What it means
The tender or lot reference (BT-17) is carried in cac:OriginatorDocumentReference, where EN 16931 uses only the identifier (cbc:ID). This rule checks that there is no cac:IssuerParty, which would name the organisation that issued the referenced document.
Why it matters
This is a warning, so the invoice is not rejected. The standard already has its own sections for the seller, the buyer and other parties, and none of them is filled from this element. The recipient's software normally ignores it, so it is worth removing.
How to fix it
Open the tender or lot reference in your invoicing software and clear any organisation name or address saved as its issuer. Keep the reference number. If the details are needed, check that the buyer section of the invoice already holds them. If you build the XML yourself, remove cac:IssuerParty from cac:OriginatorDocumentReference.
The rule as published
A UBL invoice should not include the OriginatorDocumentReference IssuerParty 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-092 still fails, and which other rules do.