As a follow-up to our previous article, Thinking About Using a Website Overlay Accessibility Tool? Think Again, we’re revisiting the role of accessibility overlay widgets in today’s rapidly evolving digital compliance landscape.
It's 2025, and while overlays now boast AI enhancements and new customization features, many of the core limitations – and risks – remain. With the European Accessibility Act (EAA) now fully in effect and global litigation on the rise, it's clearer than ever: accessible design can't be outsourced to a toolbar.
Are AI Accessibility Overlay Widgets More Effective in 2025?
Despite improvements in speed and customization, AI-powered overlay widgets remain fundamentally flawed when it comes to accessibility compliance and real usability.
- Effectiveness remains limited. Most overlays still correct only 20-40% of common accessibility issues, missing core requirements like semantic heading structure, form labeling, and keyboard navigation.
- Assistive tech conflicts persist. Screen reader users often report that overlays interfere with navigation, focus order, or native labels, making once-usable pages more difficult to navigate.
- AI doesn’t equal understanding. Even the most advanced AI widgets struggle with contextual accuracy, often inserting incorrect alt text, applying contrast adjustments inconsistently, or failing to account for dynamic content changes.
In short, AI has made overlays faster but not better. While they may offer quick visual fixes, they still fall short of what real users and legal standards demand.
An example of an accessibility overlay widget. Source: EqualWeb
The Web Accessibility Legal Landscape in 2025
If you’re using an accessibility overlay widget and hoping it protects your organization from legal risk, we have bad news:.
- In April 2025, the Federal Trade Commission (FTC) fined a major overlay vendor $1 million for misleading claims about product effectiveness and WCAG compliance.
- Since early 2024, more than 1,000 lawsuits in the United States have targeted organizations that relied predominantly on accessibility overlay widgets, accounting for roughly a quarter of all Americans with Disabilities Act (ADA) digital accessibility cases that year. Over 300 new suits have been filed in just the first half of 2025 alone – some resulting in court-mandated removal of the overlays and settlement agreements requiring full accessibility remediation.
- Courts have consistently ruled that simulating accessibility is not the same as meeting accessibility standards.
Case in Point: The European Accessibility Act (EAA)
The European Accessibility Act (EAA), which took full effect in June 2025, mandates that all digital products and services provided within the EU meet WCAG 2.1 AA standards. This includes e-commerce sites, mobile apps, online banking, and digital communications platforms.
The European Commission has publicly stated that accessibility overlays – whether AI-powered or not – don’t constitute a valid path to WCAG compliance. These tools are increasingly viewed as superficial fixes that fail to address the underlying structural and semantic issues that define true accessibility.
While formal EAA enforcement is still in its early stages as of mid-2025, and few penalties have been made public, the risks are clear. Consider a likely scenario: A US-based software provider selling to clients in the EU relies solely on an AI overlay to meet accessibility requirements. If regulators determine that the widget doesn’t provide equivalent access and fails to fix underlying HTML issues, the company could face significant penalties, such as a large fines and a requirement to implement full WCAG remediation.
Overlay widgets that simply adjust visuals or simulate accessibility compliance aren’t enough – and may even increase legal and reputational risk.
What AI Can (and Can’t) Do When It Comes to Accessibility Overlays
AI is undeniably playing a bigger role in digital experiences, and that includes accessibility. In 2025, overlay tools often use AI to:
- Automatically adjust contrast, font size, and line spacing for individual users.
- Provide real-time text-to-speech support or page magnification.
- Attempt to generate alternative text using computer vision.
But even when AI-enabled, overlays still fall short in areas that matter most:
- Dynamic form labeling and validation feedback remain unreliable.
- Keyboard navigation and focus handling often break due to overlay interference.
- AI-driven changes may conflict with assistive technologies like screen readers or voice input systems.
Even more troubling, overlays can overwrite correctly implemented native HTML elements, undoing otherwise accessible development work.
The Bottom Line
In 2025, accessibility overlays – even those powered by AI – are still no substitute for accessible code, thoughtful design, and real user testing. While AI introduces helpful tools for personalization and adaptive design, it can’t fix underlying structural issues or guarantee compliance on its own.
The best strategy remains the same:
- Start with semantic, WCAG-compliant code.
- Integrate accessibility into the website design process.
- Conduct both automated and manual accessibility testing.
- Engage real users with disabilities in usability validation.
Organizations that treat accessibility as a core part of their digital strategy build more inclusive, usable, and legally resilient experiences, and avoid the costly pitfalls of shortcut solutions. Even in 2025.
If you need help identifying website accessibility issues, the best place to start is with an accessibility audit. Learn more about our accessibility audits and comprehensive accessibility services, and reach out to get started.