Accessibility ≠ Overlay: EDF and IAAP warn that overlays do not make a website accessible
A joint statement from EDF and IAAP
On 17 May 2023, the European Disability Forum (EDF) and the International Association of Accessibility Professionals (IAAP) published a joint statement on accessibility overlays. They recognize the potential of artificial intelligence and emerging technologies, but warn that current technology cannot instantly solve every accessibility problem on a website.
Users already have their own preferences
Many functions offered by overlays—such as magnification, contrast, colour changes or reading assistance—already exist in browsers, operating systems and assistive technologies. People may already have their devices configured to meet their needs, and EDF and IAAP warn that an additional layer can interfere with those technologies or override user preferences.
The robust solution belongs in the website itself
A screen reader needs a page to expose its structure, relationships, names, roles, states and values correctly. Buttons, labels, focus management and dynamic components need to be implemented properly. If the barrier is in the original code, the strongest solution is to fix it there rather than trying to reconstruct its meaning later through an additional layer.
Privacy and assistive technologies
Some technologies may attempt to detect whether a person is using assistive technology. That information may be related to disability and therefore to sensitive personal data. The joint statement highlights the risks of this kind of detection when users are not given an appropriate choice about the processing of that information.
A false sense of security
Installing an overlay can lead a website owner to believe that accessibility has been solved while unlabeled forms, keyboard-inaccessible menus, incorrect focus order or dynamic content that is not announced by a screen reader remain. The presence of an accessibility panel does not prove that those barriers have disappeared.
Do overlays guarantee European compliance?
EDF and IAAP state that overlays do not make a website accessible and do not by themselves guarantee conformity with European accessibility legislation. They also state that overlays are not an acceptable alternative to fixing the website itself.
Accessibility is not the user’s responsibility
Digital accessibility is the responsibility of those who own, design, develop and maintain the product, not the user. A disabled person should not have to activate a special profile in order to access a service. The question should be which barriers exist in the product and how they can be removed.
Innovation, but within an accessibility process
EDF and IAAP do not reject innovation. They recommend working with accessibility specialists, people with disabilities and representative organizations. Automated tools can help, but they should be part of a broader process involving accessible design, development, evaluation and real-world testing.
Accessibility ≠ Overlay
The first three parts of this series converge on one idea: accessibility should not depend on a separate experience, automated repair or detecting the user. A website should work with the tools and preferences people have already chosen. Real accessibility is designed, developed, tested and maintained in the website itself.
Original sources
European Disability Forum (EDF) + International Association of Accessibility Professionals (IAAP)
Joint statement on accessibility overlays · 17 May 2023.
European Disability Forum — Joint statement
This article is part of the “Accessibility ≠ Overlay” series. Part 03 — European Disability Forum + IAAP.