EN 301 549 § 10
The European harmonised standard explicitly references PDF/UA-1 for non-web documents. Procurement under the European Accessibility Act (EAA) routinely requires PDF/UA conformance for PDFs delivered with a product or service.
PDF/UA-1 (ISO 14289-1) is the single international standard for accessible PDF. The Matterhorn Protocol turns that standard into 31 machine-testable checkpoints and 136 failure conditions. This page explains what each of them means, which are automatable, and where the WCAGHub PDF Checker runs them for you.
Two related documents that together define what makes a PDF accessible — one at the standard level, the other at the test level.
The international standard published in 2012 and amended in 2014. Specifies how a PDF must be tagged, what metadata it must carry, and which features are forbidden (untagged content, images without alt text, security that blocks assistive tech).
Published by the PDF Association (2014, revised 2021). Translates PDF/UA-1 into 31 checkpoints and 136 failure conditions — telling software how to test and telling humans what to look for. It's the reference test suite.
Published 2024, based on PDF 2.0. Adds MathML, improved list and table semantics, pronunciation hints, and better support for complex scripts. Tooling support is still emerging — most compliance programmes in 2026 still target PDF/UA-1.
PDF/UA and WCAG overlap but aren't identical. A PDF can fail WCAG and still be valid PDF/UA if the failure is outside PDF/UA's scope (e.g. colour contrast is a WCAG concern, not a PDF/UA one). Serious compliance programmes test both.
WCAG was written for web pages. When the law requires accessible documents, it almost always reaches for PDF/UA as the PDF-specific technical norm.
The European harmonised standard explicitly references PDF/UA-1 for non-web documents. Procurement under the European Accessibility Act (EAA) routinely requires PDF/UA conformance for PDFs delivered with a product or service.
Revised Section 508 requires that electronic documents meet WCAG 2.0 AA. US federal agencies and many state programmes use PDF/UA as the conformance test because it's machine-verifiable.
UK public sector bodies must publish accessible documents under PSBAR 2018. PDF/UA is the accepted PDF-level conformance test referenced in government accessibility guidance.
The Australian Digital Transformation Agency recommends PDF/UA-1 for all government PDFs. DDA complaints involving inaccessible PDFs routinely reference PDF/UA as the expected standard.
Ontario's AODA and federal ACA both include PDFs under their accessible information requirements. Canadian government procurement explicitly references PDF/UA.
National libraries and archives (e.g. DNB, Library of Congress, NLA) accept PDF/UA as the long-term preservation format for accessible documents — because tagging survives migration.
Every checkpoint has a number and a plain-English intent. The pills below mark whether we test it automatically (Auto), partly automatically (Hybrid), or whether human review is required (Manual).
Real content (text, images, annotations) must be marked as tagged. Artifacts (headers, page numbers, decoration) must be marked as artifact. Our checker flags any untagged content or missing /MarkInfo /Marked true entry.
Custom tag names must map to a standard PDF structure type (/H1, /P, /L, etc.). Tool checks the role map exists and is well-formed; a human confirms the mapping is semantically correct.
Structure elements must be nested correctly — e.g. <LI> only inside <L>, <TH> and <TD> only inside <TR>. Our 161 checks include the full VeraPDF rule set for structural nesting.
All text content must have a Unicode mapping — no private-use glyphs, no font subset with broken ToUnicode CMaps. Screen readers depend on this entirely.
Acrobat's “Suspect” flag in the Accessibility report marks content that looks like it may be missing tags. Matterhorn requires a human to confirm each one isn't a false positive.
Title, language, and the PDF/UA identifier must be present in XMP metadata. Tool checks dc:title, Catalog /Lang, and pdfuaid:part = 1.
Structure tree root, /ViewerPreferences /DisplayDocTitle true, and natural language must all be declared correctly at the catalog level.
Every meaningful image must be tagged as <Figure> with an Alt entry, or marked as an artifact if purely decorative. Tool detects missing alt text automatically; a human decides whether the alt text is meaningful.
Headings must use the <H1>…<H6> structure types and form a logical hierarchy (no jumps from H1 to H4). Tool checks the tags and order; human confirms visual heading style matches.
Real tables must use <Table>, <TR>, <TH>, <TD>. Header cells need a Scope attribute (Row / Column / Both) or an explicit Headers / ID relationship for complex tables.
Lists must use <L> with <LI> children. Each <LI> needs a <Lbl> and <LBody>. Visually “listy” paragraphs that aren't tagged as lists are flagged.
Mathematical expressions must be tagged as <Formula> with meaningful Alt or MathML (PDF/UA-2). Our tool flags formulae that lack alt; a human writes the actual alt text.
Running headers, footers and page numbers must be tagged as artifacts (pagination / header / footer). If they're left as real content, screen readers read them on every page.
Information must not be conveyed by colour alone. Contrast ratios (4.5:1 normal, 3:1 large) are a WCAG concern but widely audited alongside PDF/UA. Tool samples contrast automatically where foreground+background are detectable.
Fonts must be embedded (full or subset) with correct ToUnicode CMaps and Widths arrays. Checker validates every font in the resource dictionary.
Security settings must not block assistive technology. If the PDF is encrypted, the /P bit 10 (extract for accessibility) must be set.
When optional content groups are used, the order must be defined and each group must have a descriptive name. Hidden layers cannot hide essential content.
File attachments must have meaningful descriptions. Our checker flags attachments with missing descriptions; a human writes the text.
If article beads are present, they must respect logical reading order. Tool validates thread structure against reading order tree.
Signature fields must have accessible names and descriptions. The visible signature appearance must be tagged, not left as raw XObject content.
Blank lines, check boxes rendered as images, and similar “print-and-fill” forms must be either converted to interactive form fields or accompanied by an accessible alternative.
Every annotation in the Annots array must either be tagged in the structure tree or marked as an artifact. Stamps, rubber-band highlights, and comments are common offenders.
Every page that contains annotations must declare /Tabs /S (structure order). Visual order, forms logic, and screen-reader order then all agree.
Every form field must have a TU tooltip (screen-reader label) and, where applicable, a T partial name. Required fields must be programmatically indicated.
Link annotations must be inside a <Link> structure element with a /Contents entry or a child text run that describes the purpose. “Click here” is not descriptive.
Audio and video must have captions or transcripts. Our tool flags media annotations; the captions themselves need a human to verify they're accurate and synchronised.
Attached PDFs must themselves conform to PDF/UA. Attached non-PDF files must have accessible descriptions explaining their content.
JavaScript, launch, and navigation actions must not rely on timing or sensory cues that fail for assistive tech users. Flashing content (>3 Hz) is forbidden entirely.
Dynamic XFA forms are not allowed in PDF/UA-1. Static XFA is tolerated only if accompanied by an accessible AcroForm equivalent. Tool flags any dynamic XFA root immediately.
Documents with more than a handful of pages must include bookmarks (outline entries) that reflect the heading structure. Page labels must be human-readable (e.g. “iii”, “3”, “A-3”).
The displayed page number (in headers/footers) and the PDF page label must match. Mismatches confuse screen-reader navigation, cross-references, and citation workflows.
The PDF Checker combines 55 native detections written for human-readable reporting with 106 checks from VeraPDF — the PDF Association's reference PDF/UA-1 validator. Together that's 161 checks against the ISO standard.
18 native checks
Tagged PDF root, role map, reading order, language declaration, title, XMP metadata, pdfuaid:part identifier, structure tree health.
2 native checks
Heading hierarchy (no skipped levels) and H1 presence on first page.
6 native checks
Alt text presence and length, artifact detection, filename-as-alt rejection, decorative vs. meaningful classification.
6 native checks
Header cells, scope attributes, complex-table Headers/ID associations, summary, regularity.
5 native checks
Link accessible text and purpose; form tooltip (TU), label and required indication.
3 native checks
Contrast sampling at 4.5:1 / 3:1, font embedding, Unicode encoding.
7 native checks
Title, author, XMP block, pdfuaid:part = 1, creator, modification date, language tag.
8 native checks
OCR detection, reflow, flashing content, selectable text, bookmarks, page labels, tab order, viewer preferences.
106 rules (ISO 14289-1)
Full reference validator output, merged with our native findings. Each failure includes the ISO rule ID; our AI explainer translates the raw rule text into plain language.
Across thousands of PDFs scanned on WCAGHub, these are the conditions that come back fail on almost every untouched export.
The pdfuaid:part = 1 declaration is missing. Without it, no validator (or screen reader) can recognise the document as claiming PDF/UA conformance. One-line fix in Acrobat Pro preflight — but it's almost always absent on export from Word.
Logos, dividers and background shapes left as untagged content. Screen readers trip on them every time. Fix: mark them as artifact in the tag tree.
Alt text of image1.jpg or IMG_0042.PNG satisfies “has an alt entry” but fails meaningful-content review. Our checker recognises filename patterns and flags them.
Every cell tagged <TD>, no <TH>, no Scope. Sighted readers infer headers from bold or shading; assistive tech cannot. Fix: promote the first row and/or column to <TH> with Scope=Column or Scope=Row.
PDF has dc:title but ViewerPreferences /DisplayDocTitle is false — so the window still shows the filename. A single dictionary flip.
Catalog /Lang is absent, so screen readers fall back to the OS default voice — often the wrong language. Trivial to fix, very common.
The field is present and interactive, but TU is empty. The visible label sits next to the field but isn't associated with it programmatically, so screen readers announce “edit” with no context.
What buyers, compliance leads, and document authors ask us about PDF/UA most often.
No. WCAG is a cross-format web content standard; PDF/UA is a PDF-specific technical standard. A compliant PDF typically needs to satisfy both — PDF/UA for tagging and structure, WCAG for things like contrast, readability, and cognitive load. Our checker reports against both.
PDF/UA-1 is still the practical target for compliance in 2026. PDF/UA-2 was published in 2024 but authoring-tool and validator coverage is still catching up. Most procurement language still reads “PDF/UA-1 (ISO 14289-1)”.
Partially. Modern Microsoft Word export does produce tagged PDFs with basic structure, but almost always misses the pdfuaid:part identifier, viewer preferences, and complex-table headers. Expect a manual remediation pass in Acrobat Pro or a dedicated tool.
VeraPDF is the reference validator for PDF/UA-1 machine-testable rules. It's excellent, but it does not test human judgement items (meaningful alt text, correct heading level, sensible reading order). That's why our checker pairs VeraPDF's 106 rules with 55 native checks plus human-review guidance.
Our report gives fix guidance for Adobe Acrobat Pro, Microsoft Word, Adobe InDesign, and LibreOffice — the four environments most documents originate or get remediated in. Every detection includes the exact steps in each tool's UI.
Not necessarily. Signed PDFs are fine if the signature field has an accessible name and the visible appearance is tagged. Encrypted PDFs must allow content extraction for accessibility (/P bit 10). Our checker flags both conditions.
Pass VeraPDF validation against PDF/UA-1, complete the manual-review Matterhorn checkpoints, set pdfuaid:part = 1 in XMP, and document the evaluation in an accessibility statement. The conformance claim is a combination of machine test + documented human review — one without the other isn't defensible.
EN 301 549 (EU), Section 508 refresh (US federal), AODA (Ontario), PSBAR (UK), DTA guidance (AU), and most national archives all reference PDF/UA-1 as the PDF accessibility test. See the Compliance hub for per-country detail.