Accessibility Compliance Guide

Alt Tags and the European Accessibility Act

The European Accessibility Act is transforming digital accessibility requirements across the EU. For website owners, understanding how to implement proper alt tags is now not just a best practice—it's becoming a legal requirement.

As the digital landscape continues to evolve, accessibility has moved from a "nice-to-have" feature to a critical legal requirement. The European Accessibility Act (EAA), set to be fully enforced by June 28, 2025, introduces comprehensive accessibility standards that significantly impact websites and digital content across the EU. At the heart of these requirements is the proper implementation of alt text for images—one of the most fundamental yet often overlooked aspects of web accessibility.

This guide focuses specifically on alt tags (also called alt text or alternative text) and how they factor into EAA compliance. Whether you're a business owner, web developer, or content creator, understanding these requirements is essential for both legal compliance and creating a more inclusive web experience.

European Accessibility Act: A Brief Overview

The European Accessibility Act (Directive EU 2019/882) aims to improve the functioning of the internal market for accessible products and services by removing barriers created by divergent regulations across EU Member States. While the EAA covers a broad range of products and services, its digital accessibility requirements have far-reaching implications for websites and online content.

The EAA specifically covers e-commerce websites, banking services, e-books, and various digital interfaces. For website owners, this means ensuring that all digital content meets accessibility standards, with proper image alt tags being a critical component of compliance.

Key EAA Timeline:

  • June 2019: The EAA was officially published
  • June 28, 2022: The directive was formally adopted as regulation
  • June 28, 2025: Enforcement begins—this is the compliance deadline

It's important to note that the EAA applies to businesses both inside the EU and those outside the EU that offer products or services to EU customers. This includes businesses in the UK and other non-EU countries that export products or provide digital services to EU countries.

"The EAA represents a significant step towards a more accessible Europe, offering benefits to both businesses and individuals while laying out a clear timeline for its phased implementation and enforcement."

Business Disability Forum

Why Alt Tags Matter Under the EAA

Alt tags are HTML attributes that provide alternative text descriptions for images on a website. They serve several crucial purposes that align directly with the EAA's accessibility requirements:

  • Screen Reader Compatibility. Alt tags allow screen readers to describe images to users who are blind or have visual impairments, ensuring they can access all content on your website.
  • Broken Image Fallback. When images fail to load due to connectivity issues or broken links, alt text displays instead, ensuring users still understand what should be there.
  • Information in Multiple Formats. The EAA specifically requires that information be provided via more than one sensory channel—alt tags help fulfill this requirement by providing text alternatives to visual content.

From a legal perspective, properly implemented alt tags are now essential for compliance with the EAA. Section I of Annex I of the directive specifically addresses requirements for providing information in accessible formats, which directly applies to image content on websites.

EAA Requirements for Alt Tags

Looking at the specific language in the EAA, several requirements directly impact how alt tags should be implemented on websites. According to Annex I, Section I of the directive:

Products must be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities and shall be accompanied where possible in or on the product by accessible information on their functioning and on their accessibility features.

Information on the use of the product provided on the product itself (labelling, instructions and warning) shall be:

  • made available via more than one sensory channel;
  • presented in an understandable way;
  • presented to users in ways they can perceive;

Instructions containing any non-textual content shall be accompanied by an alternative presentation of that content.

For website images, this means:

  • All non-decorative images must have alt text that accurately describes their content and function.
  • Alt text must be understandable and presented in a way that users with disabilities can perceive.
  • Images that convey information crucial to using the website or understanding its content must have descriptive alt text that fully captures this information.
  • Decorative images should have empty alt attributes (alt="") to ensure screen readers skip them.

Additionally, Annex II of the EAA provides examples of solutions that contribute to meeting these accessibility requirements. For alt tags, this includes:

  • Providing tactile relief format or sound in addition to a text warning so that blind persons can perceive it.
  • Ensuring that text can be read by persons who are visually impaired.
  • Accompanying a diagram with a text description identifying the main elements or describing key actions.
Modern ergonomic green lounge chair with brown headrest on swivel base.

alt="Modern chair."

Modern ergonomic green lounge chair with brown headrest on swivel base.

alt="Modern ergonomic green lounge chair with brown headrest on swivel base."

Comparison between non-compliant and EAA-compliant alt text for an e-commerce product image.

Creating EAA-Compliant Alt Tags

Creating alt tags that meet EAA requirements involves both technical implementation and thoughtful content creation. Here are best practices for writing alt text that complies with the EAA:

  • Be Specific and Descriptive. Provide enough detail to convey the image's content and purpose. For e-commerce products, include key features, colors, and uses that would help someone make a purchasing decision.
  • Consider Context. The purpose of the image affects what information should be included in its alt text. An e-commerce product image requires different details than a decorative banner image.
  • Keep It Concise. While descriptive, alt text should remain concise. Most screen readers work best with alt text under 125 characters. Prioritize the most important information about the image.
  • Include Text From Images. If an image contains text, especially if that text conveys important information, include it in the alt text.
  • Avoid Redundancy. Don't start alt text with "Image of" or "Picture of" as screen readers already announce elements as images.

Examples of EAA-Compliant Alt Text:

  • E-commerce product: alt="Wireless Bluetooth headphones with noise cancellation, 30-hour battery life, and foldable design in matte black"
  • Chart or graph: alt="Bar chart showing monthly sales growth of 15% from January to June 2025, with highest growth in April at 28%"
  • Infographic with text: alt="Infographic showing 5 steps to EAA compliance: 1. Audit your website, 2. Fix alt text, 3. Ensure proper headings, 4. Add keyboard navigation, 5. Test with screen readers"

Special Cases for Alt Tags Under the EAA

Different types of images require different approaches to alt text to meet EAA requirements:

  • Complex Infographics: For highly detailed infographics, consider providing both alt text and a separate accessible version of the information, such as a data table or descriptive text near the image.
  • Logos and Brand Images: For company logos, include the company name and any tagline if it's part of the logo. For example: alt="AltTagger logo".
  • Image Buttons and Interactive Elements: For images that function as buttons or interactive elements, the alt text should describe the action, not just the image. For example: alt="Search for products" instead of alt="Magnifying glass icon".

Automating Alt Tags to Meet EAA Requirements

With the scale of images on many websites, manually writing alt text for every image can be time-consuming. AI-powered solutions like AltTagger can help automate this process while ensuring compliance with EAA requirements:

  • Image Analysis Technology: Modern AI can detect objects, people, actions, and text within images to generate descriptive alt text automatically.
  • Contextual Understanding: Advanced alt text automation can consider the image's context on the page to generate more relevant descriptions.
  • Human Review Integration: The most effective systems combine AI-generated alt text with human review processes to ensure accuracy, especially for complex or specialized content.

Automated solutions can significantly reduce the workload of implementing EAA-compliant alt text across your website while ensuring consistent quality. However, it's important to note that the EAA still places responsibility on businesses to ensure all content is accessible, regardless of whether automated tools are used.

EAA Alt Text Compliance Checklist

As the June 2025 EAA enforcement deadline approaches, use this checklist to ensure your website's alt tags are compliant:

Alt Text Audit Checklist:

  • Perform a site-wide audit to identify all images without alt text
  • Review existing alt text for accuracy and completeness
  • Ensure decorative images use empty alt attributes (alt="")
  • Check that functional images (like buttons) have alt text describing their action
  • Provide alternatives for complex images (charts, infographics, diagrams)
  • Test your website with a screen reader to verify the experience
  • Implement a process for adding alt text to new images going forward

Conclusion: Preparing for EAA Compliance

As the June 28, 2025 enforcement deadline for the European Accessibility Act approaches, businesses must prioritize digital accessibility, with proper alt text implementation being a cornerstone requirement. Complying with the EAA's alt text requirements is not just about avoiding legal penalties—it's about creating a more inclusive digital environment that serves all users equally.

By following the guidelines in this article, you can ensure your website's images are accessible to everyone, including people with visual impairments who use screen readers. Remember that while the EAA focuses on accessibility for persons with disabilities, improvements in this area benefit all users through clearer communication and better user experience.

Tools like AltTagger can help streamline the process of implementing EAA-compliant alt text across your website, allowing you to focus on your core business while ensuring accessibility compliance. Start your accessibility journey today to be fully prepared for the 2025 EAA enforcement deadline.