Short answer
The European Accessibility Act applies from 28 June 2025 to e-commerce and other consumer services in the EU, with microenterprises providing services exempt. Accessible images need a text alternative that serves the equivalent purpose, the rule in WCAG success criterion 1.1.1. A DAM stores alt text per asset, language and context, routes AI drafts through human review and passes alt text to every publishing channel.
What the European Accessibility Act covers
The European Accessibility Act, Directive (EU) 2019/882, sets accessibility requirements for listed products and for services provided to consumers after 28 June 2025, including e-commerce services.
This page is orientation for DAM and content teams. It gives no legal advice: national transposition laws set the exact duties and penalties, so confirm your position with counsel.
Fact: recital 42 of the Directive describes e-commerce services as services provided at a distance through websites and mobile device-based services. The consumer requests them individually, with a view to concluding a consumer contract. Fact: Article 4(3) requires covered services to meet the accessibility requirements in Sections III and IV of Annex I.
| Date or rule | What it means | Source provision |
|---|---|---|
| 28 June 2022 | Deadline for Member States to adopt and publish national laws | Article 31(1) |
| 28 June 2025 | Member States apply the national measures | Article 31(2) |
| 28 June 2030 | End of the transitional period in which service providers may keep using products they lawfully used to provide similar services | Article 32(1) |
| Up to 5 years | Service contracts agreed before 28 June 2025 continue unaltered until expiry, at most five years from that date | Article 32(1) |
| Microenterprise exemption | Microenterprises providing services, with fewer than 10 persons and turnover or balance sheet of EUR 2 million or less, are exempt | Articles 3(23) and 4(5) |
DAMSelection found no amendment or postponement of the Directive on the EUR-Lex and Commission pages checked on 14 October 2026. The 28 June 2025 date stands.
Where text alternatives come from
Text alternatives enter EAA compliance through EN 301 549, the harmonised European standard written for the Directive, which applies the web content rules of WCAG, including success criterion 1.1.1.
WCAG 2.2 success criterion 1.1.1 sets the core rule. "All non-text content that is presented to the user has a text alternative that serves the equivalent purpose". Recital 47 of the Directive points to the four WCAG principles for websites and mobile applications. For products, Annex I Section I, point 1(b)(vi), asks that instructions for use provided off the product come with an alternative presentation of any non-textual content.
Fact: ETSI, CEN and CENELEC published EN 301 549 V4.1.1 in September 2026. The new version references WCAG 2.2 and adds Annex ZB, which maps its clauses to the Directive's requirements. The Irish National Disability Authority reports that the Official Journal citation of V4.1.1 is pending and expected on 16 December 2026. Until then, the authority describes V3.2.1 (2021), built on WCAG 2.1, as the version in force.
DAMSelection assessment: text alternatives rules match in WCAG 2.1 and 2.2, so the version switch changes little for image alt text. Plan the DAM fields once and reuse them through both versions.
Alt text as DAM metadata
Alt text belongs in the DAM as a governed metadata field per language, because the DAM is where every channel collects the image.
Treat alt text like any other field in the metadata schema: defined, validated and owned. The IPTC Photo Metadata Standard has carried two accessibility fields since version 2021.1, which lets alt text travel inside the file as XMP.
| DAM field | Purpose | Standard mapping |
|---|---|---|
| Alt text, per language | Short description of purpose and meaning | IPTC Alt Text (Accessibility), Iptc4xmpCore:AltTextAccessibility, 250 characters |
| Extended description, per language | Longer description for charts, diagrams and infographics | IPTC Extended Description (Accessibility), Iptc4xmpCore:ExtDescrAccessibility |
| Decorative flag | Marks images that assistive technology should skip | Rendered as empty alt in the channel |
| Alt text status | Draft, AI draft, reviewed, approved | DAM workflow field |
| Context variants | Alt text per use, such as product page or campaign banner | DAM related records |
Use the Metadata Model Builder to place these fields next to product, rights and AI fields.
One image, several alt texts
One image often needs different alt text in different contexts, because WCAG asks for a text alternative that serves the equivalent purpose on that page.
A product cutout on a product detail page describes the product variant. The same cutout in a campaign banner may need to carry the offer text shown in the image. Worked example: a library of 20,000 publishable images in four languages needs 80,000 alt text values before any context variants.
- Store a default alt text per language on the asset.
- Store context variants for high-traffic placements, such as the homepage and category banners.
- Let the channel choose the variant through the integration, with the default as fallback.
- Mark images of text for review, since the alt text must repeat the words shown.
Alt text rules for the DAM style guide
Alt text quality depends on a short written style guide that reviewers apply to every image, stored in the DAM next to the brand guidelines.
The first four rules follow the W3C guidance for success criterion 1.1.1. The last two are DAMSelection practice; add your own rules on tone and languages.
- Describe the purpose and meaning of the image in the context where it appears.
- Mark purely decorative images as decorative, so assistive technology can skip them.
- Repeat the words shown in images of text, such as offer banners and packaging claims.
- Give charts, diagrams and infographics a short alt text plus an extended description, and link the data in a table where practical.
- Use the product name as written in the PIM, without SKU codes unless shoppers search by them.
- Skip phrases such as "image of" or "photo of", because screen readers already announce the image.
DAMSelection assessment: publish the style guide in the brand portal and link it from the alt text field help text. Reviewers then apply one standard across agencies and markets.
Measuring alt text coverage
Alt text coverage is the share of publishable images with approved alt text in each language, and it belongs on the DAM governance dashboard.
Track coverage per language, per channel and per asset type each month. Read DAM KPIs for the wider metric set.
| Metric | Definition | Why it matters |
|---|---|---|
| Coverage | Publishable images with approved alt text, per language | Shows exposure on covered channels |
| Review backlog | AI drafts waiting for human review | Shows where the workflow stalls |
| Context variants | High-traffic placements with their own alt text | Shows quality on the pages users see most |
| Channel loss | Published images where the channel shows no alt text | Shows integration gaps |
DAMSelection rule of thumb: start with product images on live e-commerce pages, then campaign assets, then the archive. Archive images get alt text when someone reuses them.
AI-assisted drafting with human review
AI drafts alt text quickly, and human review stays necessary for product accuracy, brand terms and the purpose of the image on the page.
AI models describe what they see, while the purpose of an image depends on the page around it. DAMSelection assessment from PIMvendors practice: AI drafts work well for lifestyle and scene images and poorly for technical product images, where model names and attributes matter. Read AI in DAM for testing methods.
- Generate an AI draft on upload, in the master language.
- Pull product name and key attributes from the PIM into the draft prompt.
- Route the draft to a reviewer, with status set to AI draft.
- Translate the approved text, then review the translations for brand terms.
- Record reviewer and date, and block publication of images without approved alt text.
Passing alt text to channels
Alt text only reaches users when every integration carries the field from the DAM to the page, feed or app that renders the image.
Map the alt text field in each integration and test it in integration testing. DAMSelection assessment: three gaps cause most failures in projects PIMvendors reviews.
- CMS and e-commerce connectors that sync the image file and drop the alt text field.
- Image CDN delivery URLs, which carry no alt text, so the page template must request it through the API.
- Marketplace and retailer feeds, where alt text travels through the PIM and its syndication mapping.
Read DAM integrations and DAM vs PIM to decide which system owns the field for product images.
What to test in a demo
Vendors should prove alt text handling on the buyer's own images, in every language and channel the buyer publishes to.
Add these scenarios to your scripted DAM demo or build them with the Demo Script Generator.
- Upload 50 of your images and generate alt text drafts in two languages.
- Show the review step, the status field and the audit trail.
- Set a context variant and show the CMS picking it up without manual entry.
- Export an image with alt text embedded in the IPTC accessibility field.
- Run a report of publishable images without approved alt text, per language.
Frequently asked
Does the European Accessibility Act require alt text?
The European Accessibility Act requires covered services to meet the accessibility requirements in Sections III and IV of Annex I. The harmonised standard EN 301 549 applies WCAG, whose success criterion 1.1.1 requires a text alternative for non-text content. Images on covered e-commerce sites therefore need meaningful alt text or a decorative mark.
When did the European Accessibility Act start to apply?
Member States apply the national measures from 28 June 2025 under Article 31(2) of Directive (EU) 2019/882. Service contracts agreed before that date can continue unaltered until expiry, for at most five years. Service providers may keep using products they lawfully used to provide similar services during a transitional period ending on 28 June 2030.
Are small companies exempt from the accessibility requirements?
Microenterprises providing services are exempt under Article 4(5). A microenterprise employs fewer than 10 persons and has an annual turnover or balance sheet total of EUR 2 million or less. Microenterprises dealing with products face lighter obligations, set out in the Directive and national law.
Can AI write alt text for EAA compliance?
AI can draft alt text, and the result still needs human review before publication. Models describe visible content and miss the purpose of the image on the page, product names and brand terms. Store the review status and reviewer in the DAM, so the organisation can show who approved each text.
Where should alt text live, in the DAM or the CMS?
Alt text should live in the DAM as the single source per asset and language. The CMS, commerce platform and PIM feeds then read it through integrations. Page-specific variants can sit in the DAM as context records or in the CMS, as long as one owner is agreed.
Sources
- Directive (EU) 2019/882, the European Accessibility Act (EUR-Lex)
- Directive (EU) 2019/882 on the accessibility requirements for products and services, EUR-Lex
- European Commission: European Accessibility Act
- ETSI EN 301 549 V4.1.1 (2026-09): Accessibility requirements for ICT products and services
- W3C: Understanding Success Criterion 1.1.1 Non-text Content (WCAG 2.2)
- IPTC Photo Metadata Standard 2025.1
- National Disability Authority: EN 301 549 V4.1.1 published