The European Accessibility Act has been in force since June 28, 2025. We’ve covered all the background, deadlines, and affected businesses in our complete EAA 2025 guide. This article is the practical counterpart: a checklist to systematically work through the image portion of your compliance.
Why images, of all things? Because missing alt text is the most easily provable barrier there is. Anyone – including a plaintiff’s attorney – can check within seconds via source code or a scan tool whether your images have alt attributes. And in typical stores, most of them don’t.
1. The legal situation in 3 minutes
| Region | Law | Risk |
|---|---|---|
 EU | European Accessibility Act (EAA) | Fines up to €100,000 (Germany), cease-and-desist risk |
 USA | Americans with Disabilities Act (ADA) | 4,500+ website lawsuits in 2024 alone |
 Global | WCAG 2.1 Level AA | The technical standard behind both laws |
Important: the EAA applies to stores that sell into the EU – regardless of where they’re hosted or where the company is based. For a country-by-country breakdown of specific penalties, see the EAA fines catalog.
2. What the law actually requires for images
Plenty of myths circulate here – and they either cost stores unnecessary work or lull them into false security. The actual requirement is precise:
The one relevant requirement: WCAG 2.1 AA, success criterion 1.1.1
Every informative image needs a text alternative – the alt attribute in HTML. Period.
Not required: title attributes (they have no value for screen readers), captions, or descriptive file names.
Not mandated: a specific creation process. The law doesn’t regulate whether alt text is written manually or AI-assisted – it requires a compliant outcome.
And a second clarification that’s often overlooked: decorative images (dividers, background ornaments, purely ornamental elements) don’t need descriptive text – but they do need an empty alt attribute (alt=""). If the attribute is missing entirely, many screen readers read out the file name. That’s both a violation and a miserable user experience.
3. The 10-point checklist
Get the full picture: how many images does your store have in total, and how many lack an alt attribute? An automated scan delivers the numbers in minutes – for example the free accessibility scan. No inventory, no prioritization.
The most important category: every main product image needs descriptive alt text that names the product specifically – material, color, shape, series. Generic texts like “product image” don’t substantively meet the requirement.
Additional views (back, detail, lifestyle scene) are the most commonly forgotten in manual workflows. Each view needs its own alt text describing what that view shows – not the same text pasted five times.
Color, size, and material variants have their own images – and need their own alt texts. “Sneaker Model X in navy blue” and “Sneaker Model X in white” are two different descriptions. Copy-pasted alt text across all variants is a classic gap.
Category headers, homepage banners, content blocks (e.g. Shopware Shopping Experiences, WooCommerce blocks): these images live outside the product catalog and slip through catalog-focused audits. Informative banners (say, with promotional text inside the image) need alt text that conveys the information.
Purely ornamental images get an empty alt="" – not a missing attribute, not invented text. Screen readers then skip the element cleanly, and you avoid “noise” for assistive technology users.
An existing attribute isn’t automatically compliant. Check samples for three failure patterns: file names as alt text (IMG_4823.jpg), keyword stuffing, and meaningless placeholders. Our guide on writing alt text shows what good looks like.
The EAA applies in every EU target market. If you sell in French, you need French alt text – a German alt text in the French channel doesn’t help screen reader users there. Check each language version separately.
Compliance isn’t a one-off project. Define how new product images get their alt text from now on – ideally automatically on upload, so the gap doesn’t immediately reopen.
Record when you checked and fixed what (scan reports, coverage rates, dates). In the event of a complaint or audit, documentation shows you’re working on compliance systematically – which beats any ad-hoc excuse.
4. Implementation in your store platform
The checklist is platform-neutral – but the hands-on steps differ by system. Here’s where to find and maintain alt text in the four most common store platforms:
WordPress
Alt text lives in the Media Library: click an image → “Alternative Text” field. Worth knowing: alt text is stored per media library entry – changing it there affects new insertions, while alt text already set inside a post can differ. For existing content, check both. With hundreds of images, there’s no way around a bulk solution – the AutoAlt.ai plugin for WordPress page shows how that works.
WooCommerce
WooCommerce uses the WordPress Media Library but spreads product images across three places: main image, product gallery, and variation images. Variation images in particular (checklist item 4) are regularly missed in manual workflows because they sit inside the product’s variations view. The WooCommerce integration covers all three image types.
Shopware 6
You maintain alt text in the media section or directly on the product – and crucially, per language: with multiple sales channels in different languages, every language version needs its own alt text (checklist item 8). Also check: images inside Shopping Experiences, which live outside the product catalog. For existing catalogs, bulk processing is available via the Shopware plugin – full walkthrough: 10,000 images in bulk.
Shopify
On the product: open media → click the image → “Edit alt text”. Don’t forget: theme images (sliders, banners, collection headers) are maintained separately in the theme editor and are the most common omission in product-centric audits. Details on the automated route on the Shopify app page.
Using a different system? AutoAlt.ai offers native integrations for eight platforms in total – beyond the four above, also Magento, Joomla, Drupal, and PrestaShop – plus a developer API for custom builds.
5. Prioritization: where to start
With thousands of images, sequence matters. Prioritizing by visibility and risk has proven effective:
- First: homepage, top categories, and your most-visited product pages – this is where auditors, customers, and crawlers look first.
- Then: the rest of the active product catalog, including variants and galleries.
- Last: archived content, discontinued products, blog history.
The double effect
This prioritization is identical to SEO prioritization: the pages with the most traffic also benefit most from indexable alt text in Google Image Search. Compliance work and visibility work are the same work here.
6. Test it yourself in 5 minutes
You don’t need an audit budget for a first assessment – three checks deliver an honest picture within minutes:
- Browser console (30 seconds): Open a product page, press F12, and enter in the console:
document.querySelectorAll('img:not([alt])').length– this counts all images completely missing thealtattribute. Withdocument.querySelectorAll('img[alt=""]').lengthyou additionally see the empty attributes (correct for decorative images, but an error on product images). - Screen reader spot check: On Mac, the built-in VoiceOver is enough (Cmd+F5); on Windows, the free NVDA. Navigate through a product page and listen to what’s announced for the images. If you hear file names like “IMG-4823-final-v2-jpg”, you know where you stand.
- Automated scan: For a view across the whole store instead of individual pages: the free accessibility scan crawls your pages and delivers the breakdown of where and how many alt texts are missing.
These self-tests don’t replace a full WCAG audit across all success criteria – but for the image portion, the most common and most visible gap, they’re entirely sufficient to identify where action is needed.
7. Manual vs. automated
For execution, the same math applies as with any catalog project: manual writing costs 2–3 minutes per image and doesn’t scale beyond a few hundred images. AI-assisted generation processes existing catalogs in bulk and handles new uploads automatically – with AutoAlt.ai on EU servers in Germany, with zero image storage and GDPR compliance built in. For a concrete walkthrough of a full bulk run, see our step-by-step guide on adding alt text to 10,000 Shopware images – the principle applies equally to WooCommerce, Shopify, and the other integrations.
Legally, the point from section 2 remains decisive: the law prescribes no creation process. Whatever accurately describes the image content is compliant – the quality of the outcome counts, not the method.
8. What happens after a complaint
The EAA isn’t a toothless law with an abstract fine range – it has a concrete enforcement mechanism, and it typically starts not with the authority, but with a single user:
- Step 1 – Complaint: Consumers and recognized associations can complain to the competent market surveillance authority and request action. In Germany, the central market surveillance body for accessibility (MLBF) coordinates supervision; other EU member states have designated their own authorities.
- Step 2 – Review: The authority checks the conformity of the service. Missing alt text is the most quickly and objectively verifiable defect – one look at the source code suffices.
- Step 3 – Order with deadline: If defects are found, the first step is an order to remove the barriers within a set deadline. Anyone already working systematically and documenting it (checklist item 10) has a clear advantage here.
- Step 4 – Sanctions: If remediation fails to happen, fines follow – up to €100,000 in Germany – and as the final escalation stage, the authority can demand that the service be discontinued. In parallel, there’s the civil risk of cease-and-desist letters, and for US-facing stores, ADA litigation.
The practical consequence: the authority doesn’t appear out of nowhere – but a single frustrated screen reader user can set the process in motion. And unlike many WCAG criteria, missing alt text leaves no room for interpretation to hide behind. For fine levels in other EU countries, see the EAA fines catalog.
9. FAQ
Do decorative images need alt text?
Yes and no: they need an empty alt attribute (alt=””). This tells screen readers to skip the image. A completely missing alt attribute, however, is a WCAG violation, because screen readers then often read out the file name.
Does the EAA also require title attributes or captions?
No. For images, the EAA requires exclusively a text alternative via WCAG 2.1 AA (SC 1.1.1) – the alt attribute. Title attributes have no value for screen readers or compliance; captions and file names are not required.
Can alt text be AI-generated and still be EAA-compliant?
Yes. The law requires a compliant outcome, not a specific creation process. What matters is that the alt text accurately describes the image content – whether written by hand or AI-assisted.
What penalties apply for missing alt text?
In Germany, the national EAA implementation (BFSG) provides for fines of up to €100,000, plus the risk of cease-and-desist letters. For US-facing stores: there were over 4,500 ADA website lawsuits in 2024. See the EAA fines catalog for a country-by-country breakdown.
Does the EAA apply to small online stores?
The EAA generally applies to e-commerce services in the EU. Microenterprises (fewer than 10 employees and under €2 million annual turnover) are partially exempt for services – when in doubt, the exact classification should be checked legally.
Checklist item #1: done in 2 minutes.
The free accessibility scan checks your store and shows how many images are live without alt text – including a page-level breakdown.