What it means
UBL lets the tax details of a party carry a text that explains why the party is exempt from VAT. EN 16931 does not read it there. The reason for an exemption belongs to a VAT category in the VAT breakdown (BG-23), as text (BT-120) or as a code (BT-121). This rule fails whenever cbc:ExemptionReason is present in the seller's tax details.
Why it matters
This rule is a warning, so the invoice is still accepted. The recipient's software looks for the reason in the VAT breakdown and ignores it in the seller's details. It is worth fixing when the invoice is exempt from VAT, because the buyer and the tax authority need the reason where the standard puts it.
How to fix it
In your invoicing software, enter the exemption reason on the VAT category, for example next to the exempt line or in the VAT notes of the invoice, not in your company profile. If you build the XML yourself, delete cbc:ExemptionReason from cac:AccountingSupplierParty/cac:Party/cac:PartyTaxScheme. Then put the text in cbc:TaxExemptionReason under cac:TaxTotal/cac:TaxSubtotal/cac:TaxCategory.
The rule as published
A UBL invoice should not include the AccountingSupplierParty Party PartyTaxScheme ExemptionReason 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-172 still fails, and which other rules do.
Related rules
- UBL-CR-173 The seller's tax details should not include a registration address
- UBL-CR-174 The seller's tax scheme should not include a name
- UBL-CR-175 The seller's tax scheme should not include a tax type code
- UBL-CR-176 The seller's tax scheme should not include a currency code
- UBL-CR-177 The seller's tax scheme should not include a jurisdiction address
- UBL-CR-178 The seller's legal entity should not include a registration date