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Warning

CII-SR-394: Leave the exchange rate out of invoice discounts and charges

In short

Warning: worth checking.

CII-SR-394 means a discount or charge on the whole invoice contains an ActualTradeCurrencyExchange, which EN 16931 does not use. It is only a warning and the invoice is still accepted; remove the element and give the amount in the invoice currency.

On this page

What it means

A discount (BG-20) or charge (BG-21) on the whole invoice contains an ActualTradeCurrencyExchange element, which holds a currency exchange rate. EN 16931 has no exchange rate on a single discount or charge: these amounts are given in the invoice currency (BT-5).

Why it matters

This is a warning, so the invoice is still accepted. The buyer's software does not read the exchange rate, so any conversion it describes is ignored. It is worth fixing if the amount on the discount or charge is not in the invoice currency, because then the totals may not add up for the buyer.

How to fix it

Remove the ActualTradeCurrencyExchange element and state the discount or charge in the invoice currency. If the VAT also has to be reported in another currency, EN 16931 does that once for the whole invoice, with the VAT accounting currency (BT-6) and the total VAT amount in that currency (BT-111).

The rule as published

ActualTradeCurrencyExchange 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-394 still fails, and which other rules do.

Updated 6 November 2026