What it means
An invoice or credit note can point to the tender or lot it belongs to (BT-17) through cac:OriginatorDocumentReference, and EN 16931 uses only the identifier (cbc:ID) inside it. This rule checks that there is no cbc:IssueTime there, the time of day the referenced document was issued. It fails when the element is present at all, even if it is empty.
Why it matters
This is a warning, so the file is still accepted and can be sent. EN 16931 has no field for this time, so the recipient's software has nowhere to put it and normally ignores it. It is worth removing because it adds nothing and a recipient with stricter checks may query it.
How to fix it
Open the tender or lot reference in your invoicing software, often under references or procurement details, and clear any time next to it. Keep the reference number. If the software fills the time in by itself, update it or ask the supplier to stop, then export the file again. If you build the XML yourself, delete cbc:IssueTime from cac:OriginatorDocumentReference.
The rule as published
A UBL invoice should not include the OriginatorDocumentReference IssueTime Where this rule applies
| Rule set | Version |
|---|---|
| EN 16931 (UBL) | 1.3.17 |
| EN 16931 (UBL credit note) | 1.3.17 |
| XRechnung 3.0 (UBL) | 3.0.2 |
| XRechnung 3.0 (UBL credit note) | 3.0.2 |
| Peppol BIS Billing 3.0 (invoice) | 2026.5 |
| Peppol BIS Billing 3.0 (credit note) | 2026.5 |
| SI-UBL 2.0 / NLCIUS (invoice) | 2.0.3.13 |
| SI-UBL 2.0 / NLCIUS (credit note) | 2.0.3.13 |
| France CTC (UBL invoice) | 1.4.0-04 |
| France CTC (UBL credit note) | 1.4.0-04 |
| CIUS-RO UBL Invoice 1.0.9 | 1.0.9 |
| CIUS-RO UBL Credit Note 1.0.9 | 1.0.9 |
Check your file
Drop your e-invoice to see whether UBL-CR-081 still fails, and which other rules do.