Matterhorn 28-003 · PDF/UA-1 UA1:7.18.1-3
Annotation used as decoration: boxes, lines and highlights
A Square or Line annotation used to draw a box round a callout is decoration and should be artifacted, or tagged for what it actually means.
The condition, as the protocol states it. “An annotation is used for visual formatting but is not tagged according to its semantic function.”
Matterhorn Protocol 1.1, checkpoint 28, index 28-003, section UA1:7.18.1-3. The protocol marks this as requiring human judgement.
What a screen reader actually does
The reader announces "square annotation" mid-sentence.
The condition
Annotations exist for interaction and review: comments, markups, links, form fields. They also draw things, and some files use them for nothing else. Acrobat’s drawing tools sit with its review tools: Line, Arrow, Rectangle, Circle, Cloud, Polygon, Connected lines and Draw all make drawing markups (Add shapes, lines, and freeform drawings). Draw a red frame round a warning with the Rectangle tool and the file gains this:
<< /Type /Annot
/Subtype /Square
/Rect [ 66 730 330 756 ]
/C [ 0.8 0.1 0.1 ] % red
/F 4 % print
>>It looks like page design. In the file it is an annotation, the same kind of object a reviewer leaves when they draw a box and type check this figure. The same goes for a Line annotation used as a rule under a heading, a highlight used as a background, a text box used to put a label on a drawing, a stamp used as a logo.
Condition 28-003 is an annotation used for visual formatting that is not tagged according to its semantic function. It is a judgement a person makes, because nothing in the dictionary above says whether it was meant as decoration or as a remark.
What a screen-reader user gets
Left untagged, it fails 28-002, and depending on the reader it is either skipped or surfaces as an annotation with no place in the text. Tagged as an <Annot> with no description, it is presented as an annotation in the middle of the reading order with nothing to say for itself, and fails 28-004. Either way the reader is told about a comment where the author meant a frame, and the frame’s actual message (this paragraph matters) does not reach them.
Making the decision
For each annotation, ask what a reader would lose if it were deleted.
It is a real annotation. A reviewer’s note, an Approved stamp, a correction. It stays an annotation: an <Annot> element holding it, and a description in /Contents that says what it says. That is 28-002 and 28-004, and this condition is satisfied.
It means something, but not as a comment. The red frame says warning. Then the meaning belongs in the content, where every reader gets it: a heading or a word that says Warning, tagged as what it is. The frame itself is then decoration.
It is decoration. It should not be read at all, and the tools disagree about how to say so. Adobe’s guidance for its checker’s Tagged annotations rule is that annotations must be “either included in the Tags tree or marked as artifacts”, and it points to the Content panel’s Create Artifact for the second (Create and verify PDF accessibility). veraPDF reads PDF/UA-1 more strictly: its rule that annotations other than links, form fields and printer marks sit inside an <Annot> fails an annotation that is an artifact just as it fails one that is untagged. The way out of the disagreement is for the decoration not to be an annotation at all. Draw it in the source document as a shape, where it exports as page content and can be marked decorative there.
How to find them free
Acrobat Pro’s Content panel lists, for each page, its annotations (comments and links) alongside the page’s content objects (Edit document structure with the Content and Tags panels). Open it from Menu → View → Show/Hide → Side panels → Content and look for annotations that, on the page, are clearly design.
The Tags panel’s Find searches for unmarked comments, links and annotations. Adobe files drawing markups under comments, so an untagged one should turn up as an unmarked comment.
The Accessibility Checker’s Tagged annotations rule reports annotations that are neither tagged nor artifacts. It cannot tell you which of them are decoration; that is still your call.
How to fix it free, in Acrobat Pro
For a real annotation, tag it as Adobe describes for comments: in the Tags panel choose Find from the options menu, choose Unmarked Comments, click Find, then Tag Element, choose Annotation as the type and click OK; repeat with Find Next (Edit document structure with the Content and Tags panels). For its description, select the markup and use Add a comment to give it a note, which is the annotation’s /Contents.
For decoration, delete it: Adobe’s instruction for a drawing markup is to select it and press Delete. If the design needs the frame, redraw it in the source as a shape. Marking the annotation as an artifact from the Content panel (right-click → Create Artifact) is Adobe’s documented alternative and satisfies Acrobat’s checker; expect veraPDF to report it.
For a frame that carries meaning, add the meaning to the text first, then treat the frame as decoration.
What Taggart does
Taggart has no check for this condition. The protocol gives it no machine test, and Taggart does not guess, so there is no 28-003 finding in a Taggart report and no item for it in the review queue. A clean report says nothing about it either way.
What Taggart does instead is hold the conformance claim. 28-003 is one of the conditions no check of Taggart’s decides, and until a person confirms them the report stops at machine checks passed and the PDF/UA identifier is not written. In the application that is the checkbox on the conformance card, “I have checked these conditions by hand, or with another validator”, and the card lists what you are confirming. Tick it only once you have been through the drawn annotations as described above.
What Taggart reports on the same file is the annotation’s structure. The red frame above, untagged, comes back as 28-002 (not inside an <Annot>) and 28-004 (no description). The repair for 28-002 is annotation-structure, marked safe, so Fix All Safe applies it: it wraps the frame in an <Annot> element placed where its rectangle sits. That clears 28-002, leaves 28-004 waiting for a description, and leaves this condition’s question exactly where it was. A decorative frame tagged as an annotation is still a decorative frame.
So decide first. If the drawn annotations in a file are decoration, deal with them in Acrobat or the source before running Fix All Safe, because Taggart has no repair that turns an annotation into an artifact or into page content.
How Taggart handles it
No software can decide this one, and Taggart has no check for it, so it never appears among the findings or in the review queue. It is on the list of conditions Taggart asks you to confirm by hand before it writes the PDF/UA claim into the file — the claim waits until you have.
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
Why can't a checker find these?
Because a reviewer's comment and a designer's frame are the same object. Both are a /Square annotation with a rectangle and a colour. What differs is intent, and intent is not in the file. That is why the protocol leaves this condition to a person.
Is putting the annotation in an <Annot> tag enough?
It satisfies 28-002, which asks for exactly that. It does not settle this condition: a decorative frame inside an <Annot> is still a frame being presented as an annotation. The question here comes first, and the tagging follows from the answer.
What about review comments left in the published file?
Those are real annotations and tagging them is correct, but most published documents should not carry them at all. Deleting a leftover comment is usually a better repair than describing it.
Does Taggart decide this for me?
No. It has no check for this condition, so there is never a 28-003 finding and nothing about it in the review queue. What it does is withhold the PDF/UA claim: 28-003 is on the list of conditions you confirm by hand before Taggart writes the identifier into the file. On the drawn box itself it reports 28-002 and 28-004, and the decision on this page comes before you act on those.
Where this sits in the standards
| Standard | Reference |
|---|---|
| Matterhorn Protocol 1.1 | Checkpoint 28 (Annotations), index 28-003 |
| PDF/UA-1 (ISO 14289-1) | Clause 7.18.1-3 |
| WCAG 2.1 | 1.3.1 Info and Relationships — Level A |
| 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
- 28-002 An annotation is not a direct child of an Annot structure elementNon-widget, non-link annotations must sit inside an Annot structure element so they have a place in the reading order.
- 28-004 An annotation has neither a Contents entry nor an alternative descriptionEvery non-widget annotation needs an accessible description, either in its own /Contents or in the /Alt of the structure element that encloses it.
- 01-001 Artifact tagged as real contentDecoration — a rule line, a page-border image, a watermark, a background flourish — has been given a real content tag, so assistive technology announces it as if it were part of the document.
- 13-004 Figure tag alternative or replacement text missingA Figure element has neither /Alt nor /ActualText. Every Figure must have one or the other; if the image is decorative it should be an artifact instead of a Figure.
Other conditions in checkpoint 28
Checkpoint 28 covers annotations. These are its other failure conditions; the ones without a link are in the rule set but do not have a written page yet.
- 28-001 An annotation is not in correct reading orderThe annotation's position in the structure tree does not match where it appears on the page.
- 28-002 An annotation is not a direct child of an Annot structure elementNon-widget, non-link annotations must sit inside an Annot structure element so they have a place in the reading order.
- 28-004 An annotation has neither a Contents entry nor an alternative descriptionEvery non-widget annotation needs an accessible description, either in its own /Contents or in the /Alt of the structure element that encloses it.
- 28-005 A form field has neither a TU entry nor an alternative descriptionThe /TU tooltip is the accessible name of a PDF form field. Without it the field has no name at all — the visible label printed next to it is not connected to the control.
- 28-006 An annotation with subtype undefined in ISO 32000 does not meet 7.18.1A custom annotation subtype still has to be placed in the structure tree and described.
- 28-007 An annotation of subtype TrapNet existsTrapNet annotations are prepress artefacts and are forbidden in PDF/UA-1.
- 28-008 A page containing an annotation does not contain a Tabs entryAny page carrying annotations must declare a tab order. PDF/UA-1 requires /Tabs /S — tab order follows the structure tree.
- 28-009 A page containing an annotation has a Tabs entry with a value other than S/Tabs is present but set to /R (row order) or /C (column order) rather than /S (structure order).
- 28-010 A widget annotation is not nested within a Form tagEvery form control must sit inside a Form structure element.
- 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).
- 28-012 A link annotation does not include an alternate description in its Contents entryLink annotations need /Contents describing where the link goes.
- 28-013 An IsMap entry is true but the functionality is not provided in some other wayA server-side image map requires pointing at a pixel, which is not possible without a mouse.
- 28-014 CT entry is missing from the media clip data dictionaryThe media clip's content type (/CT) is required so a processor knows what it is being asked to play.
- 28-015 Alt entry is missing from the media clip data dictionaryMedia clips require an /Alt array giving a text description.
- 28-016 File attachment annotations do not conform to 7.11The file specification referenced by a FileAttachment annotation must carry both /F and /UF.
- 28-017 A PrinterMark annotation is included in the logical structureCrop marks and registration targets are production artefacts and must not appear in the structure tree.
- 28-018 The appearance stream of a PrinterMark annotation is not marked as ArtifactThe content inside a PrinterMark's appearance stream must itself be artifacted.
Check your own file. Taggart’s validator is free and unlimited — 75 of the 87 Matterhorn conditions software can decide, with the other 12 listed for you to confirm; no watermark, no expiry, and no account needed up to 60 pages.
This condition needs a person’s judgement, so there was nothing for a tool to check. Written from ISO 14289-1 and the Matterhorn Protocol on . The Acrobat steps follow Adobe’s documentation and were not walked through by hand. Last updated .