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From: Paul Rayius
Date: Jun 18, 2025 7:52AM

That is the rule, as explicitly stated in the PDF/UA-1 standard (ISO 14289). You are not “allowed” to have both numbered and non-numbered headings in an accessible PDF. For PDF/UA-1 compliance, you can use <H> or <Hn> but not both.

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From: Claire Forbes < <EMAIL REMOVED> >
Sent: Wednesday, June 18, 2025 9:43 AM
To: Paul Rayius < <EMAIL REMOVED> >; WebAIM Discussion List < <EMAIL REMOVED> >
Subject: RE: <H> tags within PDF

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Thank you for your reply.
I guess what I’m trying to understand it why is having one <H> tag considered non-compliant when the rest of the heading tags are <H1> or <H2>, <H3>

From: Paul Rayius < <EMAIL REMOVED> <mailto: <EMAIL REMOVED> >>
Sent: Tuesday, June 17, 2025 4:58 PM
To: WebAIM Discussion List < <EMAIL REMOVED> <mailto: <EMAIL REMOVED> >>
Cc: Claire Forbes < <EMAIL REMOVED> <mailto: <EMAIL REMOVED> >>
Subject: RE: <H> tags within PDF

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Hi Claire,
This is a good question; thanks for asking!
CommonLook PDF throws a failure when a PDF has both and (numbered heading) tags because that is a violation of PDF/UA-1. That said, to address your "other" question, "where does this fail in WCAG": It's important to note that while the WCAG standard does apply very well to PDF, because HTML (web) and PDF are different technologies there is not always a 1:1 mapping between requirements. That said, when it comes to PDF, where there is not a direct alignment between the two specifications, the requirements for PDF have to "win."
I hope that helps explain CommonLook's approach.
Best,
Paul


Paul Rayius, ADS
VP, Customer Support and Training
P: +1 800 563 0668 x5209
E: <EMAIL REMOVED> <mailto: <EMAIL REMOVED> >
Visit us online:
allyant.com
Allyant was formed by combining the best web and document accessibility brands (T‑Base, CommonLook, and Accessible360).
Read our story.
E-mail Notification: The information contained in this email and any attachments is confidential and may be subject to copyright or other intellectual property protection. If you are not the intended recipient, you are not authorized to use or disclose this information, and we request that you notify us by reply mail or telephone and delete the original message from your mail system.