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Warning

UBL-CR-163: The seller's address should not include a region element

In short

Warning: worth checking.

UBL-CR-163 means the seller's postal address contains a Region element (cbc:Region), which EN 16931 does not use. Remove it, and put any county, state or province in the country subdivision (BT-39) instead.

On this page

What it means

UBL lets a postal address carry a separate Region element. EN 16931 has no field for it. The seller's address (BG-5) has one place for this kind of detail, the country subdivision (BT-39). This rule fails whenever cbc:Region is present in the seller's postal address, even if it is empty.

Why it matters

This rule is a warning, so the invoice is still accepted. The recipient's software has no field to store a region, so the value is ignored and does not reach their records. It is worth fixing when the region is part of how the recipient finds your address, because it will not be read where it is.

How to fix it

In your invoicing software, look at the address of your own company and move the region into the county, state or province field if there is one. If you build the XML yourself, delete cbc:Region from cac:AccountingSupplierParty/cac:Party/cac:PostalAddress and put the text in cbc:CountrySubentity.

The rule as published

A UBL invoice should not include the AccountingSupplierParty Party PostalAddress Region

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-163 still fails, and which other rules do.

Updated 6 November 2026