feature or as an additional piece of software that the user needs to access not only the Web but all software.

On this latter point, it is a mistake to believe that the features provided by the overlay widget will be of much use by end users because if those features were necessary to use the website, they’d be needed for all websites that the user interacts with. Instead, the widget is as—at best—redundant functionality with what the user already has.

Strengths and weaknesses of automated repair

While some automated repair is possible, customers should be discouraged from using an overlay as a long-term solution.

Some overlay products have capabilities aimed at providing accessibility repairs to the underlying page on which the overlay is added. These repairs are applied when the page loads in the user’s browser.

While it is true that a non-trivial array of accessibility problems can be repaired in this manner, the nature, extent, and accuracy of such repair are limited by a number of important factors:

Automated application 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
Automated repair of keyboard access is not reliable
Modern, component-based user interfaces, such as those using ReactJS, Angular, or Vue may change the state of all or some of the underlying page independently of the overlay, rendering it unable to fix those JavaScript-driven changes to content.
Repairs to the page can either slow down page load times or cause unexpected page changes for assistive technology users.

In addition to the above, overlays do not repair content in Flash, Java, Silverlight, PDF, HTML5 Canvas, SVG, or media files.

An additional class of product exists, which only perform automated repairs and are marketed as a temporary solution. These include Amaze by Deque Systems, Alchemy by Level Access, and Sentinel by Tenon.

For purposes of this document, these products aren’t considered to be in the same class of product as the overlays that provide widgets. The most notable difference, beyond the lack of a “widget” is that Amaze, Alchemy, and Sentinel are understood by their manufacturers as being intended for use as an interim solution.

Fitness for achieving compliance with accessibility standards

While the use of an overlay may improve compliance with a handful of provisions in major accessibility standards, full compliance cannot be achieved with an overlay.

Among the many claims made by overlay vendors is the claim that the use of their product will being the site into compliance with accessibility standards such as WCAG 2.x, related and derivative standards, and laws that mandate compliance with those standards.

Conformance to a standard means that you meet or satisfy the ‘requirements’ of the standard. In WCAG 2.0 the ‘requirements’ are the Success Criteria. To conform to WCAG 2.0, you need to satisfy the Success Criteria, that is, there is no content which violates the Success Criteria.Understanding WCAG 2.1: Understanding Conformance

Given that conformance is defined as meeting all requirements of the standard, these products’ documented inability to repair all possible issues means that they cannot bring a website into compliance. Products marketed with such claims should be viewed with significant scepticism.

Privacy of personal data

Overlays that automatically enable certain settings, like those for screen reader or speech recognition users, do so by detecting when an assistive technology is running on the device. This exposes the fact that the person using the device at the time has a disability. In certain cases, like screen reader users where the majority are blind or have low vision, it exposes even more detail about the nature of their disability. Like age, ethnic background, or preferred gender, disability is sensitive personal information. It is not data that should be collected without the informed consent of the person it belongs to.

Some overlays have been found to persist users’ settings across sites which use the same overlay. This is done by setting a cookie on the user’s computer. When the user enables a setting for an overlay feature on one site, the overlay will automatically turn on that feature on other sites. While the overlay company might think they’re doing good by the end user, the big privacy problem is that the user never opted in to be tracked and there’s also no ability to opt-out. Due to this lack of an opt-out (other than explicitly turning off that setting) this creates GDPR and CCPA risk for the overlay customer.

In their own words

Many users with disabilities have expressed strong words of dissatisfaction with overlay products. As shown below, overlays themselves may have accessibility problems significant enough for users to take steps to actively block overlays from appearing at all.

Please note: while this section may mention specific vendors, these comments are par-for-the-course when it comes to the user experience provided by overlay widgets which have, in themselves, a pattern of negatively impacting the user experience.

Conclusion

No overlay product on the market can cause a website to become fully compliant with any existing accessibility standard and therefore cannot eliminate legal risk.

Accessibility on the Web is a big challenge, both for owners of websites and for the users of those websites. The invention of novel approaches to resolving this challenge is to be commended.

However, in the case of overlays—especially those which attempt to add widgets that present assistive features—the challenge is not being met. Even more problematic are the deceptive marketing provided by some overlay vendors who promise that implementing their product will give their customer’s sites immediate compliance with laws and standards.

The ineffectiveness of overlays is something that has broad agreement among accessibility practitioners, per the WebAIM Survey of Web Accessibility Practitioners which found:

A strong majority (67%) of respondents rate these tools as not at all or not very effective. Respondents with disabilities were even less favorable with 72% rating them not at all or not very effective, and only 2.4% rating them as very effective.

Statement from sponsors and signatories to this fact sheet

As a result of the above information:

We will never advocate, recommend, or integrate an overlay which deceptively markets itself as providing automated compliance with laws or standards.
We will always advocate for the remediation of accessibility issues at the source of the original error.
We will refuse to stay silent when overlay vendors use deception to market their products.
More specifically, we hereby advocate for the removal of accessiBe, AudioEye, UserWay, User1st, MK-Sense, MaxAccess, FACIL’iti, and all similar products and encourage the site owners who’ve implemented these products to use more robust, independent, and permanent strategies to making their sites more accessible.

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Link to Original Article: https://overlayfactsheet.com/