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Fatal

PEPPOL-EN16931-R002: At most one invoice note, unless both parties are German

In short

Fatal: fails the selected checks.

PEPPOL-EN16931-R002 means the invoice has more than one invoice note (BT-22) although the buyer and seller are not both German. Combine the notes into one text, separating the parts with a line break, and export again.

On this page

What it means

A Peppol invoice may contain at most one invoice note (BT-22) at document level. Only when both the seller and the buyer are in Germany are several notes allowed, because XRechnung uses separate notes for legal statements.

Why it matters

Peppol BIS Billing 3.0 adds this rule to EN 16931 so that every access point and receiver can process the invoice the same way. The sending or receiving access point rejects an invoice that fails it, so it never reaches the buyer.

How to fix it

Combine the notes into one text, separating the parts with a line break, and export again. Notes that are really something else, such as payment terms or an order reference, belong in their own fields.

The rule as published

Read the rule on the publisher's site

Where this rule applies

Rule set Version
Peppol BIS Billing 3.0 (invoice) 2026.5
Peppol BIS Billing 3.0 (credit note) 2026.5
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether PEPPOL-EN16931-R002 still fails, and which other rules do.

Updated 6 November 2026