Should alt text say an image is AI-generated?

Nothing we found requires it, and nothing forbids it. The Commission's Article 50 guidance puts alt text outside the machine-readable marking rule, and no accessibility standard says how to mention how an image was made. Describe what the image shows, put any AI disclosure in its own text, and use the alt text for it only when no other text is available.

Published October 21, 2026. Last reviewed October 21, 2026.

Alt text answers one question: what does this image show, or do, here? An AI label answers another: how was it made? This guide is about whether the second answer belongs inside the first. It uses the sources we could read on October 21, 2026, and it is general information, not legal advice.

The labeling rules themselves are on our AI disclosure laws hub and the page on Article 50 of the EU AI Act. How to make a label reachable by assistive technology is in our guide to accessible AI labels, and the basics of writing alt text are in the complete guide to alt text.

What the sources say

Four sources touch the question. None answers it directly.

The Act and the Commission's Guidelines. Article 50(5) of Regulation (EU) 2024/1689 says the information "shall conform to the applicable accessibility requirements". Paragraph 144 of the Commission's Guidelines on Article 50 (C(2026) 5054 final, July 20, 2026, non-binding according to paragraph 5) adds that Article 50 "does not impose distinct or additional accessibility requirements." Neither says what alt text should contain.
Paragraph 68 of the Guidelines. It lists content that falls outside the machine-readable marking duty of Article 50(2), starting with "Outputs generated in the form of a short sequence of numbers, symbols or letters", and it names single words, image captions, alt-text, UI labels and icon-scale graphics as examples. That is a rule about providers of generative systems marking what their systems output, for example a model that writes alt text. It does not say whether the alt text of an AI-generated picture should mention how the picture was made.
The Commission's icons page (last updated October 13, 2026). It says "If possible, the icon should be readable by assistive technologies using alt text or ARIA labels indicating that the content is AI-generated or manipulated." This is the only official text we found that names alt text as a carrier of an AI statement. It is advice, it is hedged with "If possible", and it concerns the icon. The same page says the use of the icons "does not establish legal compliance by itself."
WCAG 1.1.1 asks for a text alternative "that serves the equivalent purpose". Our WCAG 1.1.1 explainer covers the criterion. WCAG does not mention AI, so the question becomes what purpose the image serves on this page.

Two other passages matter by implication. Paragraph 117 says a label for a deep fake should be "understandable and perceivable by natural persons (e.g. with visible or audible labels), without them needing to rely on any specific technical tools or performing dedicated actions". Alt text reaches only people who use assistive technology or whose images fail to load, so on our reading it cannot be the only place a required label appears. Paragraph 142 says information is clear when it is "noticeable, easy to understand by and accessible for the natural person concerned (including persons with disabilities)". Read together, they point to a visible label plus a text equivalent for people who cannot see it. The Guidelines do not say it in those words; that is our reading.

What nobody has settled

We found no authority that says alt text should state that an image is AI-generated, and none that says it should not. Specifically:

The W3C AI Content Disclosure Community Group published a final report in October 2026 (its address carries 20261009). It is a Community Group Report, which "does not establish a W3C Standard, adoption into HTML, or browser support." It proposes a way to declare how text was produced and puts AI-generated text alternatives, including alt text, within its scope. For an img element, the declaration "describes its authored text alternative, not the image's provenance".
WebAIM's alt text article, last updated on October 19, 2021, does not discuss AI-generated images. Our research on October 21, 2026 found nothing on AI labels in the W3C WAI image guidance or in the WCAG 3 working draft either.
A CHI 2024 paper studied alt text for AI images with image creators and screen reader users. Its abstract says "state-of-the-art image generation models do not output alternative (alt) text with their images". We could read only the abstract, so we do not cite its findings.

The two-layer pattern

Given that, we suggest two layers. This is our judgment, not a rule from any regulator or standard.

Layer one is the description. The alt text says what the image shows and does, as it would for any image. It leaves out how the image was made unless that changes what the image is on this page.
Layer two is the AI statement, in its own text, in a place everyone can reach: a visible caption in real text, or, when the label is an icon, that icon's own text alternative.

Keeping them apart has four practical effects. A screen reader user hears the description and the disclosure as two things and can skip either. A visible caption reaches people who see the image, people who use screen readers and people whose images do not load. The description stays accurate if the image is reused somewhere that needs no label. And if a rule changes the wording, you edit one caption, not every description.

<!-- Layer one in the alt text, layer two in a visible caption -->
<figure>
  <img src="/images/rain-jacket.webp"
       alt="Woman in a green rain jacket crossing a wet street">
  <figcaption>AI-generated image</figcaption>
</figure>

<!-- When the label is its own icon, the icon carries layer two -->
<div class="image-frame">
  <img src="/images/rain-jacket.webp"
       alt="Woman in a green rain jacket crossing a wet street">
  <img class="ai-icon" src="/images/ai-generated-black.svg"
       alt="AI-generated image" width="56" height="56">
</div>

If the only text you can edit is the alt text field, for example in a marketplace listing, a social post or a CMS with no caption, put a short statement in the alt text and keep the description after it: alt="AI-generated image of a woman in a green rain jacket crossing a wet street". We would lead with the statement when the picture is realistic enough that a listener could take it for a photograph, because that is the case the EU deep fake rule is aimed at. Keep it to a few words. Our guide to captions, alt text and figcaption explains why the same sentence should not appear in both.

Six images and where the AI wording goes (our reading, checked October 21, 2026)
Image	Alt text	Where the AI wording goes
A stylized AI illustration at the top of a blog post	Empty, if it adds nothing the text lacks (see decorative images)	Usually nowhere. For an image you publish, Article 50 asks for a label where the picture is a deep fake, and an obviously unrealistic picture is unlikely to be one (Guidelines paragraph 113).
A realistic AI-generated photo of a person wearing your jacket	What the picture shows: the person, the jacket, the street	A visible caption such as "AI-generated image". The Guidelines list an AI-generated product image that can mislead about the real product as a deep fake (paragraph 116).
A real product photo on an AI-generated background	The product and the setting, as usual	Not in the alt text. The Guidelines list this as a non-example as long as the ad is not likely to mislead about the product (paragraph 116). The file can still declare the edit in its metadata; see our guide to AI image metadata.
An empty apartment furnished with AI	The staged room, as a buyer would see it	A visible statement beside the photo, with a link to the original. See virtual staging disclosure.
A realistic AI-generated person in an advertisement	What the person is doing in the ad	The disclosure inside the ad itself. See synthetic performer ads.
Any image whose alt text an AI model drafted	The draft, after a person has checked it against the image	Not required by Article 50(2) according to paragraph 68. Review matters more than labeling here.

Describe the picture you have, not the prompt you wrote

AI images often differ from the prompt that produced them: an extra object, a sign with garbled lettering, a detail that is not there. Write the alt text from the image. A prompt describes an intention, and pasting it into the alt text can describe things the image does not contain. It can also publish wording you never meant to publish. If lettering in the picture is unreadable and that matters to the page, say so plainly, as in "a shop sign with illegible lettering".

The same rule applies to the file's metadata. The IPTC standard has a field for the prompt, and a tool that fills it in is publishing the prompt with every copy of the image. Our AI image metadata writer does not write a prompt.

If an AI wrote the alt text

Paragraph 68 puts alt text outside the machine-readable marking duty, so a model that drafts alt text does not have to mark it. The editorial duty is separate. Google's Search Central guidance on generative AI content (last updated October 1, 2026) says "It is critical to manually factcheck and review all AI-generated content for accuracy and trustworthiness before publishing", and that the review also applies to metadata such as "alternate texts for images, which can appear in Search results." The same page says "Sharing information about how a piece of content was created can help give your readers more context", without saying where on a page to put it.

We have measured one side of this. Our vision check of alt text, tested on 124 labeled alt texts, left 97.8% of correct alt text alone and flagged 98.4% of planted errors, and the misses are listed in our AI alt text accuracy test. That is a test of judging alt text, not of writing it, so it does not tell you how accurate a drafted alt text is. Read each draft against its image before it goes live.

What a check can and cannot tell you

A tool can read what a page and a file declare. It can find the words "AI-generated" in alt text, in a figcaption or in text next to an image, and it can read the markers a file carries. Our free AI label checker does the first on a live page, and our accessible AI label generator writes caption text and markup with the text equivalent included. Neither can tell whether an image is AI-generated: Anthropic's documentation for the vision model we use says it "cannot determine whether an image is AI-generated", and a file with no marker proves nothing. Neither says a label is sufficient.

What this guide does not settle

No authority has ruled on alt text. The two-layer pattern is our judgment. The Guidelines are non-binding, as paragraph 5 says.
Paragraph 68 is about marking by providers. It is not a statement about what the alt text of an AI picture should say.
Whether a given image needs a label at all depends on the deep fake test in Article 3(60), applied to the foreseeable audience. Many AI images are not deep fakes.
No enforcement under Article 50 turned up in the sources we read on October 21, 2026. That says nothing about what authorities will do later.

Alt text and AI image questions

Do I have to write "AI-generated" in the alt text of my AI images?

No source we read requires it. Article 50 asks for a clear and distinguishable disclosure of certain AI content, and the Guidelines say the disclosure must meet accessibility rules that already apply. None of that names alt text as the place. If a visible label exists, give its words a text equivalent, preferably a caption.

Does alt text that an AI model wrote need its own AI label?

Paragraph 68 of the Guidelines puts alt text outside the Article 50(2) marking duty. The text limb of Article 50(4) covers AI-generated text published to inform the public on matters of public interest, which product alt text is not, in our reading. Check the text against the image either way.

What if my platform only gives me an alt text field?

Put a short statement first and the description after it, for example "AI-generated image of an orange two-person tent pitched on grass". Keep it to a few words, and do it only for images that need a label, such as a realistic person who does not exist.

Should a decorative AI image have alt=""?

Yes, if it is decorative: an empty alt hides it from a screen reader. If the image also needs an AI label, put the label in a visible caption or in the label's own text, not in the empty alt. Our decorative images guide explains when an image counts as decoration.

Does Google want "AI-generated" in alt text?

Not in anything we read. Google Merchant Center asks that AI-generated product images carry the IPTC DigitalSourceType value trainedAlgorithmicMedia in the file, and its Search guidance asks for human review of AI-written alt text. Neither page tells you to write the words into alt text.

Can the metadata tag do the job instead of a label?

For a deep fake label, no. Paragraph 117 says deployers cannot rely on the machine-readable marking the provider embeds, because those markings are not immediately clear and distinguishable to the people who see the content. Metadata also goes missing when a CDN resizes the file.

AI disclosure laws: every AI disclosure rule we track, with its source and the date we checked it.
Virtual staging disclosure: California AB 723, the MLS rules we could verify and the EU icon page's example.
AI chatbot disclosure: the EU provider duty, the US business duties and wording that works.
Synthetic performer ads: New York GBL 396-b and California SB 1050 compared.
AI image metadata: C2PA, IPTC and XMP markers, who reads them and what survives a CDN.
Accessible AI labels: what EU Article 50(5) asks, the WCAG criteria a label touches and the pixels problem.

See which images show AI wording

Check up to 50 pages once, $49, no subscription. The Site Image Check has an AI disclosure section: for each image, the AI markers the file declares and whether the page shows AI-label text with it (alt text, figcaption or adjacent text). It never decides whether an image is AI-generated. To test one page first, use the free AI label checker.

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