Matterhorn 27-001 · PDF/UA-1 UA1:7.17-1
PDF bookmarks: no PDF/UA test, still a failed review
PDF/UA-1 sets no machine test here, but a long document without bookmarks fails WCAG 2.4.5 in practice and is the single most common procurement complaint.
The condition, as the protocol states it. “No tests specific to navigation are required; use appropriate semantics.”
Matterhorn Protocol 1.1, checkpoint 27, index 27-001, section UA1:7.17-1. The protocol defines no specific test for this condition.
What a screen reader actually does
The bookmarks panel is empty; the only navigation left is the heading list.
What the protocol says, and what it does not
Matterhorn checkpoint 27 has exactly one entry, 27-001, and its text is:
No tests specific to navigation are required; use appropriate semantics.
That is the whole checkpoint. PDF/UA-1 clause 7.17 does not require bookmarks, and a validator that reports a hard failure for their absence is reporting something the standard does not say.
Taggart still surfaces it, as a review item rather than a blocker, because the gap between what PDF/UA-1 requires and what a reviewer will accept is real, and this is the widest part of it.
What is in the file
The outline is a linked structure hanging off the catalog:
1 0 obj
<< /Type /Catalog /Outlines 40 0 R ... >>
40 0 obj
<< /Type /Outlines /First 41 0 R /Last 45 0 R /Count 5 >>
41 0 obj
<< /Title (Executive summary)
/Parent 40 0 R
/Next 42 0 R
/Dest [ 3 0 R /XYZ 0 792 0 ]
>>Nesting is expressed with /First, /Last, /Next, /Prev and /Parent — an outline item’s children hang off /First, so a three-level outline is three levels of that.
Why reviewers care
Three separate audiences, and bookmarks serve all of them:
Screen reader users get a second navigation route alongside the heading list, which is what WCAG 2.4.5 Multiple Ways (Level AA) asks for.
Sighted keyboard users get the only structural navigation a PDF viewer offers them. There is no heading list in Acrobat’s UI; there is a bookmarks panel.
Everyone on a long document. A 200-page technical standard without bookmarks is a scroll bar.
This is why it shows up on procurement checklists that otherwise track WCAG literally. It is visible, it is easy to check, and its absence reads as carelessness.
How to fix it free, in Acrobat Pro
If the document has real headings, Acrobat will build the outline from them:
- Open the Bookmarks panel.
- Options menu → New Bookmarks from Structure.
- Choose which structure elements to use — tick
H1,H2,H3. - Acrobat creates a nested outline matching the heading hierarchy.
That is the whole job, and it takes about ten seconds — if the headings are tagged. If the outline comes out wrong or empty, the headings are wrong or missing, which is 14-001 and 14-003. Fix those and re-run this.
Manually, for a document without headings: select text on the page, then Ctrl/Cmd + B to create a bookmark from the selection. Drag bookmarks in the panel to nest them.
Upstream: Word exports headings as bookmarks when Create bookmarks using: Headings is ticked in the export options. InDesign generates them from the Table of Contents or from paragraph styles marked for bookmarking. Both produce a correct nested outline with no manual work.
Where Taggart differs
Taggart reports it with the page count so the judgement is yours:
This 88-page document has no bookmarks. PDF/UA-1 sets no specific test for navigation, but a document of this length with no outline is routinely rejected under WCAG 2.4.5 Multiple Ways.
It is explicitly labelled as a human decision rather than a failure, and the report says the protocol sets no test — so a report handed to a client does not misrepresent the standard.
The fix derives the outline from the heading structure, up to a level you choose, and refuses to run if there are no headings to derive it from:
no heading elements to derive an outline from; tag the headings first
That refusal is deliberate. Bookmarks invented from page positions or type size look plausible and navigate to the wrong places, and an outline that is confidently wrong is harder to spot than one that is missing.
How Taggart handles it
This one is a judgement call. Taggart puts it in the guided review queue with the relevant page region highlighted, records the decision you make and who made it, and prints that decision in the remediation report.
The fix is Generate bookmarks from headings. It changes what the document means, so Taggart proposes it and waits for your approval rather than applying it unattended.
Whatever Taggart changes, the page still looks identical. Fixes edit the PDF object model, not the content streams, and every remediation is re-rendered and compared against the original at structural similarity ≥ 0.999 before you get the file back. A tool that quietly reflows your document is worse than no tool.
Frequently asked questions
Are bookmarks actually required?
Not by PDF/UA-1 — checkpoint 27 explicitly sets no specific test and says to use appropriate semantics. They are required in practice: WCAG 2.4.5 Multiple Ways is Level AA, most public-sector review checklists ask for them, and a reviewer who opens a 90-page document to an empty bookmarks panel will say so.
How long does a document have to be before it needs them?
There is no threshold in any standard. Taggart reports it from nine pages, which is roughly where a heading list stops being enough on its own. Use judgement: a 12-page report with four sections benefits; a four-page letter does not.
Is a heading list not enough?
It is one way, and WCAG 2.4.5 asks for more than one. Bookmarks also work for sighted keyboard users and for anyone who does not run a screen reader, which a heading list does not.
Should bookmarks match the headings exactly?
They should be derived from them. If your bookmarks and your headings disagree, one of them is wrong — and it is usually the bookmarks, because they get made by hand.
Where this sits in the standards
| Standard | Reference |
|---|---|
| Matterhorn Protocol 1.1 | Checkpoint 27 (Navigation), index 27-001 |
| PDF/UA-1 (ISO 14289-1) | Clause 7.17-1 |
| WCAG 2.1 | 2.4.5 Multiple Ways — Level AA |
| EN 301 549 / Section 508 / ADA Title II | All three point at WCAG 2.1 Level AA for non-web documents, so a Level A or AA criterion here is in scope for each of them. |
Related conditions
- 14-001 Headings are not tagged Text that is visually a heading — larger, bolder, isolated — is tagged as a paragraph. The document has no navigable outline.
- 14-003 Numbered heading levels in descending sequence are skipped The heading hierarchy jumps a level going down — H1 straight to H3. Going back up any number of levels is fine; going down must be one level at a time.
- 22-001 Article threads do not reflect logical reading order If article threads are present at all, the bead order must match the logical reading order.
- 09-001 Tags are not in logical reading order The order of elements in the structure tree does not match the order a human would read the page. This is the single most common substantive defect in tagged PDFs and the one Acrobat's own tooling handles worst.
Other conditions in checkpoint 27
Checkpoint 27 covers navigation. These are its other failure conditions; the ones without a link are in the rule set but do not have a written page yet.
Check your own file. Taggart’s validator is free and unlimited — every machine-checkable Matterhorn condition, no page cap, no watermark, no account needed.
Verified against a real document on . Last updated .