What it means
Each discount (BG-27) or charge (BG-28) on an invoice line is checked for a CategoryTradeTax element, a block with a VAT category and rate. In EN 16931 a line discount or charge takes the VAT category and rate of the line it belongs to (BT-151 and BT-152), so it has no VAT block of its own.
Why it matters
This is a warning, so the file is still accepted. VAT is worked out from the line's own category and rate, so a VAT block on the discount or charge changes nothing. If it shows a different rate from the line, it only makes the file harder to read.
How to fix it
Delete the CategoryTradeTax from the line's SpecifiedTradeAllowanceCharge in the XML. Then check the VAT category and rate on the line itself, because those decide the VAT. In invoicing software, the rate is set on the line or item, not on the discount.
The rule as published
CategoryTradeTax should not be present 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 |
Check your file
Drop your e-invoice to see whether CII-SR-191 still fails, and which other rules do.