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To get this error, you usually have created a heading via the Paragraph drop menu but either:
False Positives
If your heading contains a space or the Unicode , the Accessibility Checker (UDOIT) will not recognize the heading as being empty. It is not common for an empty--or in this case invisible--heading to only contain a space, but if it happens to you, this is why the Accessibility Checker (UDOIT) has not flagged it.