What it means
The rule checks the seller party (cac:AccountingSupplierParty/cac:Party) and fails when it holds a cac:FinancialAccount. EN 16931 does not take the account to pay into from the party. It takes it from the payment instructions (BG-16): cac:PaymentMeans with a cac:PayeeFinancialAccount, whose ID is the IBAN or other account number (BT-84).
Why it matters
This is only a warning, so the invoice is still accepted. The recipient looks for the account to pay in the payment instructions and does not read one stored in the party. If the account appears only here, the buyer's system finds no bank details, and an XRechnung without payment instructions fails rule BR-DE-1.
How to fix it
Open the payment details of the invoice in your invoicing software and check that the payment method and your IBAN are filled in. In the XML they are in cac:PaymentMeans/cac:PayeeFinancialAccount/cbc:ID. Then remove cac:FinancialAccount from cac:AccountingSupplierParty/cac:Party. It is worth fixing soon if the account is only in the party block, because the buyer then has no bank details to pay to.
The rule as published
A UBL invoice should not include the AccountingSupplierParty Party FinancialAccount 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-197 still fails, and which other rules do.