The 2025 Alt Text Mandate: Why "Good Enough" Accessibility Is Now a Legal Liability

The era of treating accessibility as a "nice-to-have" line item is over.

For the last decade, e-commerce merchants viewed alt text (alternative text) through the lens of accommodation—a benevolent task for the intern to handle when they had spare time. But as we approach the midway point of the decade, the function of non-text content has fundamentally shifted. It has graduated from a passive compliance checkbox to the structural pillar of your site's legal safety and revenue engine.

The deadline has passed. On June 28, 2025, the European Accessibility Act (EAA) moved from theory to enforcement. If you sell to the EU, this is not a suggestion; it is a hard stop. Combine this with the aggressive crackdown on ADA violations in the U.S., and the reality is stark: If your images are blind to machines, your business is liable.

This isn't about charity. It's about risk mitigation and survival. Here is the definitive guide to writing alt text in 2025, and why the old methods—and the cheap "widgets" you installed to fix them—are about to fail you.

The Legal Cliff: EAA and the End of the "Overlay" Era

The most dangerous myth in e-commerce today is the "Widget Fallacy."

Thousands of merchants have installed accessibility overlays or widgets, believing these superficial patches protect them from litigation. The data proves otherwise. In the first half of 2025 alone, 22.6% of accessibility lawsuits were filed against sites already using a widget.

Why? Because legislation like the EAA and the Americans with Disabilities Act (ADA) demands source-code compliance.

The European Accessibility Act is a directive with specific technical requirements rooted in WCAG 2.2. It requires that your site is "Perceivable, Operable, Understandable, and Robust" at the code level. An overlay that sits on top of your site does not fix the underlying HTML. If your source code lacks an alt attribute, you are non-compliant.

The Department of Justice (DOJ) has solidified this stance in the U.S., ruling that "effective communication" is non-negotiable. A website filled with images labeled "image" or "null" is increasingly viewed by courts as a failure to provide effective communication. With fines and settlements ranging from $55,000 to over $150,000, bad alt text is now a boardroom-level financial risk.

The "Keyword Stuffing" Trap vs. True Vision-AI

As merchants scramble to fix their code following the June 2025 deadline, many are turning to cheap automation tools. This is where the second major pitfall lies: The difference between "Keyword Stuffing" and Semantic Description.

Competitor tools like AltText.ai or basic Shopify plugins often rely on "scraping" logic. They look at your product title ("Blue Running Shoe") and your tags ("Sneaker, Sport"), and mash them into an alt text description.

This is a liability, not a solution.

Search engines and legal auditors in 2025 have evolved.

• Old SEO (and bad tools): alt="buy running shoes cheap nike"
• Modern Compliance: alt="Nike Air Zoom Pegasus 39 running shoe in obsidian blue with mesh detailing."

The former is "keyword stuffing," which Google's Natural Language Processing (NLP) now flags as spam, potentially de-indexing your images. The latter is an Entity Description.

This is why Vision-AI—technology that actually "sees" the image rather than just reading the metadata—is the only defensible moat. You need technology that can pass the "Relevance Test." A generic AI might look at a lifestyle shot of your product and say "people sitting at a table." But a context-aware Vision-AI understands the intent: "Mahogany conference table with seating for eight, featuring ergonomic mesh chairs."

The New Rules of Engagement: WCAG 2.2

The release of WCAG 2.2 has introduced specific nuances that generic writers and basic AI tools miss. Compliance in 2025 requires adhering to stricter principles:

1. The "Focus Not Obscured" Rule

If your images act as buttons or links (Functional Images), the focus indicator (the outline that appears when a user tabs to it) must not be hidden. This is critical for sighted keyboard users. Your alt text must align with this visual cue.

2. Target Size and the "Icon-Only" Danger

WCAG 2.2 mandates a minimum target size of 24x24 CSS pixels. If you use small icon buttons (like a magnifying glass for search), the alt text carries a heavier load. Because the clickable area is larger, accidental clicks increase. The "accessible name"—derived from your alt text—is the only way a screen reader user can verify the button's function before activation.

The Rule: For functional images, describe the action, not the appearance.

• Wrong: "Magnifying glass icon."
• Right: "Search store."

How to Audit Your Alt Text Strategy (Right Now)

If you are relying on a CSV upload from a VA or a basic generative plugin, you need to audit your strategy against the "Decision Tree."

1. The Decorative Test (The Null Trap)

If an image is purely for "vibes"—borders, spacers, or generic mood stock photos—it must have a null attribute (alt="").

Critical Warning: Do not simply omit the attribute. If you leave it out, a screen reader will often attempt to read the file name, resulting in a jarring audio experience like "Graphic, slash, D-S-C-zero-zero-five-nine-dot-jpg."

2. The Contextual Hierarchy

Context determines content. A single image changes meaning based on where it lives.

• On a Product Page: Focus on physical details (color, texture, dimensions).
• On an 'About Us' Page: Focus on the people and the emotion ("Our diverse executive team collaborating during Q3 planning").

Generic AI cannot make this distinction. You need a solution that allows for "Human-in-the-Loop" (HITL) verification to bridge the gap between machine speed and human intent.

The Hidden ROI: Multimodal Discovery

If the fear of a lawsuit doesn't motivate you, the promise of revenue should.

In 2025, nearly 60% of searches are "zero-click." Users are getting their answers directly on the result page via AI overviews or visual carousels. Google Lens allows users to shop by pointing their cameras at real-world objects.

For your product to appear in these rich results, Google must have a high-confidence link between the visual pattern and your product data. Alt text is that Semantic Bridge. It teaches the machine to see. By implementing high-quality, descriptive alt text, you aren't just avoiding a fine; you are unlocking a massive, high-intent traffic source that your competitors (who are still using keyword stuffing) cannot access.

The Final Verdict

The window for "figuring it out later" has closed. The EAA deadline has passed, and the legal landscape is hostile toward negligence.

You have two choices:

1. Continue gambling with "overlay" widgets and keyword-stuffing tools that provide a false sense of security while actively hurting your SEO.
2. Deploy a Vision-AI solution that generates legally defensible, context-aware, and SEO-rich descriptions directly into your source code.

Lumi AI doesn't just guess at your images; it sees them, understands them, and writes the code that keeps you compliant and profitable.

Don't wait for the demand letter. Calculate your ROI or secure your store today.

Learn more: Why accessibility widgets fail, how accessibility drives SEO, and building a compliance retainer service.