Alt text and captions on UGC are an accessibility issue, not just a legal checkbox

What WCAG 2.2 requires of customer content

WCAG 2.2 is the current W3C Recommendation (the latest version is dated 12 December 2024). Most accessibility policies and audits target Level AA, which includes every Level A criterion. These are the ones a UGC gallery touches most often.

The pattern in that table is that most of the obligations fall at Level A, the baseline. They are not stretch goals for a mature programme. The video-specific detail, including player controls and focus handling, is covered in accessibility in shoppable video.

The European Accessibility Act and e-commerce

The European Accessibility Act is Directive (EU) 2019/882. It lists e-commerce among the services it covers and defines e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. Member States had to apply their national measures from 28 June 2025.

The microenterprise exemption is narrower than it sounds. Article 4(5) exempts microenterprises providing services, and Article 3 defines a microenterprise as one that employs fewer than 10 people and has an annual turnover or annual balance sheet total not exceeding EUR 2 million. A brand with 12 staff selling into the EU is in scope for its storefront, including the gallery on it.

The Act's service requirements are framed around making content perceivable, operable, understandable and robust, the same four principles WCAG is organised under, and the harmonised European standard used to show conformance, EN 301 549, builds on WCAG. Enforcement sits with national authorities, so penalties and procedures vary by country. If you sell into the EU, get specific legal advice for the markets that matter to you; this article is not that.

What a screen reader and a muted player actually present

Missing alt. When an image has no alt attribute at all, some screen readers fall back to announcing the file name, which for UGC is usually a CDN string. An empty alt is worse in a different way: it tells assistive technology the image is decorative, so a photo doing real persuasive work is skipped entirely.

Caption as alt. A common shortcut is to drop the source post's caption into the alt attribute. Social captions are written for engagement, not description, so the result is often a run of hashtags, emoji names and an @mention, read aloud in full on every tile. It fills the attribute and conveys nothing about what the photo shows.

Uncaptioned video. A shopper who is deaf or hard of hearing, or simply watching with the sound off on a train, sees a person talking about the product with the actual argument missing. The specific claim that makes a testimonial persuasive is in the audio.

Writing alt text for UGC that does the job

Good alt text for a customer photo says what the photo is evidence of. That is usually three things: that it is a customer photo, which product it shows, and the context that makes it useful (a size on a body, a colour in daylight, the item in a real room). Product tags supply the first two automatically; the context is what a human adds.

Keep it short, since screen reader users hear every tile. Don't start with "image of", which is announced already. Don't describe the customer's appearance beyond what is relevant to the product, and never guess at attributes like ethnicity or body type. If a tile is a link to a product, the alt text should make the destination clear.

Captions and descriptions for customer video

Captions from the source platform rarely survive import, so plan to generate your own. Automatic transcription is a reasonable first draft; product names, sizes and prices are exactly where it goes wrong, so correct the clips that get the most display time first. Closed captions that the viewer can toggle are more flexible than text burned into the frame, but burned-in captions are better than none. The practical detail is in captions and subtitles for shoppable video.

For visual-only information, such as a clip showing how a fabric moves with no narration, a short text description beside the player covers 1.2.3 at Level A. Autoplay is a separate issue: muted autoplay avoids the 1.4.2 problem, and a visible pause control on auto-advancing reels covers 2.2.2.

A workflow that scales to thousands of posts

Two rules keep the backlog manageable. Prioritise by exposure: fix the posts in live rotation before the archive, which is easier if you rotate the gallery monthly. And attach the human edit to moderation rather than creating a separate accessibility queue, since moderating UGC at scale already means someone looks at every post that goes live, and a moderation queue is where that look happens.