WCAG 2.2 Manual Checks for PDF Documents

These checks cannot be verified by automated tools. They must be assessed by the document creator or a human reviewer.

Why are these checks manual? 

Automated validators can verify the structure of a PDF (tags, metadata, fonts) but cannot judge whether content is meaningful — for example, whether alt text actually describes an image, or whether reading order makes sense. These checks require human judgment.

Manual – Requires human review of the document

User Agent – Depends on the PDF viewer application

  • Readability

    Content must be presented in a meaningful reading order
    WCAG 1.3.2
    Manual
    Verify that when all visual styling is removed, the content sequence remains logical. Screen readers follow the tag order in the PDF structure tree — ensure this matches the intended reading flow.
    Error: Content reading sequence is not meaningful or logical.

  • Headings

    Headings and labels must describe topic or purpose
    WCAG 2.4.6
    Manual
    Verify that every heading and label accurately describes the content that follows it. Headings should be descriptive enough that users can understand the page structure by reading headings alone.
    Error: Headings or labels do not describe their topic or purpose.

  • Images

    Use actual text instead of images of text
    WCAG 1.4.5
    Manual
    Verify that text content is rendered as real, selectable text rather than as rasterized images. Images of text cannot be resized without quality loss and are inaccessible to screen readers unless alt text duplicates the content.
    Error: Text is presented as an image instead of actual text characters.

  • Links and Annotations

    Receiving focus must not cause unexpected context change
    WCAG 3.2.1
    Manual
    Verify that when a form field or interactive element receives focus (e.g., tabbing to it), no unexpected action occurs such as submitting a form, opening a new window, or moving focus elsewhere.
    Error: Focusing on element causes unexpected context change.
    Changing input settings must not cause unexpected context change
    WCAG 3.2.2
    Manual
    Verify that changing the value of a form control (selecting a radio button, entering text) does not automatically trigger a context change like navigating to a new page
    Error: Changing input causes unexpected context change.
    Input errors must be identified and described to user
    WCAG 3.3.1
    Manual
    If a form field has validation requirements, verify that errors are clearly identified and described in text when the user makes a mistake.
    Error: Input errors are not identified or described.
    Visible label must be included in accessible name
    WCAG 2.5.3
    Manual
    For form fields and interactive controls, verify that the visible text label is included within the accessible name so speech input users can activate controls by speaking what they see.
    Error: Visible label text is not part of the accessible name.
    Link text must describe the purpose of the link
    WCAG 2.4.4
    Manual
    Verify that the purpose of each link can be determined from the link text alone, or from the link text together with its surrounding context. Avoid generic text like "click here" or "read more".
    Error: Link purpose cannot be determined from text or context.
    Labels or instructions must be provided for user input
    WCAG 3.3.2
    Manual
    Verify that all form fields have visible labels or instructions so users know what input is expected.
    Error: Form fields lack labels or instructions.
    Suggestions for correcting input errors should be provided
    WCAG 3.3.3
    Manual
    If an input error is detected and suggestions for correction are known, verify that suggestions are provided to the user (unless it would compromise security).
    Error: No suggestions provided for correcting input errors.
    Important submissions must be reversible, checked, or confirmed
    WCAG 3.3.4
    Manual
    For forms that cause legal commitments or financial transactions, verify that submissions are reversible, data is checked for errors, or the user can review and confirm before final submission.
    Error: Important form submission is not reversible or confirmable.
    Input fields must have identifiable purpose
    WCAG 1.3.5
    Manual
    Verify that form fields collecting user information (name, email, address, etc.) can be programmatically determined so browsers can auto-fill them correctly.
    Error: Input field purpose cannot be programmatically identified.

  • Navigation

    Multiple ways to locate pages must be provided
    WCAG 2.4.5
    Manual
    Verify that more than one way is available to locate content — for example, a table of contents, bookmarks, and page headings. This helps users find content using the method that works best for them.
    Error: Only one mechanism is available for locating content.
    Navigation mechanisms must be consistent across pages
    WCAG 3.2.3
    Manual
    Verify that navigation elements (headers, footers, page numbers) that appear on multiple pages maintain the same relative order throughout the document.
    Error: Navigation mechanism order or structure varies across pages.
    Components with same functionality must be identified consistently
    WCAG 3.2.4
    Manual
    Verify that elements serving the same function are labeled consistently throughout the document. For example, a "Submit" button should not be called "Send" on another page.
    Error: Same functionality is identified differently across pages.
    All functionality must be available via keyboard
    WCAG 2.1.1
    User Agent
    Depends on the PDF viewer. Verify that all interactive elements (links, form fields, buttons) can be reached and activated using only the keyboard.
    Error: Functionality is not accessible by keyboard alone.
    Keyboard focus must not be trapped
    WCAG 2.1.2
    User Agent
    Depends on the PDF viewer. Verify that keyboard users can always move focus away from any element — focus should never become stuck in a form field or interactive region.
    Error: Keyboard focus is trapped and cannot be moved away.
    Single character shortcuts must be configurable
    WCAG 2.1.4
    User Agent
    Depends on the PDF viewer. If single-character keyboard shortcuts exist, verify they can be turned off or remapped to avoid accidental activation by speech input users.
    Error: Single character shortcuts cannot be turned off or remapped.
    Keyboard focus indicator must be visible
    WCAG 2.4.7
    User Agent
    Depends on the PDF viewer. Verify that when navigating with the keyboard, the currently focused element has a visible focus indicator (outline, highlight, etc.).
    Error: Keyboard focus indicator is not visible.
    Focused item must not be fully hidden by other content
    WCAG 2.4.11
    User Agent
    Depends on the PDF viewer. Verify that when an item receives keyboard focus, it is not completely obscured by floating elements, sticky headers, or overlapping content.
    Error: Keyboard-focused item is completely obscured by content.

  • Colour Contrast

    Color must not be the only way to convey information
    WCAG 1.4.1
    Manual
    Verify that color is not the sole method used to distinguish information — for example, required form fields should not be indicated only by red text. Use additional indicators like text labels, patterns, or icons.
    Error: Information is conveyed by color alone.
    Text must have sufficient contrast against background (4.5:1 ratio)
    WCAG 1.4.3
    Manual
    Verify that normal text has a contrast ratio of at least 4.5:1 against its background, and large text (18pt or 14pt bold) has at least 3:1. Use a contrast checker tool to measure.
    Error: Text contrast ratio is below the required minimum.
    UI components and graphics must have 3:1 contrast ratio
    WCAG 1.4.11
    Manual
    Verify that user interface components (form field borders, buttons) and meaningful graphics have a contrast ratio of at least 3:1 against adjacent colors.
    Error: UI component or graphic contrast is below 3:1 ratio.

  • Adaptability

    Content must not restrict display to a single orientation
    WCAG 1.3.4
    User Agent
    Depends on the PDF viewer. Content should be viewable in both portrait and landscape orientations unless a specific orientation is essential.
    Error: Content is restricted to portrait or landscape orientation only.
    Text must be resizable up to 200% without loss of content
    WCAG 1.4.4
    User Agent
    Depends on the PDF viewer. Verify that text can be zoomed to 200% without content being cut off or overlapping.
    Error: Text cannot be resized without losing content or functionality.
    Content must reflow to single column without horizontal scrolling
    WCAG 1.4.10
    User Agent
    Depends on the PDF viewer. When reflowed at 320 CSS pixels width, content should not require horizontal scrolling.
    Error: Content requires horizontal scrolling at 320 CSS pixels width.
    Content must be readable with adjusted text spacing
    WCAG 1.4.12
    User Agent
    Depends on the PDF viewer. Content should remain readable when line height, paragraph spacing, letter spacing, and word spacing are increased.
    Error: Content is cut off or overlaps with adjusted text spacing.
    Hover/focus content must be dismissible, hoverable, and persistent
    WCAG 1.4.13
    User Agent
    Depends on the PDF viewer. Additional content that appears on hover or focus must be dismissible, the pointer must be able to move over it, and it must remain visible until dismissed.
    Error: Hover or focus content cannot be dismissed or controlled.
    Time limits must be adjustable or extendable
    WCAG 2.2.1
    Manual
    If the document contains time-limited interactions (e.g., a form that expires), verify that users can turn off, adjust, or extend the time limit.
    Error: Time limits cannot be adjusted, extended, or disabled.
    Motion-triggered functionality must have alternative input
    WCAG 2.5.4
    Manual
    If functionality responds to device motion (shaking, tilting), an alternative UI control must be provided and motion response must be disableable.
    Error: Functionality can only be triggered by device motion.

  • Multimedia

    Audio-only content must have a text transcript
    WCAG 1.2.1
    Manual
    If the document contains embedded audio-only content, verify that an equivalent text transcript is provided nearby.
    Error: Prerecorded audio-only or video-only content lacks a text alternative.
    All prerecorded video with audio must have captions
    WCAG 1.2.2
    Manual
    If the document contains embedded video with audio, verify that synchronized captions are provided for all spoken content and relevant sound effects.
    Error: Prerecorded video content is missing captions.
    Prerecorded video must have audio description or full text transcript
    WCAG 1.2.3
    Manual
    Verify that prerecorded video has either an audio description track or a complete text alternative describing all visual content.
    Error: Prerecorded video lacks audio description or media alternative.
    All prerecorded video must have audio description
    WCAG 1.2.5
    Manual
    Verify that all prerecorded video content includes an audio description narrating important visual information not conveyed through dialogue.
    Error: Prerecorded video is missing audio description.
    Auto-playing audio must have controls to pause or stop
    WCAG 1.4.2
    Manual
    If any audio plays automatically for more than 3 seconds, verify there is a mechanism to pause, stop, or control the volume independently from system volume.
    Error: Auto-playing audio lacks controls to pause or stop.
    Moving, blinking, or auto-updating content must be controllable
    WCAG 2.2.2
    Manual
    If the document contains moving, blinking, scrolling, or auto-updating content, verify the user can pause, stop, or hide it.
    Error: Moving or auto-updating content cannot be paused or stopped.
    Content must not flash more than three times per second
    WCAG 2.3.1
    Manual
    Verify that no content flashes more than three times per second, as this can trigger seizures in users with photosensitive epilepsy.
    Error: Content flashes more than three times per second.

  • Touch and Pointer

    Multi-point gestures must have single-pointer alternative
    WCAG 2.5.1
    Manual
    If functionality requires multi-point or path-based gestures (pinch, swipe), a single-pointer alternative must be available.
    Error: Multi-point gesture has no single-pointer alternative.
    Pointer activation must be on up-event or reversible
    WCAG 2.5.2
    Manual
    Actions should complete on the up-event (releasing the pointer) or be reversible/abortable.
    Error: Pointer action triggers on down-event and is not reversible.
    Drag operations must have single-pointer alternative
    WCAG 2.5.7
    Manual
    Any functionality that uses dragging must also be achievable with a single pointer without dragging.
    Error: Drag operation has no single-pointer alternative.

  • Understandable

    Instructions must not rely solely on sensory characteristics
    WCAG 1.3.3
    Manual
    Verify that instructions do not depend only on shape, size, visual location, orientation, or sound (e.g., "click the round button" or "see the sidebar on the right"). Use additional text references.
    Error: Instructions depend only on shape, size, location, or sound.
    Help mechanisms must be in consistent location
    WCAG 3.2.6
    Manual
    If help mechanisms (contact info, help links) are provided on multiple pages, verify they appear in the same relative location each time.
    Error: Help access appears in different locations across pages.
    Information previously entered must not require re-entry
    WCAG 3.3.7
    Manual
    In multi-step form processes, verify that information the user has already entered is auto-populated or available for selection rather than requiring re-entry.
    Error: User must re-enter information already provided in same process.
    Cognitive function test must not be required for authentication
    WCAG 3.3.8
    Manual
    Verify that authentication does not require solving a puzzle, memorizing a password, or performing a cognitive test. Alternatives like copy-paste, password managers, or biometric authentication must be supported.
    Error: Authentication requires cognitive function test without alternative.
    Status messages must be programmatically determinable
    WCAG 4.1.3
    Manual
    Verify that status messages (success confirmations, error alerts, progress updates) can be detected by assistive technology without receiving focus.
    Error: Status message is not programmatically determinable.