What it means
The rule checks the seller's contact (cac:AccountingSupplierParty/cac:Party/cac:Contact) and fails when it holds a cbc:Note, a free-text remark about the contact. EN 16931 has no note on the contact. It does have a note for the whole invoice (BT-22), which sits directly under the invoice and is a different element.
Why it matters
This is only a warning, so the invoice is still accepted. A note on the contact is not part of the standard, so the recipient's software ignores it and the buyer never sees it.
How to fix it
Remove cbc:Note from cac:Contact under the seller party. If the text is something the buyer should read, such as who to ask about the invoice, move it to the invoice note (BT-22), which is the cbc:Note directly under cbc:ID at the top of the invoice. It is worth fixing when the text matters, because at the moment it is not passed on.
The rule as published
A UBL invoice should not include the AccountingSupplierParty Party Contact Note 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-191 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-195 The seller's service provider party should be left out
- UBL-CR-196 The seller's power of attorney should be left out
- UBL-CR-197 The seller's own bank account block should be left out