Can an accessibility overlay service replace WCAG 2.2 AA site remediation?

Hello, I'm Morimoto, CEO of Liberogic.

Through our contact form, many clients who first consult us about accessibility ask, "Wouldn't using this service make us compliant with JIS or WCAG?"

A figure-shaped icon sits in the corner of a website; clicking it lets visitors choose options such as enlarging text, changing color schemes, or reading content aloud. Services that provide these features are generally called accessibility overlays. Some products automatically fix page issues using JavaScript.

While these overlays may include useful features, simply installing an overlay does not complete a website's accessibility compliance, and we do not believe it can achieve WCAG AA conformance.

The Web Accessibility Infrastructure Committee (WAIC) and Mitsue Links, a pioneer in this industry, have also addressed this issue for a long time.
[Reference: WAIC: Are accessibility overlays effective for ensuring accessibility? Can they achieve conformance level AA?]
[Reference: Mitsue Links: Musings on accessibility overlays]

At one point, Chrome plugins were even released to remove such services.
Below, we have compiled answers to these questions, including case studies from Europe and North America, for reference.

Users Should Be in Control

Everyone's web environment is different. Some people enlarge the screen in their browser, some use OS color settings, some rely on screen readers or voice input, and some operate sites using only a keyboard. Some people apply the same settings across multiple sites.

The W3C explains that customizing text and managing user preferences are better served through "user agents" than through web content.
These include browsers and assistive technologies, but this does not mean websites need not consider accessibility.
The role of the website is to be usable in the environment the user has chosen.
[Reference: W3C: Overview of UAAG]

For example, if a user has enabled a setting to reduce motion, the site can adjust its animations accordingly using prefers-reduced-motion. For settings that request higher contrast, there is prefers-contrast, and for forced color modes, there is forced-colors.

Supporting these settings is not a requirement at Level A or AA conformance under WCAG 2.2. However, it is an effective way for a site to respect the preferences users have already chosen for themselves. It is worth considering before building custom toggle buttons of your own.
(See MDN: prefers-reduced-motion)

Adding features and fixing site problems are separate matters.

Accessibility overlay services offer features that change text size and colors, as well as tools that automatically fix issues such as HTML problems.
Some people may find the text size and color features useful, but for those who have already configured their browsers and assistive technologies to suit their needs, these features can overlap and interfere with their existing settings and how they operate their devices.

Automatic fixes for HTML and similar issues also have limits. For example, image descriptions (alternative text) must be written based on what the image conveys within the page. There are also issues such as whether the purpose of an input field is clear, whether the site can be used with the keyboard alone, whether focus moves correctly after a dialog opens, and whether the role and state of custom buttons are communicated to assistive technologies. These problems cannot be solved by changing appearance alone. Even when some issues can be fixed automatically, people must operate the site to confirm whether it is actually usable.

A joint statement from the European Disability Forum (EDF) and the International Association of Accessibility Professionals (IAAP) points out that some overlay features may be helpful, but they can duplicate or interfere with browsers and assistive technologies.
The statement also says that overlays are not a substitute for fixing the site itself.
(See EDF and IAAP joint statement)

In Europe, the approach is to fix problems at their source.

In its guidance on the Web Accessibility Directive, which covers websites and apps of public sector bodies, the European Commission explicitly mentions overlays.

Overlays and similar tools that do not ensure a site meets the detailed requirements of technical standards are not an appropriate solution. The best approach is to fix accessibility issues at their source.

That is the explanation.
Please note that this does not mean the EU has banned overlay technology across the board.
(See European Commission: Web accessibility)

In France, in June 2026, the Caen Judicial Court ordered a major retailer to improve the accessibility of its e-commerce website and app.
This is not a judgment on whether overlays are appropriate, but we include it as a case study because it examined whether the actual service could be used.
[Reference: court documents published by the French judicial authorities]

In the U.S., claims that installing an overlay makes a site "WCAG compliant" become an issue

In April 2025 in the U.S., the Federal Trade Commission (FTC) finalized a consent order against a provider of accessibility overlays. The FTC alleged that claims that "any website can be made compliant with WCAG" were false, misleading, or lacked sufficient substantiation.
The order requires a payment of $1 million and prohibits similar unsubstantiated claims.
This is an administrative case concerning advertising by a specific company. It is not a ruling that all overlays are illegal, but we include it as a case study.
[Reference: FTC: Announcement of final consent order]

In another lawsuit, the website operator cited the installation of an overlay and other measures, arguing that the site conforms to WCAG 2.1 AA and asking the court to dismiss the case. In March 2025, the court denied that motion and allowed the proceedings to continue.
The plaintiff argued that barriers remained for purchasing products and checking nutritional information. Installing a tool or submitting a conformance report alone did not end the lawsuit as the problem was resolved.
This is not a ruling that the overlay itself created new barriers, but we include it as a case study.
[Reference: Court decision document]

The U.S. Department of Justice also acknowledges that automated checks and overlays can be helpful in some cases, but advises cautious use. Even if automated check results show "no issues," that does not mean everything is accessible.
The guidance recommends combining them with human review.
[Reference: U.S. Department of Justice: Web accessibility guidance]

What will happen with WCAG 3.0

As of September 2026, WCAG 3.0 is still a draft. Requirements and conformance evaluation methods may change, so it is not possible to determine now whether overlays will or will not be permitted under 3.0. As a current preparation, W3C recommends first working toward the success criteria of WCAG 2.2.
[Reference: W3C: Overview of WCAG 3]

However, the draft version dated September 10, 2026 includes provisions that users can control content settings through their browsers and assistive technologies, and that content responds to users' accessibility settings.
The draft also introduces the concept of an "accessibility support set," treating the combination of browsers, assistive technologies, and settings used for evaluation as a unit.

The new draft of WCAG 3.0 has been published. What has changed this time?
What changes in WCAG 3.0?

All of these are still under consideration, and it cannot be said that a provision banning overlays will be created. However, the direction does not suggest that adding an overlay eliminates the need to improve the website itself.
[Reference: W3C: WCAG 3.0 draft]

First, the website itself needs to be usable.

The steps that site operators and builders should take are clear.

• Give headings, buttons, and forms meaningful names and roles.
• Make sure everything can be operated with the keyboard alone and that users can tell where focus is.
• Provide alternative text that fits the role of each image.
• Support zoom and users' color and motion preferences.
• In addition to automated checks, verify with real interactions and assistive technologies, and fix any issues you find.

Additional tools may help certain users, and they can be worth using once you have confirmed their real-world impact on users. However, installing a tool does not mean that improvements are complete.

Control over accessibility rests with users.
The goal is to make the site usable with whatever browser, OS, and assistive technology users choose.
To get there, the fundamentals are to build the site, test it, and keep fixing it.

By the way, Liberogic offers Lente Scan, a free automated diagnostic tool that finds accessibility issues on websites, and Lente Audit, where experts review the parts that automated checks cannot catch and help with improvements.
When building and maintaining a site, please also make use of our free Chrome extension, which lets you check contrast and page structure.

Both of these services contribute to improving the accessibility of the website itself.