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 |
Check your file
Drop your e-invoice to see whether UBL-CR-162 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-168 The seller should not have a physical location