Guide · As of 31 October 2026
Accessibility without an overlay. No panic, but no excuse either.
Germany’s accessibility act (BFSG) has applied since June 2025, implementing the European Accessibility Act. Since then many vendors sell widgets that promise to make a site accessible with one line of code. What holds up, and what actually counts.
Who the German act covers
The BFSG covers “services in electronic commerce”: offers that lead to a contract with consumers online, such as a shop or an online booking. A pure information site of a trade business usually does not fall under it.
Micro-enterprises are exempt for services: fewer than 10 employees and no more than 2 million euros annual turnover or balance sheet (§ 2 BFSG). Other EU countries implement the European Accessibility Act with similar rules.
The first warning letters in Germany arrived from August 2025. Whether BFSG breaches can be pursued under competition law at all is open; no court ruling on it is known so far.
Why an overlay does not make a site conformant
Overlay plugins put a toolbar or script on top of the finished page: larger text, contrast toggle, read aloud. The page underneath stays as it is. Missing labels, a broken heading order, controls you cannot reach with a keyboard: a script does not reliably fix those.
More than a thousand accessibility practitioners and disabled users put it this way in the Overlay Fact Sheet: no overlay product can make a website fully compliant with any existing standard. The German UPA accessibility working group wrote in 2025 that overlays do not fix basic problems in the code and are no substitute for an accessible build.
In 2025 the US Federal Trade Commission required one vendor (accessiBe) to pay 1 million US dollars for claiming its AI tool could make any website WCAG-compliant.
What counts instead
Accessibility comes from the HTML and CSS itself: real headings and landmarks, a label on every form field, enough contrast, a visible focus, text that does not clip when enlarged or spaced, motion you can switch off.
None of that is magic, but it is handwork. It belongs in the design, not in a plugin that costs every month.
What Kiekkist designs bring
Every design is checked against WCAG 2.2 AA before it is sold, automatically and with a checklist. The report is in the package, and the checker also checks your finished site.
What you add later still matters: alt text, PDFs, form copy, embedded tools. A checked design is a good start, not a guarantee for the finished website.
Sources
Questions
Do I need an accessibility overlay?
No. An overlay does not make a site conformant. What counts is clean HTML and CSS: headings, labels, contrast, focus, text that does not clip when enlarged.
Does accessibility law apply to my website?
If you sell to consumers online (shop, online booking) and are not a micro-enterprise, probably yes in the EU. A pure information site usually not. When in doubt, ask a specialist or a lawyer.
Is a Kiekkist design compliant?
The design is checked against WCAG 2.2 AA before sale. Whether your finished site conforms also depends on your content. Nobody can guarantee that for you.