WCAGdesk

WCAGdesk vs UserWay.

UserWay sells an accessibility overlay — the same product category for which the US FTC fined accessiBe $1 million in April 2025 for deceptive marketing. WCAGdesk is a continuous source scanner that produces RFC 3161-timestamped, hash-anchored evidence bundles for the European Accessibility Act.

Why the category itself is the problem

Overlays — UserWay, accessiBe, EqualWeb, AudioEye's widget tier — share an architecture: a JavaScript snippet that re-decorates the DOM after page load. WebAIM's 2023 study of one million home pages found sites running overlays were no more accessible than sites without them. The accessibility community has maintained an open letter signed by hundreds of practitioners against the category since 2021. EU enforcement under the EAA tests the served HTML — not the widget overlaid on top of it.

Sources: WebAIM Million 2023 · Overlay Fact Sheet · FTC consent order, In re accessiBe Ltd., April 2025
Overlay category ~1M Home pages WebAIM scanned in 2023. Overlay-equipped sites failed at the same rate as sites without them.
WCAGdesk RFC 3161 Per-scan trusted timestamp + SHA-256 hash chain anchored to Polygon. The exhibit your Fachanwalt files.
01

Head to head

Dimension UserWay WCAGdesk
Category JavaScript overlay widget Continuous source scanner + evidence record
Touches your source HTML No — runtime DOM mutation Yes — reports on what is actually shipped
Engine Proprietary widget + manual "Managed" upsell axe-core 4.11 — same engine as Lighthouse and Chrome DevTools
Evidence artifact Widget settings; "audit report" only on higher tiers PDF/A-2b + RFC 3161 timestamp + SHA-256 hash chain on Polygon
Screen-reader behaviour Independent testing shows overlay disruption of AT flow Does not modify your site
EU posture Same category as the product fined by the FTC in April 2025 Designed for EAA Art. 4 and BFSG § 12 disclosure
Abmahnung response No timestamped history to attach Dated hash-chained record + German response draft for a Fachanwalt
Pricing (entry) Free starter tier, then ~$49–$490+/mo per domain €149/mo Audit · €299/mo Defense · €599/mo Counsel · cancel anytime
02

The structural issue: overlays don't change the served document

UserWay's widget loads after your page does and re-decorates the DOM. From the perspective of every party that matters in EU enforcement — the law firm running a BFSG warning-letter campaign, the Marktüberwachungsbehörde inspecting your site, the consumer-protection NGO filing a complaint — the served HTML is what gets tested. They do not run your overlay. They scan the raw markup.

That means the alt text the widget "adds," the contrast it claims to fix, the ARIA labels it injects — none of these appear in the document the regulator sees. Your source remains the source of liability.

03

The evidence problem

Even if a widget did improve the served page (it doesn't), it would still leave no defensible record. When an Abmahnung dated 14 March cites failures on three specific URLs, the question your Fachanwalt has to answer is: what state was the page in on 14 March? A widget cannot tell you that. A timestamped scan from the previous Wednesday can.

WCAGdesk's record is the artifact the legal process is shaped around — dated crawls of the actual served HTML, anchored to a hash chain so the timeline is independently verifiable.

04

Where UserWay's marketing concedes the gap

Read UserWay's higher-tier pages and you'll see "Managed Compliance" upsells offering manual auditing, remediation, and policy work for several thousand dollars per month on top of the widget. That copy is the company itself acknowledging that the widget alone does not produce a compliance outcome — you need real source-level work and a real audit record. WCAGdesk supplies the audit record at €149–€599/mo without locking it behind a sales call.

05

What WCAGdesk does

  1. Crawls a representative sample of your live URLs on a weekly (Audit) or daily (Defense / Counsel) schedule using a clearly identified user agent.
  2. Runs axe-core 4.11 against the rendered DOM and stores the engine version, ruleset, and per-URL hash with each scan.
  3. Issues a PDF/A-2b report carrying an RFC 3161 timestamp. Each weekly batch rolls into a SHA-256 Merkle tree anchored to Polygon mainnet.
  4. Generates an EAA Article 4 accessibility statement in EN and DE, prefilled with real numbers, refreshed quarterly.
  5. Defense view assembles an Abmahnung response packet: scan history, remediation log, German draft for a Fachanwalt für IT-Recht.
06

Honest disclosures

  • WCAGdesk is automated. axe-core catches roughly 30–40% of WCAG criteria — the ceiling for any automated tool, per Deque's own published research. For full BFSG conformance you also want manual expert review; the methodology page goes deeper.
  • Until Q3 2026 our RFC 3161 timestamps come from FreeTSA (publicly trusted, not a qualified TSA under eIDAS Art. 41). Qualified TSA via Sectigo and AdES PDF sealing are on the roadmap.
  • We are not lawyers. The evidence WCAGdesk produces supports a defence; a Fachanwalt runs the actual defence.

See your real source through a real scanner.

One free scan of your live HTML, no signup, axe-core 4.11. You'll see what an EU enforcement letter would actually cite — separate from what any overlay would claim.