Images of text and accessibility: a checklist for translated images

A banner that says "Summer sale", a product photo with feature callouts, an infographic, a screenshot of your app: each of these is a picture with words in it. When you localize a campaign into four languages, you publish four of them, and each one has to work for people who use a screen reader, zoom in or need strong contrast. This checklist covers the rules that apply to images of text, what the European Accessibility Act changed for online shops, and what to check every time an image is translated.

What counts as an image of text

WCAG treats an image differently depending on what the text is doing in it:

Most images that marketing and e-commerce teams translate fall in the first row (banners, social creatives, offer graphics) or the third (product photos and infographics).

The WCAG criteria that apply

WCAG 2.2 is the current W3C Recommendation; the criterion numbers below are the same in WCAG 2.1.

• 1.4.5 Images of Text (Level AA). If the technology you use can produce the visual presentation, use text rather than an image of text. Two exceptions: the image can be visually customized to the user's requirements, or a particular presentation of the text is essential to the information. Logotypes are considered essential.
• 1.4.9 Images of Text (No Exception) (Level AAA). Images of text are used only for pure decoration or where a particular presentation is essential. The European standard EN 301 549 targets Levels A and AA, not AAA, but this criterion shows the direction: live text by default.
• 1.1.1 Non-text Content (Level A). All non-text content has a text alternative that serves the equivalent purpose, apart from a few listed exceptions such as decoration. For images of text, the W3C images tutorial is explicit: the text alternative contains the same text as the image.
• 1.4.3 Contrast (Minimum) (Level AA). Text and images of text have a contrast ratio of at least 4.5:1, or 3:1 for large-scale text. Incidental text in a picture with significant other visual content and logotypes have no contrast requirement, so the rule covers text baked into banners.
• Related criteria. Resize Text (1.4.4) excludes images of text: words inside a picture do not have to grow when users enlarge text, another reason to keep key information live. Language of Parts (3.1.2) asks you to mark text written in another language than the page.

Why translating an image makes this harder

Translating an image of text multiplies the work: one source banner becomes one image per language, and each copy can fail in its own way.

• The alt text stays in the source language. A French banner with English alt text tells screen reader users something different from what everyone else sees, and the screen reader may read it with the wrong pronunciation.
• The alt text describes instead of repeating. "Promotional banner" is not a text alternative for a banner that announces a discount, an end date and a code. The alt text should say what the banner says.
• The translation is longer. German and French often take more room than English. Text that is shrunk to fit can lose the large-text allowance and then needs 4.5:1, and text that moves can land on a busier part of the background.
• Key facts end up as pixels. A price, a deadline or a legal mention inside an image cannot be resized, copied or found by search, and it does not follow your currency or terms when they change.

The checklist

1. Use live text where you can. For banners, hero images and offer graphics, put the headline, the offer and the button label in HTML text over a background image. That text is translated with the rest of the page, resizes and has no image to regenerate. Logos stay as they are.
2. When text stays in the image, repeat it in the alt text. Product photos with callouts and social media creatives often have to keep their text. Their text alternative contains the same words. For long text, such as an infographic, add a full text version next to the image or link to one.
3. Translate the alt text with the image. Every translated image gets alt text in its own language. Check that your CMS stores alt text per language, and that an untranslated field does not fall back to the source language without anyone noticing.
4. Mark the language when it differs. If a page in one language shows an image in another, for example an English screenshot in a French help article, mark the alt text or the text version with the right lang attribute.
5. Check contrast in each translated version. Measure the text color against the background behind it: 4.5:1 for normal text, 3:1 for large text. Do it after translation, because the font size, line breaks and background area can change.
6. Give decorative images an empty alt. Use alt="" for decoration, and do not repeat in the alt text what the page already says in live text right next to the image.
7. Do not skip pictures with other content. Product photos, screenshots and charts are outside the images of text criterion, but they still need a text alternative that conveys any text that matters, such as a chart's key figures.
8. Keep critical information out of images. Prices, offers, sizes and legal terms are safer as live text: readable at any zoom level, easy to update and translated with the page.
9. Leave logos alone. A logotype is exempt from the images of text and contrast rules. Its alt text is the brand name, which usually stays the same in every language.
10. Review image and alt text together. A person who reads the target language checks the translated image, its alt text and any text version side by side before the language goes live.

The European Accessibility Act: who has to comply

The European Accessibility Act, Directive (EU) 2019/882, applies in the Member States since 28 June 2025. For online businesses, the key points are:

• Consumer services. It covers services provided to consumers, including e-commerce services, consumer banking, e-books, electronic communications and parts of passenger transport services such as websites, apps and e-tickets. The directive defines e-commerce as services provided at a distance through websites and mobile services, at the request of a consumer, with a view to concluding a consumer contract. Services sold only to businesses are outside its scope.
• What it asks for. The requirements for services include an alternative presentation for non-text content, sufficient contrast, and websites and apps that are perceivable, operable, understandable and robust: the four principles of WCAG.
• Microenterprises. Microenterprises providing services are exempt. The directive defines them as fewer than 10 persons with an annual turnover or annual balance sheet total of no more than EUR 2 million.
• Disproportionate burden. A company that claims a fundamental alteration or a disproportionate burden must document its assessment.
• No grace period for websites. The directive lets services keep using products they already used before 28 June 2025 until 28 June 2030. France's consumer protection authority, the DGCCRF, states that a website or app is not a "product", so an existing online shop cannot rely on that transition.

If your company sells only to businesses, as agencies and software vendors often do, the obligation sits with your customers' consumer-facing services. The images you deliver end up on their sites, so helping them comply means delivering images that can be published accessibly: live text where possible, and alt text for every language.

EN 301 549: the technical standard

In Europe, "WCAG Level AA" usually reaches companies through EN 301 549, the harmonised standard for the accessibility of ICT products and services.

• The new version. EN 301 549 V4.1.1 (2026-09) was prepared for the European Accessibility Act. Its web, document and software clauses are aligned with WCAG 2.2 Level A and AA, and a new annex maps them to the directive's requirements.
• Images of text. Clause 9.1.4.5 covers the web, 10.1.4.5 non-web documents and 11.1.4.5 software. Non-text content is clause 9.1.1.1 for the web.
• Presumption of conformity. Under the directive, a harmonised standard gives a presumption of conformity once its reference is published in the Official Journal of the EU. As of early October 2026, we could not confirm that V4.1.1 has been cited under the Accessibility Act, so it does not yet give that presumption. Check the Commission's list of cited standards before relying on it.
• The previous version. EN 301 549 V3.2.1 (2021) is the version cited under the Web Accessibility Directive, which covers public sector websites.

France: who checks and what it costs

France transposed the directive into the Consumer Code (article L.412-13, created by law 2023-171), completed by décret 2023-931 and an arrêté, both of 9 October 2023. The arrêté sets out the requirements, and the rules apply from 28 June 2025.

• Who checks. The DGCCRF checks the accessibility of services, including e-commerce, in coordination with other regulators: Arcom, ARCEP, Banque de France, ACPR and AMF. It says its checks began on 28 June 2025, in particular after reports made through SignalConso, its consumer complaint platform.
• Fines. The DGCCRF lists fines of EUR 7,500 for fifth-class offences ("contraventions"), which add up with the number of breaches found. It can also issue injunctions backed by penalty payments and publish the sanction.
• Microenterprises. In the DGCCRF's words, no accessibility obligation applies to service providers that are microenterprises.
• Compliance information. Service providers must publish information on how they comply. The DGCCRF gives RGAA audit reports as an example. The RGAA is the French accessibility framework, currently based on WCAG 2.1 AA; check the official site for the version in force before an audit.
• Large companies. Companies with a turnover above EUR 250 million also fall under article 47 of law 2005-102 on the rights of disabled people, which Arcom enforces with its own sanctions.

Where TranslateMyImage fits

Some images have to keep their text: a product photo with callouts, a social media creative, an infographic. For those, TranslateMyImage helps you produce the localized version. Upload the image to the image translator, choose the language, and review the result. For a catalog, plans from Pro up include batch translation and the image translation API, which produce several languages in one run.

The result is an image, and a tool does not make an image accessible on its own. Each translated image still needs:

• alt text in the same language, containing the same text as the image;
• a contrast check of the translated text against its background;
• a review by someone who reads the language.

And if a banner can be rebuilt with live text, translate the text instead of the picture. For store-specific steps, see how to translate images on Shopify and how to localize email images.

Sources

• W3C, Understanding 1.4.5 Images of Text
• W3C, Understanding 1.4.9 Images of Text (No Exception)
• W3C, Understanding 1.1.1 Non-text Content
• W3C, Understanding 1.4.3 Contrast (Minimum)
• W3C WAI, Images tutorial: images of text
• W3C, Web Content Accessibility Guidelines (WCAG) 2.2
• EUR-Lex, Directive (EU) 2019/882, the European Accessibility Act
• ETSI, EN 301 549 V4.1.1
• DGCCRF (in French), products and services must comply with the accessibility directive
• Légifrance (in French), law 2023-171, article 16, décret 2023-931 and arrêté of 9 October 2023
• DINUM (in French), accessibilite.numerique.gouv.fr, the RGAA reference site

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