Currently, ORES wp10 uses an 'image_links' feature that counts only images in an article if they use the normal [[File:Something.jpg]] markup format. Images withing gallery tags are not counted, and lead images in infoboxes are not counted.
In both cases, counting those images would be a better reflection of the image count, in terms of article quality.
See for example this article: https://en.wikipedia.org/wiki/The_Appearance_of_Christ_Before_the_People
ORES thinks it has one image, instead of the six it actually has: https://ores.wmflabs.org/v3/scores/enwiki/?models=wp10&revids=782180234&features