EAA, BFSG & ADA:
Is your shop truly accessible?
In the EU, the Accessibility Strengthening Act (BFSG) implements the EAA. In the US, accessibility is addressed through the ADA (Title III). Missing alt text is among the most common violations in both regions.
Quick check: WCAG 1.1.1 (alt texts)
Our AI checks your homepage live for missing alt attributes and potential violations of WCAG 2.1 AA – as a technical basis for EAA/BFSG (EU) and ADA (USA).
Risk identified!
We found images on your website without alternative text descriptions. This violates the BFSG guidelines.
What is the BFSG and why does it affect every shop?
The European Accessibility Act (EAA) is an EU directive (2019/882) that aims to make the digital single market accessible to people with disabilities. In Germany, this directive was transposed into national law through the Accessibility Strengthening Act (BFSG).
Since June 28, 2025, operators of commercial websites and apps have been required to make their digital offerings accessible. This particularly affects the e-commerce sector. It is no longer a “nice-to-have,” but a strict legal requirement, comparable to the introduction of the GDPR.
| Type of company | engagement | Detail |
|---|---|---|
| Online-Shops (B2C) | Fully affected | The entire checkout process, product images, and navigation must be accessible. |
| Dienstleister | Fully affected | Banks, booking systems, passenger transport. |
| Kleinstunternehmen* | Exceptions possible | For services only. *Fewer than 10 employees AND less than €2 million in revenue. Note: Those who sell products often still fall under this law. |
WCAG 2.1 Compliance: The Problem with Images
The law technically refers to the European standard EN 301 549, which in turn is based on the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. A key aspect is the principle of “perceivability”.
"All non-text content presented to the user must have a text alternative that serves the same purpose."
For online shops, this means: Every product image must have alt text (alternative text). This text is read aloud by screen readers so that blind people can understand what is shown in the image (e.g., color, shape, function of the product). File names like [example of a specific file name] IMG_2025.jpgare a clear violation.
Does this also apply to the USA? (ADA & WCAG)
Yes. Digital accessibility is also legally relevant for many companies in the USA. The basis is the Americans with Disabilities Act (ADA) , in particular Title III , which applies to publicly accessible offerings – including online shops, SaaS platforms and company websites.
Although the ADA does not define a single technical standard, WCAG 2.1 Level AA is frequently used in practice as a reference for digital accessibility. Those who comply with WCAG typically reduce the risk in both jurisdictions.
| REGION | LAW | TECHNICAL STANDARD | RELEVANCE FOR IMAGES |
|---|---|---|---|
| EU | EAA / BFSG | EN 301 549 → WCAG 2.1 AA | Alt text is mandatory |
| USA | ADA (TITLE III) | WCAG 2.1 AA (frequent reference) | Alt texts are legally enforceable |
Missing alt text is a clear WCAG violation and therefore a common risk in both the EU (EAA/BFSG) and the USA (ADA) – especially in e-commerce with many product images.
- ❌ No alt attribute present
- ❌ Alt="Image" or Alt="Placeholder"
- ❌ Alt="Buy red shoes cheap offer" (Keyword Stuffing)
- ❌ Alt="DSC00923.jpg"
- ✅ Precise description of the visual content
- ✅ "Dark red running shoe with white laces and profiled sole, side view"
- ✅ Neutral tone, max. 120 characters
- ✅ Context-related (product vs. decoration)
What are the potential consequences?
Failure to comply with the German Federal Disability Equality Act (BFSG) is a legal violation with far-reaching consequences. In the USA, inadequate accessibility (ADA) can also lead to legal risks.
Market surveillance authorities can impose fines of up to 100,000 euro if products or services are not offered in an accessible manner.
Competitors and consumer protection associations can now send out costly cease-and-desist letters (UWG) due to a violation of market conduct rules.
In cases of serious deficiencies, the authorities can order the online shop to be taken offline or sales to be stopped until the barriers are removed.
Compliance on autopilot.
AutoAlt.ai was specifically developed to bridge the gap between technical feasibility and legal requirements – with WCAG as its technical foundation for EU (EAA/BFSG) and USA (ADA).
- AI image analysis: Recognizes objects, colors, and context more precisely than a human.
- Legally compliant texts: Formulated neutrally and descriptively in accordance with WCAG guidelines.
- Bulk Processing: Repairs thousands of images in your media library overnight.
Frequently Asked Questions
Yes – as soon as you offer B2C and your website/app is intended for consumers (e.g., online shop, booking, checkout, customer account). Since June 28, 2025, accessibility has been mandatory in the EU for many digital services. The decisive factor is not your CMS, but whether users can operate your processes without barriers.
In practice: often yes, if you serve EU customers and offer your services/products in the EU. The EAA obligations apply throughout Europe via national implementations (e.g., BFSG in Germany). If you generate EU sales, you should set WCAG compliance as standard.
Many US companies treat accessibility as an obligation under ADA (Title III), especially for publicly accessible offerings such as online shops, SaaS, or booking platforms. Although the ADA does not specify a single technical standard, WCAG 2.1 AA is often used as a reference. WCAG is therefore the common denominator for the EU and the US.
Missing or poor alt text. This falls under WCAG 1.1.1 (non-text content) and is extremely easy to check (manually and automatically). Especially in e-commerce with many product images, this is one of the most common and visible violations.
No—but every relevant image needs a suitable text alternative.
Product images, icons with meaning, infographics: alt text required.
Purely decorative images: correctly marked as decorative (e.g., alt=””).
Important: “Decorative” must not be used as an excuse for important content.
Yes, if they comply with WCAG guidelines: neutral, precise, context-related, and not misleading. Generic texts (“image,” “photo”), incorrect descriptions, or keyword stuffing are problematic. AutoAlt.ai is designed to generate and manage descriptive, WCAG-oriented alternative texts.
Alt texts should be as short as possible and as informative as necessary. For product images, 80–140 characters often work well. The key factors are: purpose + relevant visual characteristics (e.g., color, model, view, function).
Unfortunately, no. A theme can only provide the technical basis. The most common problems arise in the content: images without alt text, poor link texts, missing labels, illogical headings, PDFs without structure. Operators are responsible for content—especially in product catalogs.
If old content is actively used (e.g., product pages, checkout, booking, support knowledge), it should be accessible. In e-commerce, old product images are often still relevant to purchases—so this is practically always an issue.
In the EU, this can result in official measures, fines, and/or warnings (depending on the country). In the US, a lack of accessibility can lead to legal disputes. Regardless of this, accessibility bugs often cause a loss of revenue (abortions during checkout) and damage to reputation.
AutoAlt.ai can cover a large, critical part: images & media text alternatives (WCAG 1.1.1) including bulk fixes and monitoring. Full compliance also includes topics such as keyboard operation, contrast, focus, form labels, error messages, PDFs, video captions, etc. AutoAlt.ai is a powerful compliance tool, but it does not replace a complete accessibility check of the entire UX.
- Scan domain (quick check)
- Fix missing/incorrect alt texts (bulk)
- Activate regular checks (new images)
- Export reports (internal/agency/compliance)
