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Warning

UBL-CR-162: The seller's address should not include a subdivision code

In short

Warning: worth checking.

UBL-CR-162 means the seller's postal address contains a country subdivision code (cbc:CountrySubentityCode), which EN 16931 does not use. Remove the element. If you want to show the county, state or province, write it as plain text in the country subdivision (BT-39).

On this page

What it means

The seller's postal address (BG-5) can carry a county, state or province as text in the country subdivision (BT-39, cbc:CountrySubentity). This rule checks that the separate code element cbc:CountrySubentityCode is not there at all. It fires when the element is present, even if it is empty, and applies to UBL invoices and credit notes.

Why it matters

This rule is a warning, so the invoice is still accepted. EN 16931 has no place for a subdivision code, so the recipient's software skips it and never sees the value. It is worth fixing when the code matters to the recipient, because only the text in BT-39 is read, or when you want a file that passes without any notice.

How to fix it

Check the address of your own company in your invoicing software, and the export settings if it has them. If there is a field for the county, state or province, make sure it is exported as text and not as a code. If you build the XML yourself, delete cbc:CountrySubentityCode from cac:AccountingSupplierParty/cac:Party/cac:PostalAddress and put the name in cbc:CountrySubentity instead.

The rule as published

A UBL invoice should not include the AccountingSupplierParty Party PostalAddress CountrySubentityCode

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-162 still fails, and which other rules do.

Updated 6 November 2026