Accessibility overlay
An accessibility overlay is a JavaScript widget that injects accessibility "fixes" at runtime without modifying source code; the DOJ and disability advocates do not consider overlays sufficient for ADA compliance.
Detailed explanation
Accessibility overlays are JavaScript snippets vendors install on a website that attempt to patch accessibility issues after the page loads. Examples include AccessiBe, UserWay, EqualWeb, AudioEye, and Isonomy. They typically inject a toolbar with display-adjustment controls (font size, contrast, focus indicators).
Overlays do not modify the underlying HTML, CSS, or theme files. Screen readers read the original markup before the overlay's JavaScript executes — so the broken structure is announced exactly as written. When the overlay script fails (ad blockers, slow CDNs, JS errors), the underlying violations are fully exposed.
In 2025, the FTC fined AccessiBe $1 million for deceptive claims that its overlay made websites fully accessible. Settlement-trail data shows 22.6% of websites sued for ADA violations had an overlay installed at the time of suit. Courts have allowed those lawsuits to proceed, sometimes citing the overlay as evidence of awareness without genuine remediation.
How this applies to Shopify stores
Most Shopify accessibility apps are overlays. AccessComply is not — it writes fixes directly into your theme's Liquid, HTML, and CSS files via the Shopify Admin API. The fix persists in source control, ships in the theme, and survives uninstalls.
Primary source: ftc.gov