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Fatal

CII-DT-091: Give a region as a name, not as a subdivision ID

In short

Fatal: fails the selected checks.

CII-DT-091 means a postal address in the file gives a region or state as a CountrySubDivisionID code, which EN 16931 does not allow. Fix it by writing the region as a name in CountrySubDivisionName, or by deleting it if it is not needed.

On this page

What it means

Each postal address in the invoice is a PostalTradeAddress block. The rule checks that the block has no CountrySubDivisionID element, which would hold a code for a region, state or province. EN 16931 has a free-text country subdivision instead (BT-39 for the seller, BT-54 for the buyer), written in the file as CountrySubDivisionName.

Why it matters

The format expects a region as a name and not as a code. A subdivision ID is outside the standard, so the file fails the check and the invoice is rejected.

How to fix it

If the region is worth stating, write it as a name, such as Bayern, in the country subdivision field. Otherwise leave it out, since it is optional. In your invoicing software, check whether the address has a state or region field that is exported as a code, and enter the name in full instead. In the XML, replace the CountrySubDivisionID line with a CountrySubDivisionName line holding the name, or delete it.

The rule as published

CountrySubDivisionID shall not be used.

Where this rule applies

Rule set Version
EN 16931 (CII) 1.3.17
XRechnung 3.0 (CII) 3.0.2
NLCIUS (CII) 1.0.3.13
France CTC (CII) 1.4.0-04
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether CII-DT-091 still fails, and which other rules do.

Updated 6 November 2026