PDF/A-3 It is a PDF variant that can be embedded into an XML file. The ZUGFeRD hybrid e-invoicing format from version 2.0.1 uses PDF/A-3: A file contains the readable PDF part and the structured XML data (BMF writing 2024, paragraphs 25 and 30; FAQ 7).
Separation from pure PDF/A
PDF/A refers to a long-term archiveable PDF. However, a pure PDF/A without an embedded XML file is not an e-invoice because the structured part is missing. Only PDF/A-3 with an embedded XML file results in a ZUGFeRD invoice. Not every ZUGFeRD profile is also sufficient: The MINIMUM and BASIC-WL profiles are not considered e-invoices. Only the profiles with complete invoice information (BMF letter 2024, paragraphs 25 and 30; FAQ 7) are considered e-invoices.
Which part applies
In a hybrid invoice, the structured XML part takes precedence. If the layout part and the XML part are not aligned with each other, the data in the XML part takes precedence (BMF letter 2024, p. 31). In these cases, only the structured part allows for the tax deduction (p. 32). If the layout part contains records relevant to taxation, such as booking notes, the company must also keep the layout part unchanged (p. 60).
Reference to SAP Business One
Since version 8.30, the Coresuite Designer generates ZUGFeRD files in PDF/A format on debitor invoices (AR invoices). In the print definition, the user switches between standard PDF and PDF/A. Older workarounds without native support only provided pure PDF/A without XML and therefore no ZUGFeRD. The add-on cks.eINVOICE offers the „PDF/A Attachment“ creation mode for ZUGFeRD with an integrated XML file. If cks.eINVOICE detects an invalid ZUGFeRD PDF, the print layout must be PDF/A-compatible.
Legal status: MF Treasury letter 2024, MF Treasury FAQ as of March 2026.
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