What it means
The check flags the presence of a country subdivision (BT-68) in the seller's tax representative postal address (BG-12), even if it is empty. In UBL, this is cac:TaxRepresentativeParty/cac:PostalAddress/cbc:CountrySubentity. In CII, it is ram:SellerTaxRepresentativeTradeParty/ram:PostalTradeAddress/ram:CountrySubDivisionName.
Why it matters
NLCIUS recommends omitting this address field. The CII variant explicitly allows it, but this warning does not tell you whether the address is correct or the invoice will be accepted.
How to fix it
Check the province, state, region or county in the tax representative's address. If you can omit it without making the address incomplete, remove its country subdivision element from the exported XML rather than leaving it empty. Keep any required tax representative details. If the subdivision is necessary, review the warning rather than deleting needed information. Export and recheck your file after any change.
Once the file is corrected, check it again for free: Check an e-invoice
The rule as published
The use of a country subdivision (cac:TaxRepresentativePart/cac:PostalAddress/cbc:CountrySubentity) is not recommended Where NLCIUS (CII) run it, the rule reads:
The use of a country subdivision (/*/*/ram:SellerTaxRepresentativeTradeParty/ram:PostalTradeAddress/ram:CountrySubDivisionName) is not recommended, but allowed Where this rule applies
| Rule set | Version |
|---|---|
| SI-UBL 2.0 / NLCIUS (invoice) | 2.0.3.13 |
| SI-UBL 2.0 / NLCIUS (credit note) | 2.0.3.13 |
| NLCIUS (CII) | 1.0.3.13 |
Check your file
Drop your e-invoice to see whether BR-NL-28-3 still fails, and which other rules do.