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 |
Check your file
Drop your e-invoice to see whether UBL-CR-188 still fails, and which other rules do.
Related rules
- UBL-CR-189 The seller contact's identifier should be left out
- UBL-CR-190 The seller contact's fax number should be left out
- UBL-CR-191 The note on the seller contact should be left out
- UBL-CR-192 Other contact channels for the seller should be left out
- UBL-CR-193 The seller's person details should be left out
- UBL-CR-194 The seller's agent party should be left out