• Jun 28, 2025: European Accessibility Act (EAA) took effect — alt text mandatory for B2C shops
• Aug 2025: First cease-and-desist wave in Germany (~€595/letter)
• Nov 2025: First EAA lawsuits in France (Auchan, Carrefour, E.Leclerc, Picard)
• Jan 2026: Market surveillance authorities begin active audits
• Mar 2026: EU Commission reprimands Germany for incomplete EAA implementation
1. The Legal Framework: EAA, WCAG, ADA & More
The requirement to provide alt text for images doesn’t come from a single law — it emerges from multiple regulations working at different levels. Here are the four relevant layers:
WCAG 2.1 Level AA — The Technical Standard
The Web Content Accessibility Guidelines (WCAG) by W3C are the globally recognized standard for web accessibility. Success Criterion 1.1.1 “Non-text Content” requires: “All non-text content that is presented to the user has a text alternative that serves the equivalent purpose.”
In practice: every informative image needs alt text. Decorative images need an empty alt attribute (alt=””). Images without any alt attribute are a violation.
🇬🇧 301 549 — The European Standard
The harmonized European standard EN 301 549 references WCAG 2.1 and is the technical standard that the EAA points to. It defines how accessibility requirements for ICT products and services must be implemented.
🇪🇺 EAA (European Accessibility Act) — The EU Directive
Directive (EU) 2019/882 requires all EU member states to implement accessibility requirements for certain products and services into national law. Each country has its own penalty framework.
As of March 2026: The EU Commission has reprimanded Germany and Croatia for incomplete implementation. Both face European Court of Justice proceedings.
🇩🇪 National Implementation — Germany (BFSG) as Example
Germany implemented the EAA through the Barrierefreiheitsstärkungsgesetz (BFSG). In effect since June 28, 2025. Applies to all businesses offering digital services to consumers. Similar national laws exist across all 27 EU member states.
In parallel, the Americans with Disabilities Act (ADA) applies to all businesses with US customers. Violations are enforced through private lawsuits — over 4,500 in 2024, with average settlements of $25,000+.
In summary: The alt text requirement flows from WCAG 1.1.1 → adopted via EN 301 549 into the EAA → implemented into national law (e.g. Germany’s BFSG) → enforced via fines + lawsuits. It’s no longer a “nice-to-have” — it’s an enforceable legal obligation.
2. Who's Affected? (And Who's Exempt)
Directly affected (EAA-mandatory):
✓ Online shops (B2C) — Any store selling to end consumers
✓ Booking & reservation platforms — Hotels, flights, events
✓ Banking & financial services — Online banking, insurance
✓ Telecommunications — Mobile, internet providers
✓ Streaming & media — Video platforms, e-readers, e-books
✓ Passenger transport — Rail, coach, airlines (digital services)
Exempt (with caveats):
- Micro-enterprises — under 10 employees AND under €2M annual revenue
- Pure B2B providers — only if demonstrably targeting businesses exclusively
- Existing contracts — service contracts signed before June 28, 2025 (transition period until June 27, 2030)
Important: The micro-enterprise exemption only protects against the EAA itself. Competitors can still file unfair competition claims. All they need is an automated scan of your website — missing alt text is detectable in seconds.
Mixed B2B/B2C shops: The gray area
Many shops sell to both businesses and consumers. As soon as any part of your offering targets consumers, the EAA applies to that part. In practice: if a private customer can order from you, you’re covered. Cleanest solution: make the entire shop accessible.
3. What Exactly Is Required? WCAG 1.1.1 Explained
The EAA technically refers to WCAG 2.1 Level AA. For alt text, Success Criterion 1.1.1 “Non-text Content” is the key requirement. It distinguishes several cases:
| Image Type | Requirement | Example |
|---|---|---|
| Informative image | Descriptive alt text (80-125 chars) | Product photos, infographics, content images |
| Decorative image | Empty alt attribute: alt="" | Backgrounds, dividers, atmospheric icons |
| Linked image | Alt text describes the link target | Product image → product page, logo → homepage |
| Image with text | Text in image must be reproduced in alt text | Banners, infographics, screenshots with text |
| Complex image | Short alt text + detailed description in surrounding text | Charts, diagrams, technical drawings |
Image WITHOUT alt attribute | WCAG violation → EAA violation | Screen reader reads filename or skips entirely |
Especially relevant for online shops: All product images — main image, gallery images, variation images — must have descriptive alt text. Color swatch images need text labels. The entire purchase flow must be accessible.
→ Full guide: What Is Alt Text? 10 Rules + Examples
4. Consequences of Non-Compliance: Fines, Lawsuits, Cease-and-Desist
Consequences for missing alt text come from three different directions — simultaneously:
Market surveillance authorities can impose fines based on the severity, duration, and recurrence of violations.
Up to €1,000,000
Spain — highest in the EU
Up to €100,000
Germany — per violation
Additionally possible: sales bans — non-compliant products or services may no longer be offered.
EAA violations can be classified as unfair competition. Competitors, consumer protection associations, and specialized law firms can send cease-and-desist letters — regardless of the micro-enterprise exemption.
~€595 per letter
Documented cost of the German cease-and-desist wave (since Aug 2025)
Plus: binding declaration to cease with contractual penalty for recurrence. Plus: your own legal defense costs.
🇺🇸 USA: 4,500+ ADA lawsuits in 2024, average settlement $25,000+
🇫🇷 France: Auchan, Carrefour, E.Leclerc, Picard sued (Nov 2025)
🇪🇸 Spain: Fines up to €1,000,000
🇳🇱 Netherlands: Up to €900,000 or 10% of annual revenue
→ Full EAA fine schedule for 12 EU countries
5. The 2025/2026 Enforcement Wave: What's Happened So Far
What caught many businesses off guard: the first wave of enforcement didn’t come from government agencies, but from specialized law firms. Since August 2025, the German firm CLAIM RA GmbH has been systematically sending cease-and-desist letters to online shops for EAA violations.
Why alt text is particularly targeted: Missing alt text can be detected fully automatically. A simple scan with tools like WAVE, axe, or Lighthouse reveals in seconds whether an image has an alt attribute. No manual review needed, no subjective judgment. This makes missing alt text the “low-hanging fruit” for enforcement — easy to prove, infinitely scalable.
In contrast, other accessibility violations (keyboard navigation, color contrast, form accessibility) are harder to detect automatically and often require manual testing. Alt text is the most obvious and easily exploitable violation.
The irony: Adding alt text is simultaneously one of the cheapest and fastest accessibility measures. While a full WCAG audit and rebuild takes weeks and costs thousands, alt text can be AI-generated in minutes. There’s hardly a worse reason to receive a cease-and-desist than missing alt text.
6. Active Enforcement Since January 2026
Since January 2026, market surveillance authorities have begun actively auditing EAA compliance. Audits can be announced or unannounced. Businesses must be able to present the following documentation:
📋 Technical documentation
Description of the digital offering, applied standards (EN 301 549), conducted audits and their results.
📢 Accessibility statement
Publicly accessible (e.g. in the footer). Contains: conformance status, known limitations, feedback contact, date of last audit, standard used.
🔍 Documented measures
Documentation of which images have alt text, when they were created/updated, which tool was used. An AI tool like AutoAlt.ai provides a processing history that serves as compliance evidence.
Important: Even without an active audit, you must be able to produce this documentation at any time. The surveillance authority can request records at any point.
7. Alt Text Compliance Checklist for Your Shop
Check these 10 points to determine if your shop meets the alt text requirement:
All product images (main + gallery + variations) have descriptive alt text with product name
Category images have alt text with category name
No image without alt attribute — decorative images have alt=""
Banners and promotional images with text → text reproduced in alt text
Logo has alt text with company name (e.g. “AutoAlt.ai Logo”)
Functional icons (cart, search, menu) have descriptive alt text or ARIA labels
Alt text under 125 characters — short and descriptive
No keyword stuffing — alt text reads like natural sentences
Accessibility statement published in footer
Technical documentation created and archived
Quick check: Open your website in Chrome → F12 → Lighthouse → Accessibility. The report instantly shows missing alt text. Or use the free AutoAlt.ai Accessibility Scanner.
8. Comply in 24 Hours: The Fast Track
You’ve been putting this off and want to comply as fast as possible? Here’s the most realistic path — tested and proven:
Run a Lighthouse Accessibility scan on your 10 most important pages (homepage, top products, categories, checkout). Count images without alt text. For most shops: 60-80% are missing.
Install AutoAlt.ai for WordPress/WooCommerce or for Shopware. Create account (50 credits/month free), API key is set automatically. Takes 2-5 minutes.
Launch the Bulk Alt Text Generator for your entire media library. The plugin processes images in the background without affecting shop performance. 1,000 images ≈ 30-60 minutes. 5,000 images ≈ overnight.
Review 20-30 generated alt texts. Do product names match? Are descriptions accurate? Edits cost no credits.
Create an accessibility statement and link it in your footer (next to Privacy Policy and Legal Notice). Contents: conformance status, known limitations, feedback contact, date.
All images have alt text, the processing history serves as documentation, the accessibility statement is published. You’re covered for the alt text portion of the EAA — the most common enforcement target is eliminated.
Get compliant — before the next cease-and-desist arrives
AutoAlt.ai generates EAA-compliant alt text via AI. Plugin for WordPress, WooCommerce, Shopware, Joomla, and Drupal. 50 credits/month permanently free.
9. Frequently Asked Questions
Is alt text legally required since 2025?
Yes. Since June 28, 2025, the European Accessibility Act mandates that all B2C digital services be accessible. Alt text for informative images is one of the most fundamental requirements (WCAG 2.1, Criterion 1.1.1). The requirement applies EU-wide. In the US, the ADA applies separately.
What penalties exist for missing alt text?
Three parallel risks: Government fines up to €100,000 in Germany (up to €1M in Spain). Competitor cease-and-desist letters (~€595 each plus binding declaration). In the US: ADA lawsuits averaging $25,000+ in settlements.
Is my small online shop also affected?
Micro-enterprises (under 10 employees AND under €2M revenue) are exempt from the EAA. However, unfair competition claims by competitors remain possible, as the exemption only applies to the EAA itself. Plus: alt text improves your SEO and costs almost nothing with AI tools.
Does an accessibility overlay like accessiBe suffice?
Overlay widgets are widely rejected by the disability community. The FTC fined accessiBe $1M because “100% WCAG-compliant” claims were misleading. Overlay alt text doesn’t appear in HTML source code and has zero SEO value. For real EAA compliance, you need real HTML alt attributes — like AutoAlt.ai generates.
How fast can I add alt text to all my images?
With AutoAlt.ai: install plugin (2 min), start bulk generator, done. 1,000 images in about 30-60 minutes, 5,000 images overnight. Manually: at 2-3 minutes per image, 1,000 images take 40-50 work hours. Hybrid approach: AI-generate, then manually review the 50-100 most important images.
Do I need an accessibility statement?
Yes. Every EAA-compliant website must publish an accessibility statement — easily findable (e.g. in the footer), itself accessible, with feedback contact. It must document the conformance status, list known limitations, and include the date of last audit.
Does the requirement apply to social media?
The EAA covers websites and apps — not social media posts directly. However, best practice recommends adding alt text on social platforms too. Instagram, Facebook, LinkedIn, and X all offer alt text fields. It improves reach and demonstrates commitment to accessibility.
How much does alt text compliance cost?
With AutoAlt.ai: 50 credits/month permanently free (= 50 images). For larger shops: Starter from $4.49/month (100 images) or Pro Credit Pack $45 one-time (1,000 images). For comparison: a single cease-and-desist costs €595+ plus legal fees. The AI solution pays for itself after the first avoided letter by a factor of 10.
Meet the Alt Text Requirement — In Minutes, Not Weeks
AutoAlt.ai generates EAA-compliant alt text via AI. Real HTML alt attributes, no overlay. Plugin for WordPress, WooCommerce, Shopware, Joomla, and Drupal.