Thank you Leonard, thank you Michael for your responses, you confirmed my
doubts.

In Lithuania we have specification "PDF-LT", here are links to English
version of the document and its appendixes with technical details:
http://www.archyvai.lt/download/10484/pdf_lt_specification.doc
<http://www.archyvai.lt/download/10484/pdf_lt_specification.doc>  
http://www.archyvai.lt/download/10483/pdf_lt_apend.doc
<http://www.archyvai.lt/download/10483/pdf_lt_apend.doc>  

The appendixes document describes the technical details of the
specification. Specification does not seek to override any part of ISO
32000-1 or ISO 19005-2. It defines new XMP metadata, adds few dictionary
entries  with specific developer prefix "LTUd" registered by Adobe, defines
restrictions for document content and requirements for signatures.

Section II in appendixes document defines optional metadata in XMP format
that may be added to signature dictionary Metadata entry, which placement in
signature dictionary raised my doubts about validity of such approach. There
shouldn't be any other points in specification that would be conflicting
with the standards. Specification defined document format being fully
conformant to PDF/A-2 and signed with PAdES Baseline format signatures. 

Entering of EU eIDAS Regulation into force and approval of the new PAdES
Baseline signatures formats will require to make amendments into PDF-LT
specification to be aligned with new EU requirements. Thus it will also be a
good opportunity to resolve this issue with metadata in signature
dictionary. I hope it won't be a big issue for current implementations, as
specification was not widely endorsed since it has not been fully entered
into force. Besides, those metadata were optional and included only in
specific scenarios (when public institution registers a document).

To shift the metadata to signature field dictionary probably would be the
best solution. I also considered this option. Once again, thank you for your
responses.




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