Key Takeaways
- The European Accessibility Act (EAA) applies to covered products and services, including e-commerce, and accessibility requirements became applicable in 2025.
- This checklist covers 7 practical review items: missing alt attributes, content-image alt text quality, decorative-image handling, functional images, alt text length, keyword stuffing, and repeatable auditing.
- Penalties and enforcement vary by EU member state, so treat this as product guidance rather than legal advice.
- Run our free alt text scanner to review common issues on public pages before a formal accessibility audit.
In This Article
EAA 2025 Alt Text Readiness Checklist for Images
If you sell covered products or services to customers in the European Union, accessibility requirements may apply to your digital experience. The European Accessibility Act (Directive 2019/882) covers product and service categories including e-commerce, and accessibility requirements became applicable in 2025.
Alt text is one of the most frequently failed accessibility criteria — and also one of the easiest to fix. The WebAIM Million report found that 57.8% of the top 1 million homepages have missing or improper alt text (WebAIM, 2024). For ecommerce sites, the number is often higher — a Littledata study of 200 Shopify stores found only 31% of product images have non-empty alt text (Littledata, 2023).
This checklist walks through 7 alt-text-specific items that are useful for EAA and WCAG readiness workflows — what to check, how to fix common issues, and where a human reviewer still needs to decide context.
Who Must Comply — and By When
The EAA applies broadly. According to the European Commission's implementation guidance (2023), the directive covers:
| Covered | Not Covered (or Deferred) |
|---|---|
| Ecommerce websites and apps | Micro-enterprises providing services (<10 employees, <— M turnover) |
| Banking and financial services websites | Micro-enterprises selling products must still comply |
| Transport and travel booking platforms | Content published before June 28, 2025 (transitional exemption until 2030) |
| E-books and digital publications | B2B-only services with no consumer-facing component |
| Businesses outside the EU selling to EU consumers | — /td> |
Important: The "micro-enterprise exemption" only applies to service providers. If you sell physical or digital products, you must comply regardless of company size (European Commission, 2023).
The 7-Point Alt Text EAA Readiness Checklist
Use this checklist to review important images on your site. Each item relates to WCAG non-text content practices that are relevant to EAA readiness, but this checklist is not a legal compliance determination.
Every <img> Element Has an Alt Attribute
WCAG SC 1.1.1 Non-text Content — Level A
The most basic rule — and the most violated. Every <img> tag on your page must have an alt attribute. If the attribute is missing entirely, screen readers may read the filename aloud, creating a confusing and frustrating experience.
<!-- Pass: alt attribute is present --> <img src="hero-image.jpg" alt="Woman using a laptop in a modern coffee shop"> <!-- Pass: empty alt tells screen readers to skip --> <img src="decorative-border.svg" alt=""> <!-- Fail: no alt attribute at all --> <img src="product-image.jpg">
Self-check: Run our free scanner — it lists every img tag missing the alt attribute.
Content Images Have Descriptive, Non-Empty Alt Text
WCAG SC 1.1.1 — Level A
If an image conveys information that is not available elsewhere in the text, its alt text must describe that information. Product photos, charts, diagrams, infographics, and photos of people all fall into this category. The alt text should be concise but adequate — aim for under 125 characters to stay within screen reader cutoffs.
<!-- Pass: descriptive, under 125 chars -->
<img src="sneaker-gray-42.jpg"
alt="Men's gray running sneakers with mesh upper and white sole">
<!-- Fail: alt is present but vague -->
<img src="sneaker-gray-42.jpg" alt="shoe">
<!-- Fail: alt text is a filename -->
<img src="sneaker-gray-42.jpg" alt="sneaker-gray-42.jpg">
Ecommerce tip: Include the product name and 1-2 distinguishing features. Example: "Women's navy wool blazer with gold buttons, front view."
Decorative Images Use Empty Alt (alt="")
WCAG SC 1.1.1 — Level A (correctly applied)
Not every image needs descriptive alt text. Purely decorative images — dividers, background patterns, ornamental illustrations, spacer images — should use alt="". This tells screen readers to skip the image entirely, reducing auditory clutter.
Many sites make the opposite mistake: they write alt text for decorative images ("blue wavy divider line"), adding noise to the screen reader experience. Empty alt is a feature, not a bug.
<!-- Pass: decorative image correctly skipped --> <img src="section-divider.svg" alt=""> <!-- Fail: unnecessary description adds noise --> <img src="section-divider.svg" alt="Blue wavy divider line">
Use the scanner: Our tool flags images with empty alt and classifies them as "decorative" (info) vs "content" (danger) so you know which to fix.
Functional Images Describe the Action or Destination
WCAG SC 1.1.1 + SC 2.4.4 Link Purpose — Level A
When an image is wrapped in a link or used as a button, the alt text should describe the destination or action, not the visual appearance of the image. If the same link also contains visible text, the image should use alt="" to avoid duplicate announcements.
<!-- Pass: describes the link destination --> <a href="/checkout/"><img src="cart-icon.svg" alt="View shopping cart"></a> <!-- Pass: alt empty because link text already describes the action --> <a href="/checkout/"> <img src="cart-icon.svg" alt=""> Checkout </a> <!-- Fail: describes the icon, not the action --> <a href="/checkout/"><img src="cart-icon.svg" alt="Shopping cart icon"></a>
Alt Text Is Under 125 Characters (Screen Reader Cutoff)
Best practice beyond WCAG minimum
While WCAG does not mandate a character limit, most screen readers cut off alt text at around 125 characters. JAWS stops at roughly 125 characters; NVDA reads the full string but truncates visually. VoiceOver on iOS reads the entire alt text but may overwhelm users with excessively long descriptions.
For complex images (charts, infographics) that need more explanation, use a two-part strategy: a concise alt text summarizing the image + a longer text description elsewhere on the page.
<!-- Pass: concise, under 125 chars -->
<img src="revenue-chart.png"
alt="2024 quarterly revenue chart: Q1 $420K to Q4 $645K">
<!-- Pass: concise alt + long description in figcaption -->
<figure>
<img src="revenue-chart.png" alt="2024 quarterly revenue bar chart">
<figcaption>Revenue grew from $420K in Q1 2024 to $645K in Q4 2024,
representing 54% year-on-year growth across all product lines.</figcaption>
</figure>
No Keyword Stuffing in Alt Text
Google Image SEO guidelines violation
Keyword stuffing alt text — filling it with repetitive search terms — is not only bad for users but also explicitly discouraged by Google. Google's Image SEO Best Practices guide states: "Avoid keyword stuffing (filling alt text with keywords). Focus on writing useful, information-rich content that accurately describes the image" (Google Search Central, 2024).
<!-- Pass: natural description with one relevant keyword -->
<img src="running-shoes.jpg"
alt="Lightweight trail running shoes with Vibram sole">
<!-- Fail: keyword-stuffed, spammy, terrible for screen readers -->
<img src="running-shoes.jpg"
alt="running shoes buy running shoes cheap running shoes best running shoes trail running shoes">
Your Site Has Been Audited by an Automated Alt Text Checker
Due diligence requirement
Manual checks are impractical for sites with more than a few dozen images. An automated scanner can identify common issues like missing alt attributes, empty alt on likely content images, keyword-stuffed alt, and overly long alt text. Automation cannot verify alt text quality the way a human can, but it gives you a prioritized review list.
Run a scan now: scan-alt.com — free for up to 50 images per month, no account required.
How to Review Your Site's Alt Text
Manual inspection works for a single page. For larger ecommerce catalogs, a scanner can help you find likely issues faster. Here's a three-step review workflow:
- Scan your homepage: Enter your URL into the free alt text checker. It crawls the page, extracts every
<img>element, and reports each image's alt text status — missing, empty, keyword-stuffed, or too long. - Prioritize the red items: The scanner labels each issue with a severity level: danger (high-priority review), warning (best-practice gap), and info (likely okay). Start with danger items, then review context manually.
- Export and assign: Use the CSV export (Pro plan) to hand off fix lists to your development team or agency. Each row includes the image URL, current alt text, issue type, and a suggested fix.
Ready to review your EAA alt text readiness?
Scan any public URL now. Free for up to 50 images/month — no credit card, no account required.
Free EAA Alt Text Scan4 Common EAA Alt Text Pitfalls
Even teams that understand the rules make these mistakes. Avoid them.
| Pitfall | Why It's a Problem | Fix |
|---|---|---|
| Using the filename as alt text | Screen readers announce "IMG_8823.jpg" — meaningless noise. Also tells Google nothing about the image. | Write a short human-readable description. If it's a CMS-generated filename, strip it and replace with a real alt text. |
| Leaving alt text out of CMS uploads | Shopify, WordPress, and most CMS platforms include an "Alt text" field during upload. If skipped, the image ships with no alt attribute. | Make alt text a required field in your content workflow. Use a bulk generator for catalogs with 100+ images. |
| Thinking alt="" is always a mistake | Teams "fix" empty alt by writing descriptions for decorative dividers, icons, and background images — adding screen-reader noise. | Use a scanner that distinguishes content images from decorative images. alt="" is correct for decorative — don't "fix" it. |
| Auditing once and never again | New products, blog posts, and CMS updates add images over time. A one-time audit goes stale in weeks. | Schedule a recurring manual or automated review — weekly for active ecommerce sites, monthly for content sites. |
FAQ
Does the European Accessibility Act require alt text on all images?
Yes — with nuance. The EAA requires websites to meet WCAG 2.1 Level AA standards, which includes SC 1.1.1 (non-text content must have a text alternative). Content images must have descriptive alt text. Purely decorative images should use alt="" (empty) to tell screen readers to skip them. The key is that every img element must have an alt attribute — even if it's empty.
When does the EAA enforcement start?
The European Accessibility Act enforcement begins June 28, 2025. EU member states were required to transpose the directive into national law by June 28, 2022, with a three-year transition period ending in June 2025. After this date, businesses selling products or services in the EU can face fines, complaints, and legal action for non-compliance.
Who needs to comply with the EAA?
The EAA applies to any business — inside or outside the EU — that sells products or services to EU consumers. This includes ecommerce stores, SaaS platforms, banking and insurance websites, transportation services, and digital content providers. Micro-enterprises (fewer than 10 employees and under — million annual turnover) providing services are exempt, but all product sellers must comply regardless of size.
Can I get fined for missing alt text under the EAA?
Penalties and enforcement processes vary by EU member state. Check the national rules that apply to your business and consult a qualified accessibility or legal advisor for formal compliance questions.
Is there a free tool to review EAA alt text readiness?
Yes. Scan Alt offers a free alt text checker that scans public HTML pages and reports common alt text issues, including missing attributes, empty alt on likely content images, keyword-stuffed text, and likely decorative images. Use it as a readiness aid, not as a formal compliance audit.
Conclusion: Build an Alt Text Review Workflow
The European Accessibility Act makes accessibility a serious business requirement for covered products and services, including e-commerce. The 7-point checklist above covers practical alt-text review items that often appear in WCAG readiness work. Items 5-7 (character limits, keyword hygiene, and ongoing reviews) are process improvements that prevent drift over time.
The good news: alt text is one of the easier accessibility issues to start fixing. A scanner can surface likely problems quickly, and a human reviewer can then confirm whether each suggestion accurately reflects the image. The payoff is practical: clearer image content, better accessibility, and a stronger foundation for SEO and compliance review.
Sources & References
- European Commission. (2023). "European Accessibility Act — Directive (EU) 2019/882." ec.europa.eu/social
- W3C. (2023). "Web Content Accessibility Guidelines (WCAG) 2.1 — Success Criterion 1.1.1 Non-text Content." w3.org/TR/WCAG21
- W3C. (2023). "Web Content Accessibility Guidelines (WCAG) 2.1 — Success Criterion 2.4.4 Link Purpose (In Context)." w3.org/TR/WCAG21
- WebAIM. (2024). "The WebAIM Million — An Accessibility Analysis of the Top 1,000,000 Home Pages." webaim.org/projects/million/
- Littledata. (2023). "Shopify Image Alt Text Survey: 200 Stores Analyzed." littledata.io
- Google Search Central. (2024). "Google Image SEO Best Practices." developers.google.com/search
- German Federal Ministry of Labour and Social Affairs. (2021). "BITV 2.0 — Barrierefreie-Informationstechnik-Verordnung." gesetze-im-internet.de