An independent witness your overlay vendor can't be
OverlayRiskWitness tests sites with their accessibility overlay on, then off, and documents where the public compliance claims don't hold up. Every finding is tied to a specific page, a timestamp, and a snapshot. No stake in the overlay. No stake in the outcome.
This is evidence documentation, not a compliance ruling. What the evidence means for your site is a question for your counsel.
Three gaps no existing tool fills
Overlay vendors grade their own homework
accessiBe and UserWay sell monitoring dashboards alongside the overlays themselves. Their own data shows whether their overlay appears to work — not whether your public "accessible" or "WCAG-compliant" claim holds up when someone tests the page from outside their system.
Free scanners diagnose, but don't prove your claim
WAVE and axe DevTools are real tools. They find violations. What they don't do is run the same page with the overlay blocked, then compare the delta against the specific compliance language on your accessibility statement. That gap is where the legal exposure sits.
The missing piece is neutral before/after proof
OverlayRiskWitness runs each page twice — overlay on, overlay off — records the axe-core diff, quotes your own public statement back, and timestamps every exhibit. That record exists outside the vendor's dashboard and outside a scanner's output. It's the only artifact that answers the actual question.
The moment this becomes urgent
Most sites running an overlay have never tested it from outside the vendor's dashboard. That gap is usually invisible — until one of these arrives.
FTC action — April 2025
The FTC's final order requiring accessiBe to pay $1 million established that overlay marketing claims are subject to federal scrutiny. For any site displaying an accessiBe badge with a compliance statement, that order changed what "due diligence" means.
Demand letter
ADA demand letters ask whether the site was accessible to the plaintiff on a specific date and page. The overlay vendor's dashboard is not a neutral answer. A timestamped before/after packet — issued by a party with no stake in the vendor's success — is.
Quarterly counsel review
Outside counsel reviewing a site's accessibility posture needs something reproducible: a record of which claims appeared on the site, which pages were tested, when, and what the overlay actually changed. That's exactly what a witness packet provides.
Source
FTC press release, April 2025: FTC approves final order requiring accessiBe to pay $1 million
The people responsible for the claim
OverlayRiskWitness is built for non-technical buyers. There's no code to install, no terminal commands, and no accessibility expertise required to run a witness or read a packet.
- Site owners
- You approved the overlay, approved the compliance statement, and assumed it worked. You need to know whether that assumption holds before someone else tests it first.
- Marketing directors
- Your team wrote the accessibility statement. Running a witness test before publication — or before a redesign goes live — is the same discipline as fact-checking any other public claim.
- Ecommerce operators
- High transaction pages (checkout, product pages, account flows) are the highest-risk pages for keyboard and focus failures. Overlays don't always fix those, and the vendor's dashboard may not surface the gap.
- Web agencies
- Your clients installed the overlay on your recommendation. Running a vendor-independent witness check is how you show the work — and how you protect the relationship if a demand letter arrives later.
- Counsel-adjacent ops teams
- You're not the attorney, but you're the one assembling the file. A witness packet gives counsel timestamped, reproducible evidence they can evaluate without having to reconstruct a browser session from memory.
Run a free witness on your site
One page, no signup. If an accessiBe or UserWay overlay is detected, you'll see one real before/after finding — for free. The full packet is $49.
Run a free witnessThis is evidence documentation, not legal advice. Your counsel decides what it means.