As far as I know, there's not a requirement. Under the UCC in most states, a statement that provides the check number, amount and date of payment is sufficient for check entries (see UCC, section 4-406(a), as enacted in your state).
However, customers may have certain expectations based on the types of statements they have received in the past. In the interests of avoiding misunderstandings and ill-will at a minimum, I'd suggest that you inform customers of the fact they won't get images (or that images cost more). Be prepared to tell them how to obtain images when they need them (using your online banking system or contacting Depositor Services, or ...).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8