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When people talk about “accessible” PDF files, they usually are referring to “tagged” PDF files, even though there is more to an accessible PDF than tags. PDF tags provide a hidden structured, textual representation of the PDF content that is presented to screen readers. They exist for accessibility purposes only and have no visible effect on the PDF file.
In the current (2001) regulations, Sections 1194.21 and 1194.22 set technical requirements for forms and documents based on WCAG 1.0, which was specific to HTML. In the planned update to Section 508, new technical standards will be based on WCAG 2.0, with far richer and more extensive requirements. While PDF “Reading Order” is not relevant to Section 508 compliance or accessibility