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Warning

UBL-CR-166: The seller's country should be a code, not a name

In short

Warning: worth checking.

UBL-CR-166 means the seller's country is also given as a name (cac:Country/cbc:Name), which EN 16931 does not use. Remove the name and keep the two-letter country code (BT-40).

On this page

What it means

EN 16931 identifies the seller's country only by its country code (BT-40), such as NL, DE or FR. UBL has an extra element for the country name. This rule fails whenever cbc:Name is present inside the country of the seller's postal address, even if it is empty. The country code itself is still required.

Why it matters

This rule is a warning, so the invoice is still accepted. Software reads the code and ignores the name. If the name and the code ever disagree, the code is the one that counts. It is worth fixing when your software writes both, so that the file has one clear answer.

How to fix it

In your invoicing software, the country of your own company is usually picked from a list, and the export writes the code for you. If the name is added as well, look for an export option that leaves it out. If you build the XML yourself, delete cbc:Name from cac:Country in the seller's postal address and keep cbc:IdentificationCode.

The rule as published

A UBL invoice should not include the AccountingSupplierParty Party PostalAddress Country Name

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-166 still fails, and which other rules do.

Updated 6 November 2026