1. Accessibility Overlays:
the policy perspective
overview of the current situation in Europe

2. What are accessibility overlays?
TOOLS THAT CAN BE
ADDED TO WEBSITES
PROMISING TO
IMPROVE
“AUTOMAGICALLY”
ACCESSIBILITY OF
WEBSITES.
THERE ARE
DIFFERENT TYPES
OF ACCESSIBILITY
OVERLAYS (E.G.
WIDGETS).
OFFERED USUALLY
AS A FAST
SOLUTION, BUT
BECAME A
PERMANENT
BRIDGE.
THEY DON’T
CHANGE THE
WEBSITE
ORIGINAL CODE,
BUT ONLY APPLY
SOME “PATCHES”.

3. Web Accessibility
Directive and overlays
• Require to be conform at least to EN 301
549 v.3.2.1 European harmonized
standard.
• The EN301549 v.3.2.1 Annex A serves as
presumed conformance.
• There are no tools that can guarantee
automated testing for all evaluation
criteria, so is impossible to fix all
evaluation criteria “automagically”.
• Overlays do not make the website
accessible or compliant with European
accessibility legislation.

4. • Overlays do not correct all accessibility issues –
even worse, they create new ones.
• Can fix “automagically” only a few success criteria
(less than 10%)
• Can interfere with assistive technologies and user
interface personalization.
• Can create false positives or false negatives.
• May impact on web site performance.
It can be difficult for people who are not digital
accessibility specialists, including users, developers,
designers and website owners who purchase
technology, to understand what accessibility overlays
can and can’t deliver, and the limitations and
potential risks of any new technology.
What they can do and
What they cannot do

5. What issue can be
created
• Can generate issues for different user needs:
• Motor: cannot guarantee possibility to use keyboard
to access to all contents (e.g. menus, buttons, etc.).
• Cognition: cannot change language for contents,
change information and correlation structure (e.g.
missing use of titles, labels, etc.).
• Visual: cannot guarantee adequate alternative text
with risks for user interactions (e.g. choosing wrong
food products that can creates issues).
• Hearing: cannot guarantee adding of captions in
videos published internally or in third parties
repository (e.g. video that don’t support natively
captions).
• Some overlays automatically detect when an assistive
technology is running on a user’s device.

6. Hard or impossible to activate
• Close icon inaccessible
• No visible focus
• No keyboard activation
• No mouse activation
• Dialog cannot be closed
• Accessibility options open behind
dialog
• Other icons leave site

7. Contrast profiles create issues
• Critical elements disappear:
• Menu icon
• Search icon
• Social media links

8. Magnification creates issues
• Images overlapping text
• Text overlapping text

9. Numbers
• We are still not seeing a lot of them in Europe,
but they are increasing even here.
• In Italy, where the WAD was extended to big
companies, these uses overlays as “first aid”
but then without moving to assessment and
remediation, so no conformance to WAD is
actually available in company websites that
uses accessibility overlay.

10. What to do
instead?
• accessibility by default (internal
guidelines, procurement
requirements, etc.)
• Assessments (periodically)
• Remediation (periodically)
• education and outreach (forever)
• Test with/involve end users with
disabilities (forever).

11. At the end
• Artificial intelligence and other
emerging technologies have great
potential to improve accessibility
and assistive technology.
• However, to date none of these
technologies can instantly fix an
inaccessible website.
• Never add something that risks
harming users, always test with
users, don’t believe in things that
sounds too good to be true.

12. Thank you!
Roberto Scano
mail@robertoscano.info
www.robertoscano.info