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    Maybe the user wants to edit these configuration files. Maybe he has special tools for editing and validating XML but not .ini or JSON. Also, I don't believe functional requirements are always related to user needs. they can also be related to other systems your software needs to interact with. Commented Feb 17, 2019 at 10:24
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    @FrankPuffer, if a user loses the possibility to edit the configuration files with company-standard tool X, then the requirement to have the configuration files in XML is a functional requirement. Anyone or anything interacting with the system is a user in this case. That includes administrators and other software systems. Commented Feb 17, 2019 at 10:28