PDF Cross-References with HTML document

Context:
ATR publishes the FCOM and AFM in PDF format. These documents are updated 3 to 4 times per year, depending on the number of Service Bulletins incorporated or corrections made.
 
My Airlines has developed its procedures manual (OMB-PRO) with multiple cross-references pointing to specific page numbers in the AFM and FCOM.
 
Problem:
Whenever I publish a new version of the FCOM or AFM, the links are no longer valid because, in 99% of cases, the page numbers have changed.
As a result, I have to manually update around 50 cross-references in the document to match the correct pages in the new PDF.
 
Potential solution:
Since the PDFs include bookmarks, would it be possible to create cross-references based on bookmarks or section titles instead of page numbers?
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