What it means
In a UBL invoice or credit note, the seller (BG-4) has a postal address (BG-5) under cac:AccountingSupplierParty/cac:Party/cac:PostalAddress. This rule checks that this address has no cbc:CitySubdivisionName, a separate element for a district or neighbourhood within the city.
Why it matters
This is a warning, so the file is still accepted. The EN 16931 address has no field for a district inside a city, so the recipient's software normally ignores it and the buyer does not see it. Fix it when the district is part of how your address is written, or when you want a file without warnings.
How to fix it
In your invoicing software, put the district in an address line instead of a separate district field, then export again. In the XML this is the additional address line (BT-36). The city (BT-37) and post code (BT-38) stay in their own fields. If you build the XML yourself, delete cbc:CitySubdivisionName from cac:PostalAddress in the seller block.
The rule as published
A UBL invoice should not include the AccountingSupplierParty Party PostalAddress CitySubdivisionName 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-161 still fails, and which other rules do.
Related rules
- UBL-CR-162 The seller's address should not include a subdivision code
- UBL-CR-163 The seller's address should not include a region element
- UBL-CR-164 The seller's address should not include a district element
- UBL-CR-165 The seller's address should not include a timezone offset
- UBL-CR-166 The seller's country should be a code, not a name
- UBL-CR-167 The seller's address should not include map coordinates