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Warning

UBL-CR-188: The seller's shareholder party should be left out

In short

Warning: worth checking.

UBL-CR-188 means the seller's legal entity in the UBL file describes a shareholder (ShareholderParty), which EN 16931 does not use. It is a warning, so the invoice is still accepted, but you can remove the block.

On this page

What it means

The rule checks the seller's legal entity block (cac:PartyLegalEntity) and fails when it holds a cac:ShareholderParty, a description of a party that owns shares in the seller's company. EN 16931 has no field for shareholders, and the information is not needed to understand or pay the invoice.

Why it matters

This is only a warning, so the invoice is still accepted. Software that follows EN 16931 does not read shareholder details, so they are ignored. They also add data about owners to a document that normally goes to the buyer and sometimes to a public body.

How to fix it

Remove cac:ShareholderParty from cac:AccountingSupplierParty/cac:Party/cac:PartyLegalEntity and export again. This block is rarely filled in by hand, so check the export settings or the XML template of your invoicing software. If the recipient really needs the information, send it separately or as text in the invoice note (BT-22). It is worth fixing when you build the XML yourself or want a clean file.

The rule as published

A UBL invoice should not include the AccountingSupplierParty Party PartyLegalEntity ShareholderParty

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-188 still fails, and which other rules do.

Updated 6 November 2026