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Messages you may see

  • Tagged annotations - Failed (Acrobat Pro, Accessibility Checker)
  • PDF/UA-1 (ISO 14289-1) rule 7.18.1-1: … annotation is an Artifact or is nested within … tag (standard type = …) instead of Annot
  • PDF/UA-1 (ISO 14289-1) rule 7.18.1-2: … annotation whose hidden flag is not set and whose rectangle is not outside the crop-box has neither Contents key nor an Alt entry in the enclosing structure element
  • PDF/UA-1 (ISO 14289-1) rule 7.18.2-1: An annotation of subtype TrapNet exists
  • PDF/UA-1 (ISO 14289-1) rule 7.18.8-1: A PrinterMark annotation is included in logical structure
  • PDF/UA-2 (ISO 14289-2) rule 8.9.2.3-1: A Markup annotation is nested within … tag (standard type = …) instead of Annot

What the rule requires

An annotation is an object that sits on top of the page rather than in its text: a sticky note, a highlight, a stamp, a movie, a link or a form field. ISO 14289-1 (PDF/UA-1) deals with annotations in clause 7.18. The Matterhorn Protocol 1.1 of the PDF Association lists the related failure conditions under checkpoint 28 (Annotations). Our checker tests the rules below.

Machine-checkable annotation rules of PDF/UA-1
RuleRequirement
7.18.1-1Every annotation except Widget (form field), PrinterMark and Link annotations is nested in an Annot structure element.
7.18.1-2Every visible annotation except widgets has a text in its /Contents key or an Alt entry on the enclosing structure element.
7.18.2-1Trap network annotations (/Subtype /TrapNet) are not permitted.
7.18.6.2-1 and -2For media clips (movies, sound), the media clip data dictionary contains a content type (CT) and an alternative description (Alt).
7.18.8-1Printer's mark annotations (/Subtype /PrinterMark) are artifacts and are not part of the structure tree.

Annotations that are hidden (hidden flag set) or lie completely outside the crop box are exempt from 7.18.1-1 and 7.18.1-2. Links and form fields are annotations as well, but have rules of their own: see Links are not tagged and Tagged form fields failed. Every page that contains annotations also needs a defined tab order, see Tab order failed.

PDF/UA-2 (ISO 14289-2, clause 8.9) keeps the idea and adds detail: markup annotations used as real content are enclosed in Annot elements (8.9.2.3), invisible annotations must be artifacts (8.9.2.2), pop-up annotations must not be in the structure tree, ink and screen annotations need a /Contents entry, sound and movie annotations are not allowed, and where both /Contents and Alt exist they must be identical (8.9.4.2).

Why it matters

Screen readers find annotations through the tag tree. An annotation outside it is either skipped or read at a point that has nothing to do with the text it refers to. A note such as "Figure 3 still shows last year's values" loses its meaning if it is read at the end of the page or not at all.

Without a /Contents text, assistive technology can announce only the type of the annotation, for example "stamp" or "highlight", but not what it means. Sighted readers see the colour, the icon or the stamp text, so they receive information that others do not.

Adobe links its rule Tagged annotations to the WCAG success criteria 1.3.1 Info and Relationships and 4.1.2 Name, Role, Value.

Common causes

  • Review comments were added in Acrobat or another viewer after the PDF had been tagged. Adobe states that comments added to a tagged PDF stay untagged unless comment tagging was switched on first.
  • The PDF was exported from Word with Document showing markup, so comments and tracked changes became part of the file.
  • Approval stamps such as "Approved" or "Draft" were placed on the pages without any text.
  • Movies, sound or 3D content were embedded by layout software without content type or description.
  • Printer's marks or trap annotations from print production were left in a file meant for screen use.
  • A tool tagged the page content but ignored the annotations.

Example

A sticky note on page 1 that is not tagged and has no text. A PDF/UA check reports rules 7.18.1-1 and 7.18.1-2:

12 0 obj
<< /Type /Annot /Subtype /Text
   /Rect [480 700 500 720] >>
endobj
Failing: annotation without structure parent and without /Contents

The same note inside an Annot element. The structure element points to the annotation with an object reference (OBJR), the annotation points back with /StructParent, and /Contents holds the text:

30 0 obj
<< /Type /StructElem /S /Annot /P 20 0 R /Pg 5 0 R
   /K << /Type /OBJR /Obj 12 0 R /Pg 5 0 R >> >>
endobj

12 0 obj
<< /Type /Annot /Subtype /Text
   /Rect [480 700 500 720]
   /Contents (Figure 3 still shows the values for 2024.)
   /StructParent 7 >>
endobj
Passing the machine check: Annot element with OBJR and a description

The number 7 is the key in the parent tree of the structure tree root that leads back to element 30. Place the Annot element next to the paragraph the comment refers to, so it is read in context.

How to fix it

Microsoft Word

Comments and tracked changes reach the PDF only when you export the markup. For a finished document, leave them out.

  1. Delete comments that do not belong in the published version (Review > Delete > Delete All Comments in Document), or accept or reject tracked changes.
  2. Choose File > Save As or File > Save a Copy and select PDF as the file type. If you save next to the original, choose More options… first.
  3. Select Options. Under Publish what, choose Document, not Document showing markup.
  4. Keep Document structure tags for accessibility selected, select OK and save.
  5. Check the new PDF again.

If a review copy must show comments, export with Document showing markup and check the result. According to Microsoft, Word tags exported comments as Annot elements from version 16.0.16831.20002; older versions do not. In Word for Mac, choose File > Save As, PDF and Best for electronic distribution and accessibility (uses Microsoft online service).

Adobe InDesign

In PDFs from InDesign, most annotations are hyperlinks, buttons and form fields, which have their own rules. Findings on this page usually concern movies, sound or other media.

  1. Choose File > Export and Adobe PDF (Interactive).
  2. On the General tab, switch on Create Tagged PDF.
  3. If movies or sound do not need to play inside the PDF, set Forms and Media to Appearance Only. Adobe notes that this exports the normal state of buttons and video posters as static graphics, so use it only in documents without forms.
  4. Offer the media file separately, with captions or a transcript, and link to it from the text.
  5. Open the exported PDF in Acrobat Pro and tag any remaining annotations as described below.

Add review comments in Acrobat only after the last accessibility check, or remove them before you publish.

Adobe Acrobat Pro

Tag existing comments

  1. Open the Tags panel: menu (Windows) or View (macOS) > Show/Hide > Side panels > Accessibility tags.
  2. In the Tags panel, choose Find from the Options menu.
  3. In the Find Element dialog, select Unmarked Comments and select Find.
  4. When a comment is found, select Tag Element, choose Annotation as the type in the New Tag dialog, and select OK.
  5. Select Find Next until all comments are tagged, then Close.
  6. Check where the new tags ended up and drag each one next to the text it refers to.

Tag new comments automatically

Before adding comments to a tagged PDF, choose Tag Annotations from the Options menu of the Tags panel. Adobe notes that highlight and underline comments are associated with the text they mark and tagged with it.

Add a text and check again

  • Open each comment or stamp and type a short text that states its meaning. For a highlight, add a comment that says why the passage is highlighted.
  • Remove comments that only served internal review. For finished documents, this is often the simplest fix.
  • Run All tools > Prepare for accessibility > Check for accessibility and look at Tagged annotations under Page Content.

Check your PDF

Upload the fixed file to see which machine-checkable criteria it meets now. The report lists the remaining problems with their pages.

Open the checker

Questions

Can I mark annotations as artifacts instead of tagging them?
Adobe's rule accepts annotations that are either in the tag tree or marked as artifacts. PDF/UA-1 exempts hidden annotations and annotations outside the crop box from the tagging rule; a visible comment that carries information belongs in the tag tree. Printer's marks must be artifacts.
Acrobat passes, the PDF/UA check fails. Which one is right?
They test different things. Acrobat's rule asks whether annotations are tagged. The PDF/UA rules also check the tag type (Annot) and the /Contents text. Both are machine checks; neither replaces a review by a person.
Do I have to keep comments in a published PDF?
No. Comments from internal review usually do not belong in the published version. Removing them removes the finding.

Sources

  1. ISO 14289-1:2014 – Document management applications – Electronic document file format enhancement for accessibility – Part 1: Use of ISO 32000-1 (PDF/UA-1) – International Organization for Standardization (ISO). Checked on 7 November 2026.
  2. ISO 14289-2:2024 – Document management applications – Electronic document file format enhancement for accessibility – Part 2: Use of ISO 32000-2 (PDF/UA-2) – International Organization for Standardization (ISO), 13 March 2024. Checked on 7 November 2026.
  3. The Matterhorn Protocol 1.1 – PDF Association. Checked on 7 November 2026.
  4. Create and verify PDF accessibility (Acrobat Pro) – Adobe (helpx.adobe.com). Checked on 7 November 2026.
  5. Edit document structure with the Content and Tags panels (Acrobat Pro) – Adobe (helpx.adobe.com). Checked on 7 November 2026.
  6. Save or convert to PDF or XPS in Office Desktop apps – Microsoft Support. Checked on 8 November 2026.
  7. Create accessible PDFs – Microsoft Support. Checked on 8 November 2026.
  8. Word PDF Accessibility – Microsoft Learn, 12 May 2026. Checked on 8 November 2026.
  9. Interactive PDF options (InDesign) – Adobe (helpx.adobe.com), 2 June 2026. Checked on 7 November 2026.