Short answer
Yes, Apple says the data a Legacy Contact might be able to access can include photos.
That is one reason the feature is worth setting up.
What that answer does not mean
It does not mean:
- the contact gets your passcode
- the contact gets iCloud Keychain passwords
- the contact gets every non-Apple account connected to the phone
Apple's own support material separates accessible Apple account data from excluded Keychain credentials and purchased media.
Why this still needs planning
If family members only need certain albums, archives, or files, leave that context somewhere else too.
Otherwise they may receive Apple access but still not know:
- what should be preserved
- what can be ignored
- what belongs to the estate record
Better question to ask
Do the right people know:
- that photos are important
- where the rest of your records live
- who should handle the Apple account after access is granted
That is a planning question, not just a feature question.
