With Update 27.3, Feature 616741 introduced the capability to embed PDF and document attachments as Base64-encoded strings in X-Rechnung XML exports. This functionality is not available for ZUGFeRD.

We request that Microsoft extends the ZUGFeRD implementation to support document attachments in two ways:

1. Base64 embedding in XML – Attachments encoded within the XML structure (same as X-Rechnung)
2. PDF/A-3 attachments – Attachments embedded as additional files in the PDF container (alongside the XML)

Current Behavior (ZUGFeRD)

• XML is embedded within the PDF/A-3 container
• Document attachments (service reports, delivery notes, timesheets) linked to the invoice are not included – neither in the XML nor as PDF attachments
• No parity with X-Rechnung

Expected Behavior

Option A – Base64 in XML: Embed attachments as Base64 within the XML using AdditionalReferencedDocument / AttachmentBinaryObject:

XML:

Service-Report-2025-001

916

Service Report

[Base64-encoded content]

Option B – PDF/A-3 attachments: Embed attachments as additional files in the PDF/A-3 container – the same way the XML itself is embedded. This leverages the PDF/A-3 format's native capability to hold multiple embedded files.

Ideally, both options should be available (configurable per setup).

Business Justification

1. Specification Compliance The ZUGFeRD specification explicitly allows embedded attachments. Microsoft Support confirmed: "ZUGFeRD specification technically allows embedded attachments via AdditionalReferencedDocument with AttachmentBinaryObject." By not implementing this, Business Central does not fully support the ZUGFeRD specification.

2. Regulatory Compliance German e-invoicing mandate (2025) requires EN 16931-compliant formats. Many industries (consulting, construction, logistics) must include supporting documents with invoices. Without this feature, businesses cannot transmit required documentation in a standardized way.

3. Interoperability

• Many systems process only the XML portion → attachments in XML ensure they are not lost
• Peppol transmission often forwards only XML → PDF-only attachments won't reach recipient
• PDF/A-3 attachments benefit users who view invoices manually in PDF readers

4. Customer Expectation X-Rechnung and ZUGFeRD are both EN 16931-compliant. Customers expect the same attachment capabilities for both formats.

Technical Feasibility

• Business Central already generates XML for ZUGFeRD before embedding it into PDF
• Adding Base64 attachments to XML before embedding is feasible (same logic as X-Rechnung)
• PDF/A-3 format natively supports multiple embedded files – no format limitation

Related Features (Update 27.3)

• Feature 616741: Embed PDFs in XRechnung XML ✓
• Feature 616740: Export email addresses in ZUGFeRD and XRechnung ✓
• Feature 613747: Enhance extensibility of ZUGFeRD ✓

Request

Extend ZUGFeRD export to support:

1. Base64-encoded attachments in XML (parity with X-Rechnung)
2. Additional file attachments in PDF/A-3 container (alongside XML)

This ensures full ZUGFeRD specification compliance and meets regulatory requirements for the German market.