A toolbar on top of the page, and the markup underneath unchanged
What it is
An overlay is a script you add to a site that presents visitors with a toolbar of display preferences, such as larger text or higher contrast, and attempts some automatic repairs to the page. It is sold as a fast route to accessibility compliance.
Does it apply to you
- You are considering one, usually because it is offered as a same-day fix after a demand letter arrives.
- You already have one installed and want to know what it covers.
What being wrong costs
Installing an overlay does not settle the underlying obligation. The Department of Justice has stated in its ADA web guidance that it does not certify or approve any product, service or website as compliant, so no vendor can confer compliance by being installed. Assistive technology reads the page markup, and a display toolbar does not change what the markup says. Where an overlay makes a public conformance claim on your behalf that turns out to be inaccurate, the claim is one you published.
What it demands
- Nothing. It is a product rather than an obligation. The obligation is the one the overlay was bought to answer, and it remains whatever it was.
- If you keep one, read what it publishes about you. Some overlays add a public conformance statement to the page, and a claim made in your name is a claim you have made.
What WebSpark does
- We do not use one, on any site, and would not add one to yours.
- Accessibility is built into the components and tested against WCAG 2.2 AA on every change, which is the work an overlay is sold as a substitute for.
- You get a dated record of what was tested and found, which is the thing a demand letter actually asks you to produce.
What you can show
- A monthly test record per route, which an overlay does not produce.
- An accessibility statement describing how conformance was established and what is known to fall short.
What stays yours
- Deciding what to do about an overlay you already have. Removing one is usually straightforward, but if a vendor has published a conformance claim on your behalf, that is worth a conversation with a lawyer first.
Sources
- Guidance on Web Accessibility and the ADAUS Department of Justice, Civil Rights Division
- Understanding ConformanceW3C Web Accessibility Initiative
WebSpark describes obligations and evidences what a site does. It does not provide legal advice, and this page is not a substitute for a lawyer who knows your business.