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Warning

CII-SR-395: Do not add a VAT subtotal element to the invoice settlement

In short

Warning: worth checking.

CII-SR-395 means the invoice contains a SubtotalCalculatedTradeTax element, which EN 16931 does not use. It is only a warning and the invoice is still accepted; remove the element and keep the VAT breakdown in the usual ApplicableTradeTax entries.

On this page

What it means

The invoice settlement section contains a SubtotalCalculatedTradeTax element, a tax subtotal that EN 16931 does not use. The VAT breakdown (BG-23) is written as ApplicableTradeTax entries, which are a different element.

Why it matters

This is a warning, so the invoice is still accepted. The buyer's software reads the VAT breakdown from the ApplicableTradeTax entries and ignores this element, so any VAT figures that only appear here are lost. It is worth fixing if those figures matter to the buyer, or if their system is strict about extra elements.

How to fix it

Remove the SubtotalCalculatedTradeTax element. Then check that the VAT breakdown is complete in the ApplicableTradeTax entries, with one entry for each VAT category and VAT rate on the invoice. Removing the subtotal element does not remove those entries.

The rule as published

SubtotalCalculatedTradeTax 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-395 still fails, and which other rules do.

Updated 6 November 2026