Matterhorn 19-002 · PDF/UA-1 UA1:7.9-1

Footnote markers that are not tagged as Reference

The in-text citation marker is not tagged as a Reference pointing at the note.

What a screen reader actually does

The superscript number is announced as a stray digit in the middle of the sentence.

The other half of a footnote

A footnote is two pieces of content on the page: the note at the bottom, and the marker in the sentence that sends the reader there. Condition 19-001 is the note; this condition is the marker.

PDF’s structure type for the marker is Reference — in ISO 32000-1, a citation to content found elsewhere in the document. A footnoted sentence tagged in full looks like this:

/P
 ├── (MCID 12)  "…which the committee reviewed in March."
 └── /Reference
      └── /Link                       ← if the marker is clickable
           ├── (MCID 13)  "1"
           └── /OBJR → link annotation 19 0 R
/Note  /ID (fn1)  "1 Ministry of Finance, Annual Budget Report 2025, p. 14."

The failure is the marker with no Reference around it: the digit is part of the paragraph’s own content, or sits in a plain Span.

What the user hears

The digit, read as part of the sentence:

…which the committee reviewed in March 1.

In most text that is a nuisance — a number dropped on the end of a word. In some it changes the meaning: “reviewed in March 1” is a date, and “up to 20 2” is a figure nobody wrote. The listener has to work out from context, every time, that a number is a footnote marker. A Reference tag is what lets a reader identify it as one; how much each reader does with that varies.

Where it comes from

Markers painted inside the sentence’s own content. If the superscript digit is drawn in the same marked-content sequence as the words around it, there is no separate piece of content for a tag to hold: a structure element refers to whole sequences, never part of one. The content has to be split before the marker can be tagged on its own, and the source document is usually the easier place to get that.

Tagging by paragraph. Taggers that work a paragraph at a time tag the paragraph and stop. The marker has its own font size and baseline, but nothing in the tagger’s job requires it to notice.

Notes fixed, markers left. Retagging footnotes as Note — in Acrobat or anywhere else — and not going back for the markers. It is also the most direct way to arrive at exactly what Taggart’s check looks for: notes present, references absent.

How to check it free

Acrobat Pro’s Tags panel. Open it from the hamburger menu (Windows) or the View menu (macOS): Show/Hide → Side Panels → Tags (Accessibility tags in the current interface). Select a marker on the page and choose Find Tag From Selection from the Options menu. If the element that comes up is the whole paragraph, the marker has no tag of its own. If it is a <Span> or a <Link> with no <Reference> around it, the marker is tagged but not as a reference.

Not the checkers. Acrobat’s Accessibility Checker has no rule about references, per Adobe’s list of its checks, and veraPDF’s PDF/UA-1 rules under clause 7.9 test note IDs only.

How to fix it free, in Acrobat Pro

From Adobe’s Tags panel guide:

If the marker already has its own tag — a <Span>, say:

1. Select it in the Tags panel and choose Properties from the Options menu.
2. Choose Reference from the Type menu and click Close.

If it is a <Link>, leave the link as it is and put a reference around it: select the <Link>’s parent, choose New Tag, give it the type Reference, then drag the <Link> into it. A link annotation has to stay inside a <Link> element, condition 28-011.

If the marker has no tag of its own, select it on the page and choose Create Tag From Selection, with Reference as the type. Acrobat places the new tag after the selected item; drag it into its sentence’s element. Check the result with Highlight Content: the new tag should outline the digit and nothing else. If it outlines the whole sentence, the marker shares its marked content with the words around it, as described above.

Where Taggart differs

Taggart’s check is coarse. It does not try to pair markers with notes; it asks one question of the whole document — are there Note elements and no Reference elements at all? — and reports once:

The document has 3 <Note> element(s) but no <Reference> elements, so the in-text citation markers are not tagged as references pointing at their notes.

That means one Reference anywhere satisfies it, however many markers are still untagged; and a document whose footnotes are tagged P gets 19-001 instead, because there are no notes for this check to start from.

The repair is Tag notes and references, the same one that serves 19-001. It retags the elements a reviewer names as markers to Reference, and changes nothing it was not given. In the application the finding is a warning and goes to the review queue, where your decision is recorded with who made it and when; the queue does not yet pass the confirmed markers on to the repair, so for now the retag is done in Acrobat as above.

How Taggart handles it

The protocol marks this condition as needing human judgement, so no validator can decide it outright. Taggart applies a heuristic to find the likely cases and reports each one as warning for you to settle in the review queue. A heuristic finds what it was built to find and can miss the rest; what this one looks for is described above.

The fix is Tag notes and references. It changes what the document means, so Taggart proposes it and waits for your approval rather than applying it unattended.

Where this sits in the standards

Related conditions

• 19-001 Footnotes or endnotes are not tagged as NoteFootnote text at the bottom of the page is tagged as an ordinary paragraph.
• 19-003 ID entry of the Note tag is not presentEvery Note element must carry an /ID so references can point at it.
• 28-011 A link annotation is not nested within a Link tagA link annotation must be a child of a Link structure element containing the link's text, joined by an object reference (/OBJR).

Other conditions in checkpoint 19

Checkpoint 19 covers notes and references. These are its other failure conditions; the ones without a link are in the rule set but do not have a written page yet.

• 19-001 Footnotes or endnotes are not tagged as NoteFootnote text at the bottom of the page is tagged as an ordinary paragraph.
• 19-003 ID entry of the Note tag is not presentEvery Note element must carry an /ID so references can point at it.
• 19-004 ID entry of the Note tag is non-uniqueTwo or more Note elements share an /ID, usually because a template was copied per page.

Checked with Taggart on a generated file that fails this condition on 2026-10-02. The Acrobat steps follow Adobe’s documentation and were not walked through by hand. Last updated 2026-10-02.