Compliance and Europe
European Accessibility Act: alt text, captions and accessible assets
Quick answer
The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025 to e-commerce and other consumer services. Images need text alternatives, videos need captions and audio description, and documents must be accessible, measured against EN 301 549 and WCAG. A DAM should store these as managed, multilingual asset data linked to each file.
Key takeaways
- The EAA, Directive (EU) 2019/882, has applied since 28 June 2025 to e-commerce, banking, e-books, transport and other consumer services, with microenterprises providing services exempt.
- Pre-recorded video and office documents published before 28 June 2025 are excluded, so every asset published since then must meet the requirements.
- EN 301 549 V4.1.1, published on 2 September 2026 and aligned with WCAG 2.2 AA, is expected to be cited in the Official Journal around the end of November 2026.
- On 4 June 2026 a French court ordered Carrefour France to make its website and app fully accessible within six months under daily penalty payments.
The European Accessibility Act turned alt text, captions and accessible documents into legal requirements for most consumer-facing digital services in the EU from 28 June 2025. For content teams, compliance depends on asset data: every image, video and PDF published to an in-scope channel needs its accessibility layer created, stored and delivered with it. The DAM is the logical system of record for that layer, because it is where assets are created, approved and distributed in every language.
What the European Accessibility Act requires
The European Accessibility Act (EAA), Directive (EU) 2019/882, requires products and services in scope to be perceivable, operable and understandable for persons with disabilities. In-scope services include e-commerce, consumer banking, e-books, audiovisual media services and passenger transport information. Microenterprises providing services (fewer than 10 employees and no more than EUR 2 million turnover or balance sheet total) are exempt. Pre-recorded video and office files published before 28 June 2025 are excluded, and services delivered with products already in lawful use before that date may continue until 28 June 2030. The so-what: the backlog can stay, but every new asset must comply.
EN 301 549 and WCAG: the technical benchmark
EN 301 549 translates the EAA's functional requirements into testable criteria, largely by referencing the Web Content Accessibility Guidelines (WCAG). Version 3.2.1, aligned with WCAG 2.1 AA, is the version still most widely referenced in audits. Version 4.1.1, published on 2 September 2026 and aligned with WCAG 2.2 AA, is expected to be cited in the Official Journal around 30 November 2026, which would give conformity presumption under the EAA. Teams should design asset workflows to WCAG 2.2 AA now to avoid rework.
Accessibility requirements by asset type
Each asset type maps to specific WCAG success criteria, and each needs a defined field or rendition in the DAM.
| Asset type | WCAG criterion | DAM requirement |
|---|---|---|
| Informative images | 1.1.1 Non-text content (A) | Alt text field per language, with a decorative flag |
| Banners with text | 1.4.5 Images of text (AA) | Live text in templates, or full text in alt |
| Pre-recorded video | 1.2.2 Captions (A) | Caption files (WebVTT or SRT) per language as linked renditions |
| Video with key visuals | 1.2.5 Audio description (AA) | Audio description track or described version |
| Audio-only content | 1.2.1 Audio-only (A) | Transcript linked to the asset |
| PDFs (manuals, brochures) | EN 301 549 clause 10 (documents) | Tagged, accessible PDF as the published rendition |
Alt text depends on context: the same product photo needs different descriptions on a product page and in a lifestyle article. Store a default description at asset level and allow placement-level overrides in the CMS, an approach that also supports image SEO.
How enforcement is developing in 2026
Enforcement is national, and the first court and regulator actions target large e-commerce operators. On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make carrefour.fr and its app fully accessible within six months under daily penalty payments, after Carrefour stated it met 71% of the criteria. A Lille court rejected a similar action against Auchan E-Commerce in May 2026 on turnover-threshold grounds, and that decision is under appeal. The Dutch ACM began testing companies that ignored its information requests, and Sweden's PTS opened e-commerce inspections. Partial compliance therefore offers limited protection.
Building the accessibility layer into the DAM
The most efficient model treats accessibility data as mandatory metadata with workflow gates. Make alt text and caption status required fields for assets tagged for in-scope channels, as part of your DAM metadata model. Use AI to draft alt text and captions, then require human review, since generated descriptions miss brand context and product details; AI auto-tagging governance applies here too. Manage caption files as renditions of the master video, as described in managing video in DAM. When evaluating platforms such as Bynder, Cloudinary or Scaleflex, test whether alt text and caption tracks pass through to the delivery URL and CMS without manual copying. Editorial estimates manual alt text at 1 to 3 minutes per image, so a 20,000-image catalogue represents roughly 330 to 1,000 hours of work without AI drafting.
What to do next
- Inventory channels in EAA scope and the assets published to them since 28 June 2025.
- Add alt text, decorative flag, caption status and audio description status as required DAM fields.
- Set up AI-drafted alt text and captions with a human review step for every language you publish.
- Replace untagged PDFs with accessible renditions, starting with manuals and terms.
- Audit priority journeys against WCAG 2.2 AA ahead of the EN 301 549 V4.1.1 citation.
Frequently asked questions
Does the European Accessibility Act require alt text on product images?
Yes, for services in scope such as e-commerce. The EAA requires perceivable information, which EN 301 549 operationalises through WCAG success criterion 1.1.1 on text alternatives. Informative product images need descriptive alt text, and purely decorative images need an empty alt attribute.
Which companies are exempt from the European Accessibility Act?
Microenterprises providing services, defined as fewer than 10 employees and annual turnover or balance sheet total of no more than EUR 2 million, are exempt from the service requirements. Services delivered with products already in lawful use before 28 June 2025 may continue until 28 June 2030.
Do videos published before June 2025 need captions under the EAA?
No. Pre-recorded time-based media published before 28 June 2025 is excluded from the requirements. Any video published or substantially republished after that date needs captions and, where visual information matters, audio description or a media alternative.