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Warning

UBL-CR-161: Do not include a city subdivision in the seller's address

In short

Warning: worth checking.

UBL-CR-161 means the seller's postal address in the UBL file contains a CitySubdivisionName element, which EN 16931 does not use. It is only a warning: move the district into an address line and remove the element.

On this page

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
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether UBL-CR-161 still fails, and which other rules do.

Updated 6 November 2026