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Warning

CII-SR-362: Do not give the payee a VAT number

In short

Warning: worth checking.

CII-SR-362 means the payee block holds a SpecifiedTaxRegistration, a tax or VAT registration of the payee, which EN 16931 does not use. Delete it and make sure the seller's VAT number is in the seller block.

On this page

What it means

The payee block (PayeeTradeParty) has a SpecifiedTaxRegistration element. EN 16931 carries VAT numbers for the seller (BT-31), the seller's tax representative (BT-63) and the buyer (BT-48), but does not carry one for the payee.

Why it matters

This is a warning, so the file is still accepted. The payee's VAT number plays no part in the VAT figures of an EN 16931 invoice, and receivers ignore it. It is worth fixing if you copied the wrong number here and the seller block is missing its own.

How to fix it

Delete the SpecifiedTaxRegistration block from the payee. Then check that the seller's VAT number (BT-31) is present in the seller block, and the buyer's (BT-48) where the invoice needs it. If your software lists a payee VAT number, remove it from the payee settings or from the export.

The rule as published

SpecifiedTaxRegistration 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
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether CII-SR-362 still fails, and which other rules do.

Updated 6 November 2026