Pattern #28 · Accessibility

Don't outsource WCAG compliance to an AI overlay

One line of code, one million dollars.

Track Aaccessibilitywcagoverlayscomplianceftctrust

Do

Use overlays and automated checkers as remediation aids inside a process that ends with manual testing using assistive technology, and claim exactly what that testing shows.

Don't

Install one line of code and update the accessibility statement. The complaint lists what the widget missed: menus, buttons, tables, alt text.

The rule. WCAG compliance is a property of the website, verified by manual testing: an automated overlay can help remediate, but it cannot be the compliance claim.

Why. The FTC ordered accessiBe to pay one million dollars over claims that its accessWidget overlay could make any website WCAG compliant, allegations the agency called false, misleading, or unsubstantiated (Federal Trade Commission, 2025a), and finalized the order in April 2025 (Federal Trade Commission, 2025b). The complaint describes manual tests of sites running the overlay that found missing or inaccurate alt text, keyboard traps, and broken menus, buttons, and tables, all Level A or AA failures, and cites the position of the W3C and other accessibility experts that no automated testing tool alone can determine whether a site meets accessibility standards (Federal Trade Commission, 2025c). The same complaint notes that accessiBe's own internal testers found errors on nearly all websites they tested (Federal Trade Commission, 2025c).

Seen in the wild. accessiBe marketed accessWidget as making any website WCAG compliant, 30 percent on install and the remaining 70 percent by AI within 48 hours, per the FTC complaint (Federal Trade Commission, 2025c).

References

  1. 01

    Federal Trade Commission. (2025a, January 3). FTC order requires online marketer to pay $1 million for deceptive claims that its AI product could make websites compliant with accessibility guidelines [Press release]. https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-order-requires-online-marketer-pay-1-million-deceptive-claims-its-ai-product-could-make-websites

    https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-order-requires-online-marketer-pay-1-million-deceptive-claims-its-ai-product-could-make-websites
  2. 02

    Federal Trade Commission. (2025b, April 22). FTC approves final order requiring accessiBe to pay $1 million [Press release]. https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-approves-final-order-requiring-accessibe-pay-1-million

    https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-approves-final-order-requiring-accessibe-pay-1-million
  3. 03

    Federal Trade Commission. (2025c). Complaint: In the matter of accessiBe Inc. and accessiBe Ltd. (Matter No. 222-3156). https://www.ftc.gov/system/files/ftc_gov/pdf/2223156accessibecomplaint.pdf

    https://www.ftc.gov/system/files/ftc_gov/pdf/2223156accessibecomplaint.pdf