Does the European Accessibility Act Require Alt Text? What Website Owners Should Know

The short answer: yes. If the European Accessibility Act applies to your website, your images need text alternatives, and for ordinary web images that means alt text.

The longer answer is that the Act never uses the words “alt text” anywhere in its text.

That gap between what the law literally says and what it effectively requires is where the confusion lives. So let’s walk through what the Act asks for, who’s covered, and what “good alt text” means when a regulator is the one asking.

A note before we start: this is a practical overview, not legal advice. If you’re unsure whether the EAA applies to your business, talk to someone qualified in your member state.

Does the EAA actually require alt text?

The European Accessibility Act, formally Directive (EU) 2019/882, has applied since 28 June 2025.

The Act doesn’t tell website owners to add an alt attribute to every <img> element. Legislation that names HTML attributes ages badly, so it does something broader instead, and broader here means more demanding, not less.

For services covered by the Act, Annex I requires that non-textual content is accompanied by an alternative presentation, and that websites and mobile services are perceivable, operable, understandable and robust.

Annex II makes the intent clearer still: as an example of how a website can meet the requirement, the directive specifically mentions providing text descriptions of pictures.

For an informative image on a web page, the standard HTML way to provide that is alt text.

That’s where WCAG becomes useful. Success criterion 1.1.1, Non-text Content, requires a text alternative that serves an equivalent purpose: a meaningful description for informative images, an accessible name for functional ones, and for decorative images the opposite, they should be ignored by assistive technology, which in HTML usually means alt=””.

So the practical answer is this:

If your site is covered by the EAA, your meaningful images need text alternatives. The Act doesn’t name the HTML alt attribute, but alt text is how you provide them on a web page, which is why “add alt text” is the correct practical instruction, even though the law never uses the phrase.

Where EN 301 549 fits

EN 301 549 is the European accessibility standard for ICT, and the document most compliance articles point to. Its status is worth being precise about, because a lot of what you’ll read online isn’t.

The version currently harmonised, v3.2.1, was prepared for the Web Accessibility Directive, the law covering public sector websites, and incorporates WCAG 2.1 for web content. For the European Accessibility Act, a revision is still being finalised: v4.1.0 entered final deliverable voting in June 2026, aligning the web requirements with WCAG 2.2. Once a harmonised standard is cited in the Official Journal of the European Union, conformity with the relevant parts can provide a presumption of conformity with the Act.

In practice: EN 301 549 remains an important technical reference, but the EAA-aligned version doesn’t yet carry that formal status. Covered service providers still need to meet the accessibility requirements implemented in the member states where they operate.

Who the EAA actually applies to

This is the part worth checking before you panic or relax.

The EAA is not a blanket “all websites in Europe” law. It covers specific categories of products and services sold to consumers in the EU:

• E-commerce (any site selling goods or services to consumers)
• Consumer banking and payment services
• E-books and e-readers
• Electronic communications services
• Transport ticketing, information and booking
• Services providing access to audiovisual media services
• Consumer hardware such as computers, smartphones, ATMs and self-service terminals

Two things surprise people here.

One: e-commerce is broad. If your WordPress site takes orders from EU consumers, it’s an e-commerce service — a WooCommerce store with 4,000 SKUs or a single checkout page for a course.

Two: being based outside the EU doesn’t automatically put you outside the EAA. A business in the US, UK or elsewhere can still fall within scope when it provides a covered service to EU consumers. If that’s you, check the implementing rules where you operate.

A brochure site with no transactions, bookings or account area is a different conversation. But before concluding you’re out of scope, check whether anything on the site starts a purchase.

Who is exempt, and why the exemption is narrower than it looks

There is a microenterprise exemption: businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million are exempt from the accessibility requirements for services.

Three caveats that matter:

• It covers services, not products. A small company manufacturing or distributing covered hardware doesn’t get the same treatment.
• It disappears once your business no longer meets the definition of a microenterprise.
• It’s an exemption from the EAA, not from every national accessibility obligation.

The other route is the disproportionate burden exception, which is not a checkbox. It requires a documented assessment, kept as evidence and repeated at least every five years — and the directive closes the obvious loophole directly: a lack of priority, time or knowledge is not a legitimate reason.

What a text alternative actually means

“Add alt text to every image” is the version most people have heard. It’s close, but wrong in a way that causes real problems.

The actual requirement is a text alternative serving an equivalent purpose, which depends on what the image is doing.

Informative images — product photos, diagrams, screenshots — need a description of what they convey. Not a pixel-by-pixel inventory, but what a sighted reader takes from them. Good alt text also has benefits beyond accessibility: we covered its role in how AI systems interpret and surface images separately.

Decorative images — background textures, dividers, abstract shapes — should have an empty alt attribute (alt=””) so assistive technology skips them. Describing them only adds noise.

Functional images — a logo that links home, a magnifying glass that submits a search, an icon button — need an accessible name describing the action, not the picture. The alt for a cart icon that opens your basket is “View cart,” not “shopping cart icon.”

Images of text — such as sale terms baked into a banner — need the same information in text. Better still, avoid images of text where possible.

Complex images — charts and infographics — usually need a short alt plus a longer description elsewhere on the page.

The test isn’t “is there an alt attribute?” It’s “if I removed the image and left only the alt text, would the page still make sense?”

Automated tools can tell you whether alt text exists. Deciding whether it serves the image’s purpose requires context, and a proper accessibility review looks beyond whether the field is filled in.

Working with a Media Library full of missing ALT text?

Nobody wants to write descriptions for 4,000 images by hand, which is where most teams stall.

The ShortPixel AI Alt Text Generator analyses each image and writes descriptive ALT text, in bulk across your existing library or automatically on upload. It has a preview mode, keeps anything you’ve already written, supports WooCommerce galleries, and can use your site or parent page as context. The same capability is built into ShortPixel Image Optimizer as AI Image SEO, alongside compression, WebP and AVIF conversion and CDN delivery.

Generation clears the backlog in an afternoon. After that it’s a review pass: mark the decorative images as decorative, and check your most important pages.

The five alt text mistakes we see most on WordPress sites

1. Filename alt text. alt=”IMG_4823″ or alt=”dsc-0091-1-scaled”. A filename is not a meaningful alternative, and it may be announced by assistive technology without telling the user anything useful about the image.

2. Alt text on decorative images. Especially in page builders, where every background and separator arrives with something in the field. Empty is correct here.

3. “Image of…” and “Photo of…” Screen readers already announce that it’s an image, so you’re adding a word every user hears on every image.

4. Product galleries where every photo shares the same alt. Front, back, detail and lifestyle shots each carry different information. “Blue running shoe” five times tells a screen reader user nothing about the difference.

5. Missing alt on the images that matter most. Hero images, logos and images inside checkout flows are usually built into templates rather than added through the Media Library, so they’re easy to miss in an audit — and on an e-commerce site, they sit in your most important user journeys.

What the EAA does not require

Worth being clear about, because compliance anxiety sells a lot of unnecessary products. The EAA does not require an accessibility overlay or a paid certification, and overlays don’t produce conformance on their own.

What covered service providers do need to publish is information about how their service meets the accessibility requirements, in their terms and conditions or an equivalent document.

A practical checklist

If your WordPress site is in scope, here’s a realistic order of work for the image side:

1. Audit what’s there. Run an automated scan to find missing and empty alt attributes across the site. This gives you volume, not quality.
2. Fix templates first. Header logo, hero images, cart and account icons, checkout imagery. Fewest items, highest impact.
3. Clear the Media Library backlog. Start with your highest-traffic pages, product pages and conversion-critical flows rather than the oldest upload. For libraries with hundreds or thousands of images, bulk generation with the ShortPixel AI Alt Text Generator, or the AI Image SEO feature in ShortPixel Image Optimizer, turns weeks of manual work into a review pass.
4. Set the decorative ones to empty alt rather than deleting the attribute.
5. Fix the pattern, not just the backlog. If images arrive with filename-based alt text, that process will refill the backlog in six months. Generating ALT text automatically on upload closes that gap.
6. Check the images of text. Sale banners, pricing graphics, infographics. These are the ones that fail hardest.
7. Document how your service meets the accessibility requirements. The EAA requires covered service providers to make this information public, in their terms and conditions or an equivalent document.
8. Write it into your publishing workflow so new content ships accessible.

None of this is glamorous. All of it is cheaper than the alternative.

What happens if you ignore it

Enforcement is national. Each member state designates its own authorities and sets its own penalties, which have to be effective, proportionate and dissuasive, alongside measures that bring the service back into compliance. The figure that matters is the one in your national implementing law, not any number quoted in an article like this one.

In practice the sequence starts earlier and quieter: a user complaint, a request for information, a required corrective action plan.

And there’s the part that has nothing to do with regulators. Tens of millions of people in the EU live with some form of disability. A product image with no useful alternative makes a product harder to evaluate, and a checkout that can’t be navigated is a sale that doesn’t happen.

What’s changing next

The technical standard behind European digital accessibility is changing.

EN 301 549 v4.1.0 is currently being finalised, updating its web requirements to WCAG 2.2 and supporting the European Accessibility Act.

For alt text, little changes. WCAG 2.2 keeps success criterion 1.1.1 Non-text Content, a Level A requirement that has existed since WCAG 2.0.

Alt text isn’t a new idea created by the EAA. The Act simply gives an established accessibility practice greater legal significance.

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