The Limits of Overlays and the FTC accessiBe Case
The accessibility community and domain experts have long noted that automated overlays do not deliver WCAG compliance on their own. The reason is structural: because an overlay does not measure and does not change the source code, it does not resolve the underlying violations. Moreover, in some cases the overlay itself can conflict with assistive technology, for example screen readers, and disrupt an experience that already worked. For this reason an overlay should be seen not as the starting point of an accessibility program but, at most, as a complement to it.
This also took concrete form at the regulatory level. In 2025, the US Federal Trade Commission (FTC) imposed a USD 1 million penalty on the overlay provider accessiBe over deceptive claims that its automated tool made websites WCAG compliant. This is a public, concrete decision showing that the claim of an automated tool achieving compliance on its own was rejected by a regulator. Source: ftc.gov.
Takeaway: No automated tool, whether an overlay or a scanner, can guarantee full WCAG compliance on its own. Full compliance requires source code fixes and manual review. The right question is not which tool makes me instantly compliant, but which tool honestly measures my situation and guides the fixes.