The European Accessibility Act and images: what’s actually required

Not legal advice. This is a plain-English summary of public sources as of 7 October 2026. The EAA is a directive implemented through 27 national laws that differ in detail. If you need to know whether and how it applies to your business, ask a lawyer familiar with the countries you sell into.

The European Accessibility Act (EAA) has applied since 28 June 2025. Since then plenty of vendors have advertised “EAA-compliant alt text”, which isn’t a meaningful claim. This guide sets out what the law actually says about images, who it covers, which technical standard applies, and what early enforcement looks like.

The basics

• What it is: Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex).
• When: Member States had to adopt national laws by 28 June 2022 and apply them from 28 June 2025 (Art. 31).
• How: as a directive, it works through national laws: Germany’s BFSG, for example (Bundesregierung). Transposition hasn’t been smooth. The European Commission has sent reasoned opinions to several Member States for incomplete transposition (AccessibleEU, Mar 2025; Cyprus News Gazette, Jan 2026).

Who’s covered

The EAA covers specific products (computers, smartphones, self-service terminals, e-readers and more) and specific services, including consumer banking, e-books, electronic communications, parts of passenger transport, and e-commerce services (Art. 2) (European Commission overview).

“E-commerce services” means “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract” (Art. 3(30)). In practice: online shops selling to consumers, and the e-commerce parts of other consumer websites and apps.

The microenterprise exemption

“Microenterprises providing services shall be exempt from complying with the accessibility requirements” for services (Art. 4(5)). A microenterprise is an enterprise that “employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million” (Art. 3(23)).

Notes: - Both parts matter. Fewer than 10 staff and small turnover (or balance sheet). A five-person shop with €3 million turnover and a €3 million balance sheet isn’t a microenterprise. - It’s for services. Germany’s federal accessibility office points out that microenterprises that place products on the market are still covered for those products (Bundesfachstelle Barrierefreiheit FAQ). - National wording varies. The Dutch regulator, for example, summarises the obligation as applying to companies with “ten or more employees and/or an annual turnover of more than 2 million euros” (ACM). Check the law of each country you sell into.

Exempt or not, accessible product images are still better for customers and for search.

What the EAA says that touches images

The Directive doesn’t mention “alt text” by name. It sets functional requirements in Annex I. For services generally (Section III), it requires, among other things:

• providing information about the service while “supplementing any non-textual content with an alternative presentation of that content” (Annex I, Section III(b)(vi)), and
• “making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust” (Section III(c)).

For e-commerce specifically (Section IV(g)):

• “providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator”;
• “ensuring the accessibility of the functionality for identification, security and payment… by making it perceivable, operable, understandable and robust”;
• “providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust.”

“Perceivable, operable, understandable and robust” are the four principles of WCAG. Text alternatives for images sit under perceivable. That’s where WCAG Success Criterion 1.1.1 Non-text Content comes in (our explainer).

Which technical standard?

The EAA lets companies show conformity through harmonised standards published in the Official Journal (Art. 15). The relevant one is EN 301 549.

• EN 301 549 V3.2.1 (2021) is based on WCAG 2.1 Level AA for web content and is the version currently cited.
• EN 301 549 V4.1.1 was published in September 2026. It adopts WCAG 2.2 and adds an annex mapping the standard to the EAA. AccessibleEU says that “until the European Commission formally cites EN 301 549 v4.1.1 in the Official Journal of the European Union, the current reference remains EN 301 549 v3.2.1” (AccessibleEU, 7 Sep 2026). ETSI’s project schedule targets 30 November 2026 for citation, which commentators describe as provisional (Pivotal Accessibility).

For images, nothing changes between the two: SC 1.1.1 is identical in WCAG 2.1 and 2.2.

Exceptions and transitional rules worth knowing

• Content exclusions (Art. 2(4)): for example pre-recorded time-based media and office files published before 28 June 2025, online maps (if navigational information is provided accessibly), third-party content that is neither funded, developed by, nor under the control of the operator, and archived content. User-uploaded marketplace photos may fall under the third-party exclusion. Your own product photos do not.
• Disproportionate burden / fundamental alteration (Art. 14): requirements apply only to the extent they don’t fundamentally alter the service or impose a disproportionate burden. You must carry out and document that assessment and keep it for five years. Adding alt text to your own product images is hard to argue is disproportionate.
• Transitional period (Art. 32): services may keep using products lawfully used before 28 June 2025 until 28 June 2030, and pre-existing service contracts may continue until they expire, for no more than five years. This is about products used to deliver services and contracts, not a grace period for your website’s content.
• Information duty (Annex V): service providers must describe how the service meets the accessibility requirements, typically in an accessibility statement or the terms and conditions.

What enforcement looks like so far

Enforcement is national and has started at different speeds:

• Germany: the market surveillance authority (MLBF) began operating on 26 September 2025. Fines under the BFSG can reach €100,000 (Taylor Wessing, Jun 2026).
• Netherlands: the ACM tested about 100 of the largest Dutch online stores and found that on 61% it was impossible to place an order using assistive technology (ACM, 24 Mar 2026).
• Sweden: the regulator began reviewing e-commerce providers in October 2025, focusing on the homepage, product page and search function (Taylor Wessing, Mar 2026).
• France: in an interim ruling on 4 June 2026, the Judicial Court of Caen found Carrefour’s online grocery site and app insufficiently accessible. It cited barriers including “missing or inadequate alternative texts for images”, and ordered conformity within six months, subject to €500 per day (Taylor Wessing, Jun 2026).

Inference: alt text is concrete, visible and easy to test, so it shows up early in audits and complaints. That doesn’t make it the most important requirement. The Dutch findings were about being unable to complete an order, which is mainly forms, buttons, keyboard access and CAPTCHAs.

What this means for your images, practically

1. Every informative image needs a text alternative that serves the same purpose, especially product photos, and above all on the homepage, product pages and search results.
2. Linked images and image buttons need names that describe their purpose (cart, search, menu, logo-home).
3. Images of text (banners, size charts, promotions) need the text available as text.
4. Decorative images should be hidden from assistive technology (alt="").
5. Complex images (size guides, comparison charts) need a long description or a table.
6. Checkout and payment images/icons count too, because Section IV(g) explicitly covers identification, security and payment functionality.

What alt text will not do

Fixing alt text does not make a site EAA-compliant, WCAG-conformant, or safe from enforcement. It’s one success criterion out of dozens. Keyboard access, form labels, colour contrast, focus order, error messages, accessible CAPTCHAs and an accessible checkout matter at least as much. Be wary of any tool that promises “EAA compliance” in one click. The US FTC’s 2025 order against accessiBe concerned exactly that kind of overclaim about WCAG compliance (FTC, Apr 2025).

Where Altpass fits (and where it doesn’t)

Altpass does one job: it finds images with missing or weak alt text, drafts context-aware alternatives for you to approve, and exports them so you can fix your source. It doesn’t audit forms, keyboard access, contrast or checkout, it doesn’t produce “compliance certificates”, and it doesn’t make anyone compliant. Use it to clear the image backlog, then work through the rest of WCAG with proper testing.

Start with your key pages

Run the free Altpass checker on your homepage, a product page and your search results page, the same surfaces Sweden’s regulator said it would review. You’ll get a score and a list of images to fix, free and without signup.

Updated 2026-10-07