PDF Accessibility - Test Procedures & Requirements

The Visa Global Accessibility Requirements (VGAR) is a combination of requirements and complimentary test procedures that help teams create and verify accessible PDF documents.

For accessibility testing, the tester simply executes the test cases and determines whether each page in the PDF document being tested passes or fails the test case. When a failure is found, the tester then documents the failure and provides it to the development team for remediation.  The development team subsequently references both the identified failure and the corresponding requirement to assist in the remediation effort.


Test Order    |    Requirement Order

Requirement Order

The following table contains the VGAR PDF requirements.

Req Order Requirement Group Requirement ID Requirement Name Expectations
1 PDF-001 Structure and Tagging PDF-001-01 Tagging

All content is tagged with the most semantically correct tag and artifacts are not included in the structure tree

If your PDF is already tagged (e.g., you created a PDF using instructions on the previous page) you must skip step 3: "Recognize Text using OCR." Otherwise, your PDF will be re-tagged, and the new tag structure is seldom as good as the original. To skip this step, preferably before you start the wizard, right-click the Recognize Text using OCR option and select Skip This Step

2 PDF-001 Structure and Tagging

PDF-001-02 Page Title Page is titled with a descriptive title and the initial view setting is set to "Document Title"
3 PDF-001 Structure and Tagging PDF-001-03 Language PDF documents MUST have accurate language tags.
4 PDF-001 Structure and Tagging PDF-001-04 Headers and Footers Running headers and footers in PDF documents MUST be consistent.
5 PDF-001 Structure and Tagging PDF-001-05 Page Numbers Page numbering in PDF documents MUST be consistent and correct with the PDF viewer page number.
6 PDF-001 Structure and Tagging PDF-001-06 TOC Has Links If a PDF contains a table of contents, it MUST contain bookmarks that link to the proper locations within the document
7 PDF-001 Structure and Tagging PDF-001-07 Tab and Reading Order PDF content MUST read and tab in the correct order with a screen reader and a keyboard
8 PDF-001 Structure and Tagging PDF-001-08 AT Compatible Encryption

An encrypted conforming file shall contain a P key in its encryption dictionary (ISO 32000-1:2008,, Table 21). The 10th bit position of the P key shall be true. 

NOTE 1 Having this bit set enables support for assistive technology devices.

NOTE 2 It is advised not to encrypt documents in such a way as to prohibit assistive technology from accessing

9 PDF-002 Text Content PDF-002-01 Semantic Tagging of Text Text content shall be tagged in logical reading order and the most semantically appropriate tag shall be used for each logical element in the document content.
10 PDF-002 Text Content PDF-002-02 Mathematical Expressions Mathematical expressions shall be tagged with a Formula tag and have an Alt attribute
11 PDF-002 Text Content PDF-002-03 Links and Link Text

All links must be tagged as links and link text must make sense in context. 

Where a PDF is likely to be printed, the full link URL SHOULD be visually available either directly next to the link text OR referenced in a footnote.

12 PDF-002 Text Content PDF-002-04 Footnotes and Endnotes

Tag all footnotes, endnotes, and note labels correctly

Footnotes and endnotes shall be tagged with a Note tag. Each Note tag shall nave a unique entry in the ID key.

13 PDF-003 Graphics and Images PDF-003-01 Text Alternatives

All non-text content MUST be tagged with a Figure tag and have accurate, descriptive alternative text if it is not decorative. The following MUST be true for the alternative text:

1) Meaningful text in the image is included in the description.

2) The alternative text MUST be no longer than 150 characters.

3) Complex images (e.g. graphs) utilize real text descriptions instead of alternative text properties.

14 PDF-003 Graphics and Images PDF-003-02 Artifacts All decorative non-text content shall be tagged as an Artifact.
15 PDF-003 Graphics and Images PDF-003-03 Figure Captions Where a visible text caption accompanies an image or graphic, it is tagged as a Caption.
16 PDF-004 Lists PDF-004-01 List Tagging List items shall be specified by appropriate LI tags with Lbl and LBody as needed.
17 PDF-004 Lists PDF-004-02 Numbered Lists For ordered lists, the explicit ListNumbering attribute shall be used for L tags.
18 PDF-005 Tables PDF-005-01 Tables Tagged

Tables have been tagged correctly and meet the following requirements:

  1. All tabular data is tagged as a table.
  2. All table rows are tagged using <TR>
  3. Column/Row headers have been tagged with TH tags and the scope has been set appropriately.
  4. Table data cells have all been tagged with the TD tag.
19 PDF-005 Tables PDF-005-02 Tables for Tabular Data Tables are only used for tabular data with a logical column/row relationship and not used for layout or positioning.
20 PDF-006 Headings PDF-006-01 Headings Tagged All headings are tagged as Headings using the H1-H6 tags.
21 PDF-006 Headings PDF-006-02 Heading Order Headings MUST be implemented sequentially in order without skipping levels. (i.e., Heading 1, then Heading 2, then Heading 3 and so on). This applies to ascending and descending heading levels. Headings of the same level may be repeated (e.g., H2, H2, H2, etc.).
22 PDF-007 Interactive Content PDF-007-01 Form Elements Have Tooltips If a PDF has form controls, each control MUST have a tooltip.
23 PDF-007 Interactive Content PDF-007-02 Radio Buttons Are Grouped Radio button elements MUST be programmatically associated with each other by sharing the same 'Name' and 'Title' attributes. The radio button choice must be set to match the text shown on screen for each radio option.
24 PDF-007 Interactive Content PDF-007-03 Form Controls Name Role Value PDF form controls MUST have the correct tag type set.
25 PDF-007 Interactive Content PDF-007-04 Input Validation PDF forms MUST indicate when user input falls outside the required format and error messaging MUST be clear and accurate for screen reader users
26 PDF-007 Interactive Content PDF-007-05 Required Input PDF form controls that are required MUST be shown as required in text, in the field properties, and in the tooltip.
27 PDF-007 Interactive Content PDF-007-06 Keyboard Compatibility All interactive PDF content can be used with a keyboard.
28 PDF-008 Media Content PDF-008-01 Captions for Video All video (both live AND prerecorded) content MUST include accurate captions.
29 PDF-008 Media Content PDF-008-02 Audio Description for Video If video content provides any information visually that is not described by an accompanying audio track, it MUST also include an Audio Description track that fully explains the visual information.
30 PDF-008 Media Content PDF-008-03 Extended Audio Description If an Audio Description track cannot fully explain the visual information during gaps in dialog, Extended Audio Description MUST be used (i.e., the video MUST pause at appropriate times to allow for the descriptions to finish).
31 PDF-008 Media Content PDF-008-04 Ways to Provide CC and AD

Captions and Audio Description MUST be made available to users via one or more of the following methods (both need not use the same method):

-always on, included in the original video

-included as a separate file or track that can be toggled on and off by the user via an accessible mechanism (note: use of Extended Audio Description may complicate this)

-included as a video file and made available via separate link(s) adjacent to the original video link.

32 PDF-008 Media Content PDF-008-05 Transcripts for audio-only/video-only For audio-only and video-only media, a transcript MUST be provided which provides the same information as presented in the original media content.

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