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 |
Check your file
Drop your e-invoice to see whether UBL-CR-194 still fails, and which other rules do.