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Warning

UBL-CR-194: The seller's agent party should be left out

In short

Warning: worth checking.

UBL-CR-194 means the seller party in the UBL file names an agent (AgentParty), 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 party (cac:AccountingSupplierParty/cac:Party) and fails when it holds a cac:AgentParty, a party that acts as an agent for the seller. EN 16931 has no agent. It is not the same as the seller's tax representative (BG-11), which EN 16931 does have, in cac:TaxRepresentativeParty at the top level of the invoice.

Why it matters

This is only a warning, so the invoice is still accepted. The recipient treats the seller as the party that issued the invoice and ignores an agent block inside it, so the agent's details are not used.

How to fix it

Remove cac:AgentParty from cac:AccountingSupplierParty/cac:Party and export again. Check that the ordinary seller fields, the name, the VAT number and the postal address, are those of the company that issues the invoice. If the party is really your tax representative, use the tax representative block (BG-11) instead. It is worth fixing when you want a file with no warnings or when you build the XML yourself.

The rule as published

A UBL invoice should not include the AccountingSupplierParty Party AgentParty

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-194 still fails, and which other rules do.

Updated 6 November 2026