What happened

On 9 September 2026, the PDF Association published two PDF/UA-1 Technical Notes. They clarify authoring and reading behavior for ActualText on a Figure structure element and for a Reference element that contains a link. The notes address interoperability questions, not a replacement for ISO 32000-1 or PDF/UA-1 requirements.

That distinction matters because a document can look correct on screen while its structure sends different information to a screen reader. The notes focus on how software exposes existing tags and annotations, rather than on redesigning a page's visible appearance.

How the two cases work

Technical Note 001 concerns non-text content whose purpose is to convey text. Under PDF/UA-1 it uses a Figure tag, yet announcing it simply as an image can obscure its meaning. The note recommends an appropriate surrounding structure, an ActualText value with the intended words, and inline placement. The accessibility interface should expose that value as text.

Technical Note 002 concerns references such as a table-of-contents entry or footnote reference. A Reference tag by itself is not necessarily clickable in PDF 1.7. If a link annotation is present, PDF/UA-1 also requires a Link tag around it. Both structures may reach assistive technology, but the same link should not be announced twice. PDF 2.0 permits a different structural arrangement, so reader behavior must account for the PDF version.

What it means for users

For someone navigating a long report by voice, repeated link announcements interrupt the flow; missing replacement text can change the meaning of an inline symbol. A visual spot check cannot reveal either problem. Ask the document author for an accessible source when a critical form, report or instruction sheet fails in your screen reader.

If you need editable material, convert a text-based PDF to Word and review the extracted headings and links. To share selected pages as pictures, export PDF pages to JPG, while recognizing that an image alone cannot preserve the PDF's tagged reading structure.

Practical checklist

  • Check reading order and listen to representative pages with the intended assistive technology.
  • Inspect text-like graphics for meaningful replacement text, rather than relying on appearance.
  • Follow reference links and listen for duplicate or ambiguous announcements.
  • Fix the source document and regenerate the PDF when structural errors originate in authoring.

Limitations and what has not changed

These notes do not perform OCR, tag an untagged PDF, or certify a converted file as accessible. A scan with no text layer remains a separate recognition problem; our scanned-PDF guide explains why ordinary conversion is insufficient. Even a formally tagged PDF needs real reader and assistive-technology testing for its intended audience.

Primary sources