What Is WCAG 2.2 Success Criterion 1.1.1?
WCAG 2.2 Success Criterion 1.1.1 (Non-text Content) is a web accessibility rule that says: every image, icon, button, chart, or other non-text item on a website must have a written description attached to it. That description is called alternative text, or alt text.
The rule exists so that people who cannot see images — for example, someone using a screen reader because they are blind — can still understand what is on the page.
SC 1.1.1 is a Level A requirement. Level A is the minimum standard under WCAG 2.2, and all UK businesses are expected to meet it under the Equality Act 2010.
A Plain-English Guide to WCAG 2.2 Success Criterion 1.1.1: Non-text Content (Level A)
Table of Contents
- Why This Matters More Than You Think
- What Is WCAG 2.2 — And What Does Level A Mean for You?
- So What Exactly Is Success Criterion 1.1.1?
- Who Uses Alt Text — And Why It’s Not Just About Screen Readers
- Breaking Down the Rules: What Needs Alt Text (and What Doesn’t)
- How to Write Alt Text That Actually Works
- Common Mistakes Businesses Make (and How to Fix Them)
- Frequently Asked Questions
- Next Steps: Going Beyond the Basics
- Glossary of Key Terms
- How UZURI Digital Can Help
1. Why This Matters More Than You Think
Picture this. A potential customer lands on your website. They’re looking for a product you sell, they’re ready to buy, and they’ve heard great things about your business. But they’re blind, and they use a screen reader — software that reads out everything on a webpage. They reach your product images. Silence. No description. No context. Nothing.
They leave.
This scenario is backed by hard numbers. Research published in the Click-Away Pound Report found that 4 million people with disabilities clicked away from inaccessible websites in the UK — costing businesses an estimated £17.1 billion in lost online sales. Separately, We Are Purple estimates that UK businesses lose approximately £2 billion every month by failing to meet the needs of disabled consumers.
These aren’t abstract concerns. The WebAIM Million 2025 report — which analyses the accessibility of the top one million websites globally — found that 18.5% of all images analysed had missing alternative text, making it one of the six most common accessibility failures detected, a list that has remained unchanged for six consecutive years. In practical terms, that means roughly one in five images on the web right now is completely invisible to screen reader users.
Here’s why that matters for your business specifically:
According to the Department for Work and Pensions’ Family Resources Survey 2023/24, 16.8 million people in the UK are living with a disability — that’s 25% of the total population, or one in four people. The collective spending power of disabled people and their households — often called the Purple Pound — is estimated at £274 billion per year in the UK alone.
And yet, despite this enormous market, research by Scope found that 73% of disabled online shoppers have encountered barriers on more than a quarter of the websites they visited. When your website fails to work for disabled users, you’re not just creating a frustrating experience — you are, in many cases, actively turning away a significant portion of your potential customer base.
The good news? One of the most impactful fixes is also one of the simplest: adding alternative text (alt text) to your images and other non-text content.
This guide will walk you through everything you need to know about WCAG 2.2 Success Criterion 1.1.1 — what it is, what it requires, how to do it well, and what it means for your legal obligations as a UK business. No jargon. No overwhelm. Just clear, practical information.
By the end of this guide, you’ll know:
- What SC 1.1.1 is and why it sits at the very foundation of web accessibility
- Your legal obligations as a UK business, grounded in real legislation
- Exactly what types of content need alt text — and a few that don’t
- How to write alt text that genuinely helps users
- The most common mistakes businesses make and how to avoid them
2. What Is WCAG 2.2 — And What Does Level A Mean for You?
Let’s start with the basics. WCAG stands for Web Content Accessibility Guidelines. It’s the internationally recognised standard for making websites and digital content accessible to everyone, including people with disabilities. The guidelines are published by the World Wide Web Consortium (W3C), and they’re used by governments, businesses, and developers around the world.
The current version — WCAG 2.2 — was published in October 2023. As of October 2024, the UK Government’s own Digital Service guidance requires public sector organisations to meet WCAG 2.2 AA.
But what about private businesses? That’s where it gets important for you.
The Three Levels: A, AA, and AAA
WCAG is divided into three conformance levels, each one building on the last:
- Level A — The minimum baseline. These are the most essential requirements, and failing to meet them creates the most significant barriers for users with disabilities. Every business with a website should be meeting Level A.
- Level AA — The standard that most businesses should be reaching. It covers a broader range of disabilities and provides a significantly better experience for all users. Most UK public sector bodies are legally required to meet Level AA.
- Level AAA — The highest and most comprehensive level. Not all content can meet AAA, but some organisations — particularly those serving specific at-risk communities or providing essential services — are expected to strive toward it.
Where Does the Law Come In?
For UK businesses, there are two key pieces of legislation to be aware of:
The Equality Act 2010 applies to all businesses — public and private — that provide goods or services to the public. Under Sections 20 and 29, organisations are required to make “reasonable adjustments” to ensure disabled people are not disadvantaged, and are prohibited from discrimination by failing to provide adequate access. While the Act doesn’t cite WCAG directly, meeting WCAG 2.2 Level A is widely recognised as the minimum standard that demonstrates reasonable adjustment for digital services.
The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 go further — requiring public sector bodies to meet WCAG 2.2 Level AA as of October 2024. If your business works with the public sector, supplies digital services to government, or is funded publicly in any way, these regulations may apply to you directly.
It’s worth being transparent about the current enforcement picture: according to Eye-Able’s legal overview, while no organisations have been successfully prosecuted under the Equality Act specifically for website accessibility failures, several discrimination cases have been settled out of court. The Royal National Institute of Blind People (RNIB) has brought forward multiple accessibility-related discrimination claims, typically achieving settlements requiring organisations to improve their digital accessibility. Notably, in 2023, a settlement of £3,000 was awarded to a blind man who was unable to use a screen reader to access the Health and Social Care Northern Ireland website when applying for a job promotion (CDP Communications, 2024).
The legal framework is clearly in place, enforcement activity is growing, and the reputational cost of being named as a discriminatory organisation can far outweigh the cost of getting it right in the first place.
The bottom line? Level A is the legal baseline for all UK businesses. Level AA should be your target. And SC 1.1.1 is a Level A requirement — meaning it applies to you right now, regardless of your size or sector.
3. So What Exactly Is Success Criterion 1.1.1?
Success Criterion 1.1.1 sits under Guideline 1.1: Text Alternatives, which is the very first guideline in WCAG. That’s not a coincidence — it’s foundational.
Here’s the official definition from WCAG 2.2:
“All non-text content that is presented to the user has a text alternative that serves the equivalent purpose, except for the situations listed below.” — WCAG 2.2, Success Criterion 1.1.1 (Level A)
In plain language: if it’s not text, you need to provide a text version of what it means or does.
Non-text content includes:
- Images (photos, illustrations, graphics)
- Icons and logos
- Charts and graphs
- Infographics
- Buttons that use images instead of text
- Audio files
- Video content
- CAPTCHA challenges
- SVG graphics
- CSS background images that carry meaning
The purpose of this requirement is to ensure that any information communicated through a visual or non-text format is also available in text — so it can be read aloud by screen readers, translated into Braille, displayed in high contrast, or presented in whatever format works best for the individual user.
This criterion falls under the Perceivable principle of WCAG — the idea that all users must be able to perceive the information on your website, regardless of how they access it.
📋 Accessibility Level: A — applies to all UK businesses under the Equality Act 2010
4. Who Uses Alt Text — And Why It’s Not Just About Screen Readers
It’s tempting to think of alt text as a niche requirement for a small group of visually impaired users. But the reality is much broader — and understanding it changes how you think about this requirement entirely.
Screen reader users are the most commonly cited group. Screen readers are used by people who are blind or have severe visual impairments — software like JAWS, NVDA, or VoiceOver reads out the content of a page in sequence, including alt text descriptions for images. According to the DWP Family Resources Survey 2023/24, the most common impairments among working-age disabled adults in the UK include mental health conditions (48%) and mobility impairments (42%), but visual and cognitive impairments also affect millions of people.
People with low vision often use screen magnifiers, and alt text helps them understand images when zoomed in at a level where context is lost.
People with cognitive disabilities may find it easier to process written descriptions alongside or instead of complex visuals.
Users with slow internet connections — more common than you might think, especially in rural areas — may have images disabled or experience images that fail to load. Alt text is what gets displayed in place of a broken or blocked image.
Search engine crawlers cannot see images. Alt text is one of the primary ways Google and other search engines understand what your images are about and what your page covers. Well-written alt text is, quite simply, good SEO.
Voice assistant users increasingly interact with web content through voice, where images must be described in order to be understood.
The scale of the audience makes this undeniably relevant to any business. According to the House of Commons Library’s briefing on UK disability statistics, 25% of the total UK population — 16.8 million people — reported a disability in 2023/24. That figure has been rising consistently: it was 18% in 2002/03 and is projected to keep growing as the population ages. And because disabled households include family members and friends who often make purchasing decisions collectively, We Are Purple estimates that the total spending influence extends to a £274 billion annual market.
An inaccessible website doesn’t just fail those individuals — it also signals something about your values to everyone who uses it.
5. Breaking Down the Rules: What Needs Alt Text (and What Doesn’t)
WCAG 1.1.1 isn’t a blanket rule that applies identically to every image. It recognises that different types of non-text content serve different purposes, and the requirements vary accordingly. Here’s how to think about each situation.
Informative Images
These are images that convey information that isn’t otherwise available in the text around them. A photo of a product, a graph showing sales data, an illustration explaining a process — all of these need descriptive alt text that communicates the same information.
Example: An image of a bar chart comparing quarterly sales across three regions needs alt text that describes what the chart shows, such as: “Bar chart showing Q1 to Q3 2024 sales. Region A leads with £1.2M in Q3, followed by Region B at £0.9M and Region C at £0.6M.”
Functional Images (Buttons and Links)
If a non-text element is a control — like an image used as a button, a search icon, or a logo that links back to the homepage — the alt text should describe the function, not the appearance.
Example: A magnifying glass icon that triggers a search function should have alt text that says “Search”, not “magnifying glass icon”.
Decorative Images
Not all images carry meaning. A decorative swirl used as a visual divider, a generic stock photo used purely for aesthetic purposes, or a background texture that adds no information — these should be given a null alt attribute (alt=””). This tells screen readers to skip the image entirely, avoiding unnecessary noise for the user.
Note: Getting this wrong in either direction causes problems. Giving a decorative image descriptive alt text creates confusion. Giving an informative image null alt text hides important content.
Complex Images (Charts, Graphs, Infographics)
For complex visuals where a short description isn’t enough, you need both a brief alt text and a longer description elsewhere on the page (or linked from it). An infographic summarising a report, for instance, may need a full text equivalent provided on the same page.
Images of Text
If an image contains text — such as a banner that reads “Summer Sale 50% Off” in stylised lettering — the alt text should include the exact words shown in the image.
Audio and Video Content
For audio or video files, SC 1.1.1 requires at minimum a descriptive title or label that identifies the content. Full captions and transcripts are addressed by other WCAG criteria (Guideline 1.2), but the basic identification requirement starts here at SC 1.1.1.
CAPTCHA
CAPTCHA challenges need alt text that explains their purpose (e.g. “CAPTCHA: Type the characters shown to prove you are human”) and must be accompanied by an alternative method — such as an audio CAPTCHA — so that users who cannot see the visual challenge still have a way to proceed.
When Alt Text Is Not Required
There are a small number of exceptions under SC 1.1.1. Non-text content used purely as a test or exercise (where describing it would defeat the purpose), and content that creates a specific sensory experience (such as abstract art), only need a basic identification label rather than a full equivalent description.
6. How to Write Alt Text That Actually Works
Writing effective alt text is part technical requirement, part craft. Here are the principles that make the difference between alt text that passes an audit and alt text that genuinely helps users.
Be descriptive, but be concise
Alt text should convey the equivalent meaning of the image in as few words as possible. There’s no strict character limit, but as a general rule, aim for under 125 characters for simple images. If more is needed, that’s usually a signal you may need a longer description alongside the image.
Describe what matters, not everything
You don’t need to describe every visual detail. Focus on the information that would be lost if the image weren’t there. Ask yourself: “If someone couldn’t see this image, what would they be missing?” That’s what your alt text should communicate.
Don’t start with “Image of…” or “Picture of…”
Screen readers already announce that they’re reading an image. Starting alt text with “Image of” is redundant and wastes characters. Just describe the content directly.
Context is everything
The same image can require different alt text depending on where it appears. A photo of a busy high street used as a decorative hero image on your homepage might be treated as decorative. The same photo used in an article about retail footfall in 2024 carries real information and needs descriptive alt text.
Practical examples
| Situation | Poor Alt Text | Good Alt Text |
|---|---|---|
| Company logo linking to homepage | “logo” | “UZURI Digital — return to homepage” |
| Product photo | “IMG_4821.jpg” | “Blue leather laptop bag with silver zip, front pocket and carry handles” |
| Infographic about recycling rates | “infographic” | “Infographic: UK recycling rates by region 2023. See full data below.” |
| Decorative divider | “swirl” | (null — alt=””) |
| Search button icon | “icon” | “Search” |
7. Common Mistakes Businesses Make (and How to Fix Them)
Despite being one of the most well-known accessibility requirements, SC 1.1.1 violations remain among the most common findings in accessibility audits globally. The WebAIM Million 2025 report found that missing image alternative text appeared on approximately 54% of home pages in 2024 (the figure improved slightly to affect around 18.5% of individual images in 2025, though the six failure types driving nearly all detected errors remained unchanged year-on-year). Here’s what to watch out for.
Mistake 1: Missing alt attributes entirely The most common failure. If an <img> tag has no alt attribute at all, screen readers will often read out the filename — which is meaningless to users. Fix: Ensure every image element has an alt attribute, even if it’s null for decorative images.
Mistake 2: Using filenames or placeholder text Alt text like “image001.jpg”, “photo”, or “image” tells users nothing useful. Fix: Always write a meaningful description that reflects the purpose or content of the image.
Mistake 3: Treating all images as informative Not every image needs a text description. Marking decorative images as decorative (alt=””) prevents screen reader users from being read irrelevant announcements. Fix: Review each image individually and make a conscious decision about whether it’s informative or decorative.
Mistake 4: Over-describing complex images Cramming a detailed description of a complex chart into a short alt text field rarely works well. Fix: Use a brief alt attribute to identify the content, then provide a full text equivalent elsewhere on the page.
Mistake 5: Not updating alt text when images change Many websites update images — product photos, staff headshots, promotional banners — without updating the associated alt text. Fix: Include alt text review in your image update process and content workflow.
Mistake 6: Icon fonts and CSS background images These are easy to miss. Icon fonts (like Font Awesome icons) that carry meaning, and CSS background images that convey information, are non-text content and must meet the same requirements. Fix: Use ARIA labels or visually hidden text for meaningful icons, and avoid using CSS background images for informative content.
8. Frequently Asked Questions
Does SC 1.1.1 apply to my small business? Yes. The Equality Act 2010 applies to any business providing goods or services to the public, regardless of size. Level A requirements — including SC 1.1.1 — represent the baseline that all UK businesses should be meeting. The Act’s Sections 20 and 29 make clear that providing an equal digital experience is a legal obligation, not just good practice.
Do I need to add alt text to every single image on my website? You need to make a decision about every image. Informative images need descriptive alt text. Decorative images should have a null alt attribute (alt=””). There’s no situation where ignoring the alt attribute entirely is acceptable practice.
What about social media images? Most major platforms — including LinkedIn, X (formerly Twitter), Instagram, and Facebook — now support alt text for images. While SC 1.1.1 technically applies to your own website, applying the same principles to your social media content is good practice and increasingly expected, particularly for businesses focused on inclusive communication.
Is alt text the same as image captions? No. A caption is visible text displayed below or near an image, intended for all users. Alt text is a behind-the-scenes attribute read only by assistive technologies (and displayed if an image fails to load). Both can add value, and they serve different purposes.
What if my website was built by an agency? Is it still my responsibility? Yes. As the business owner or website owner, the responsibility for accessibility compliance ultimately sits with you. When commissioning or updating your website, you should specify accessibility requirements — including WCAG 2.2 Level A at minimum — as part of your brief.
Does having an accessibility statement mean I’m compliant? No. An accessibility statement is a document that discloses your website’s accessibility status. It’s a required component of compliance for public sector organisations, but publishing one does not mean your site is accessible. You need to actually meet the requirements.
Could I face legal action if I don’t comply? The Equality Act 2010 does allow individuals to bring discrimination claims against businesses that fail to make reasonable adjustments. To date in the UK, most cases have been settled out of court, with organisations typically agreeing to improve their digital accessibility — as confirmed by Eye-Able’s legal analysis. However, the legal mechanism is clearly established. Beyond legal risk, the business cost of inaccessibility — measured in lost customers and lost revenue — is often a more immediate concern. The Click-Away Pound Report estimated that UK businesses were collectively losing £17.1 billion in revenue from disabled shoppers abandoning inaccessible websites.
9. Next Steps: Going Beyond the Basics
Meeting SC 1.1.1 is a great start — but it’s just the beginning of building a truly accessible website. Here’s how to keep building on this foundation:
Audit your existing content. Conduct a thorough review of all images, icons, and non-text elements currently on your website. Free tools like WebAIM’s WAVE Accessibility Checker or the axe browser extension can identify missing or empty alt attributes quickly. These tools won’t catch everything, but they’re a practical first step.
Build it into your process. Accessibility shouldn’t be a one-off fix — it should be part of how your team creates and publishes content. Include alt text as a required field in your content management system, and ensure everyone who publishes content knows how to write it well.
Move toward Level AA. Once you’re confident in your Level A compliance, WCAG Level AA is where most UK businesses should be aiming. This includes considerations like colour contrast (SC 1.4.3), captions for pre-recorded video (SC 1.2.2), and keyboard accessibility (SC 2.1.1). The GOV.UK Service Manual provides excellent plain-language guidance on what each criterion means in practice.
Consider a professional accessibility audit. Automated tools catch common issues, but they can’t catch everything — research consistently shows automated tools detect only a portion of real-world accessibility barriers. A manual audit — especially one that includes testing with real assistive technology users — gives a much more complete picture of your website’s accessibility.
Think about your whole digital presence. Your website isn’t the only place accessibility matters. PDFs, email newsletters, presentations, social media posts — all of these are digital content that can and should be made accessible. The same principles that underpin SC 1.1.1 apply across all of these formats.
10. Glossary of Key Terms
Alt text (alternative text): A written description of an image, added as an attribute in the HTML code, which is read aloud by screen readers or displayed if an image fails to load.
ARIA (Accessible Rich Internet Applications): A set of HTML attributes that can be added to elements to improve their accessibility for assistive technologies. For example, aria-label can provide a text label for an element that doesn’t have visible text.
Assistive technology: Hardware or software used by people with disabilities to help them interact with digital content. Examples include screen readers, screen magnifiers, voice recognition software, and alternative keyboards.
CAPTCHA: A challenge-response test used to determine whether a user is human or a bot, typically involving text recognition or image identification.
CSS (Cascading Style Sheets): Code used to control the visual presentation of a webpage. CSS background images are sometimes used to display images that can be missed by accessibility audits.
Decorative image: An image that adds no informational value to a page and is used purely for visual aesthetics. These should have a null alt attribute so screen readers skip them.
Equality Act 2010: UK legislation that protects individuals from discrimination, including on the grounds of disability. It requires businesses to make reasonable adjustments for disabled people, including in digital services.
Informative image: An image that conveys meaningful information that is not available through surrounding text. These require descriptive alt text.
Null alt attribute: An alt attribute with an empty value (alt=””), used for decorative images to tell screen readers to ignore them.
Purple Pound: The term used to describe the collective spending power of disabled people and their households in the UK, estimated at £274 billion per year by We Are Purple.
Screen reader: Software that converts text and other content on a computer screen into speech or Braille output. Examples include JAWS, NVDA (Windows), and VoiceOver (Apple).
SVG (Scalable Vector Graphics): A type of image format that uses XML code to define graphics. SVGs can carry semantic meaning and may require accessible names via ARIA attributes.
WCAG (Web Content Accessibility Guidelines): The internationally recognised standard for digital accessibility, published by the W3C. The current version is WCAG 2.2.
W3C (World Wide Web Consortium): The international standards organisation responsible for publishing WCAG and many other web standards.
WebAIM Million: An annual report by WebAIM that analyses the accessibility of the top one million website home pages globally. It is one of the most widely cited sources of data on the state of web accessibility.
11. How UZURI Digital Can Help
At UZURI Digital, we specialise in helping UK businesses navigate the world of web accessibility — not just to tick a compliance box, but to build digital experiences that genuinely work for everyone.
We understand that terms like “WCAG 2.2” and “Success Criterion 1.1.1” can feel dry and technical. Our job is to translate that into practical action for your business — whether you’re starting from zero, trying to understand your current position, or working toward full Level AA compliance.
Here’s how we can support you:
- Accessibility Audits — We’ll review your website against WCAG 2.2 criteria and provide a clear, prioritised report of what needs attention and why.
- Remediation Support — Whether you need a full rebuild or targeted fixes, our team can work with your existing developers or handle it directly.
- Training & Workshops — We run practical sessions for marketing teams, HR departments, and content creators on how to produce accessible digital content every day.
- Ongoing Monitoring — Accessibility isn’t a one-time project. We offer ongoing monitoring and support to ensure your website stays compliant as it evolves.
If you’ve read this far and you’re wondering where your website stands right now, the best place to start is a conversation. No pressure, no jargon — just a straight-talking discussion about what’s working, what isn’t, and what the realistic options are for your business.
Ready to take the first step? Get in touch with the UZURI Digital team today.
This guide is part of UZURI Digital’s ongoing Web Accessibility series, designed to help UK businesses understand and act on their accessibility obligations. Each post in the series covers a specific WCAG 2.2 success criterion with clear explanations, practical examples, and actionable next steps.
Key Sources & Further Reading
- WCAG 2.2 — W3C Official Guidelines
- GOV.UK Service Manual: Understanding WCAG
- GOV.UK: Meet the requirements of equality and accessibility regulations
- Equality Act 2010 — UK Legislation
- Public Sector Bodies Accessibility Regulations 2018
- WebAIM Million 2025 Report
- WebAIM Million 2024 Report
- House of Commons Library: UK Disability Statistics
- DWP Family Resources Survey 2023/24
- We Are Purple: The Purple Pound Infographic
- Scope: Disabled Customers and the Purple Pound
- Click-Away Pound Report
- Eye-Able: Equality Act 2010 and Digital Accessibility
- WAVE Web Accessibility Evaluation Tool
- axe DevTools Browser Extension