Alt Text and Accessibility: WCAG, ADA, and the European Accessibility Act
Missing alt text is the most common accessibility defect on the web. It is also the cheapest to fix: a sentence per image, written once, benefits every future visitor who cannot see the picture.
The rules around it come from three places that are often mentioned together and rarely explained: WCAG, the ADA, and the European Accessibility Act. They are not the same kind of document, and they do not ask for the same thing. This is general information, not legal advice.
What WCAG 1.1.1 actually requires
WCAG 2.2 Success Criterion 1.1.1, Non-text Content, is a Level A requirement — the lowest level, and the one every site is expected to meet. In plain terms: any image that conveys information needs a text alternative that serves the same purpose.
Three details matter more than the headline.
- "Equivalent purpose", not "description". The alt text should do the same job as the image in that context. A decorative photo and an informative chart can sit side by side on one page and need completely different treatment.
- Decorative images are exempt. The criterion explicitly allows a null alt attribute for content that is purely decorative or redundant. That exemption is not a loophole; using it correctly is part of meeting the criterion.
- Level A, not AAA. This is not an aspirational target. It is the baseline, and automated audits flag it on nearly every site that has not been through a pass.
WCAG also has SC 1.4.5, Images of Text, which discourages rendering real text inside a picture. If a banner says "50% off" in a JPEG, the text is unavailable to translation, zoom, and some assistive technology. Where you must use an image of text, the alt text should carry the words.
When alt="" is the correct answer
An empty alt attribute tells assistive technology to ignore the image. It is right in more situations than most people expect:
- A decorative divider, background flourish, or spacer graphic.
- An image that repeats text sitting right next to it, such as a logo beside the company name.
- A purely visual crop of a product that adds nothing beyond the featured image.
- An icon inside a link or button that already has an accessible name — for example, a magnifying glass inside a button labelled "Search".
What is not correct is leaving the attribute off entirely. A missing alt attribute is not the same as an empty one: some screen readers fall back to the file name, so "DSC_0098.jpg" gets read aloud. If the image is decorative, write alt="" and mean it.
| Image | Right approach | Why |
|---|---|---|
| Logo in the header | alt="AltMint" or alt="" if the name is adjacent text | Names the link destination without repeating visible text |
| Product photo | Product name plus the distinguishing view | Carries the information a sighted shopper gets from the picture |
| Chart in a report | A sentence with the trend, not "a chart" | The data is the point; the shape is not |
| Decorative divider | alt="" | Nothing is lost by skipping it |
| Screenshot in a tutorial | The step it demonstrates, plus visible labels | Lets a non-visual reader follow the instructions |
| Icon-only button | alt="" plus an accessible name on the button | The control needs a name; the glyph does not |
The ADA, in broad strokes
In the United States, the Americans with Disabilities Act prohibits discrimination on the basis of disability in places of public accommodation, and the Department of Justice has consistently treated websites as covered. The statute itself does not name a technical standard, which is why courts and settlement agreements so often point to WCAG — usually WCAG 2.1 AA — as the benchmark for what "accessible" means.
For a typical business site or online store, the practical reading is simple: if your site is a public accommodation, inaccessible images are part of a larger accessibility problem, and alt text is the first thing an audit or a demand letter will list. How the law applies to a specific organization is a question for a lawyer, not a blog post.
The European Accessibility Act
Directive (EU) 2019/882, known as the European Accessibility Act, applies to a defined list of products and services sold in the EU — e-commerce among them — and has applied since 28 June 2025. It works through harmonised standards; in practice, EN 301 549 points to WCAG 2.1 AA for web content.
Two things follow for an online store. First, product images, category pages, and checkout flows are in scope, not just the marketing site. Second, small service providers can be exempt, and enforcement sits with national authorities, so the exact obligation depends on where you sell and how large you are. Again: general information, not a legal opinion on your situation.
What this means for your images
Compliance is not a single alt text pass, but alt text is where most remediation projects start because the fix is concrete and the backlog is visible. A realistic sequence:
- Inventory the templates. Header logo, hero image, cards, product grids, testimonial avatars, footer badges. Every template that renders an image is a place where alt text can be missing.
- Check the output, not the settings. A media library full of descriptions still ships empty attributes if a theme or page builder strips them. View source on a page and read the
altattributes. - Fix the high-traffic pages first. Homepage, top product categories, checkout, and the ten pages that get the most organic traffic.
- Test with a screen reader. VoiceOver on macOS, NVDA on Windows, or TalkBack on Android. Five minutes on your homepage will teach you more than a checklist.
- Then work the archive. The long tail of old posts and product photos is where the volume is, and where manual editing stops being realistic.
Frequently asked questions
Is missing alt text a legal risk on its own?
It is rarely the only issue in a complaint, but it is the easiest one to spot and the most commonly cited. Fixing it removes an obvious, inexpensive target without claiming the site is fully accessible.
Do decorative images really need an alt attribute?
They need an empty one. alt="" is a deliberate signal to skip the image; no attribute at all leaves the behavior up to the browser and screen reader, which may read the file name.
Does accessible alt text also help SEO?
Often, because both want the same thing: a specific, honest description of what the image shows. Keyword-stuffed alt text serves neither audience, and it reads badly to a screen reader user.
Can an automated audit prove compliance?
No. Tools catch missing attributes and obvious failures, but they cannot judge whether a description is equivalent or whether an image should have been decorative. Automated checks plus human review is the realistic combination.
Once you know what needs to be written, the work is volume. Bulk editing alt text safely explains how to fix a large library without overwriting descriptions that already work, and the WordPress walkthrough covers the manual route for the pages that matter most.