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Warning

UBL-CR-197: The seller's own bank account block should be left out

In short

Warning: worth checking.

UBL-CR-197 means the seller party in the UBL file carries a bank account of its own (FinancialAccount), which EN 16931 does not use there. It is a warning, so the invoice is still accepted. Check that your IBAN is in the payment instructions (BG-16), then remove this block.

On this page

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
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether UBL-CR-197 still fails, and which other rules do.

Updated 6 November 2026