I agree that this seems to be an oversight. We have implemented eZ for some public sector clients that need the compliance. Hopefully there does not need to be a tradeoff for the functionality that the OE offers for uploading.
I'm in a similar position (also a public sector client). I love the power of eZ, and so far users prefer it to the expensive commercial package used on their main site as they can do so much more.
IIRC it worked differently in 3.5. Images were uploaded seperately and there was space to input a caption and alt text at upload time. The new version is simpler for users, I'll just have to add a bit to the manual I suppose, but I'm sure they'll forget.
For the same reasons, we were also looking at ways to require the alt-tag on classes that include an image. I guess if somebody makes a modification to the OE, it would be nice to include that option as well.