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Warning

UBL-CR-302: Do not add a separate identifier for the tax representative

In short

Warning: worth checking.

UBL-CR-302 means the tax representative (BG-11) has a cac:PartyIdentification element in your UBL invoice or credit note, which EN 16931 does not use for this party. Remove that element without removing the representative's VAT number (BT-63).

On this page

What it means

The invoice can name the seller's tax representative (BG-11), the person or company the seller has appointed to account for VAT on its behalf, for example when the seller is based in another country. EN 16931 describes this party with a name (BT-62), a VAT number (BT-63) and an address (BG-12). The seller itself can carry other identifiers, such as a company registration number (BT-30). The rule fails when cac:TaxRepresentativeParty/cac:PartyIdentification is in the file at all, even if empty. It checks both invoices and credit notes.

Why it matters

EN 16931 does not use the separate party identification element for the tax representative. The representative's VAT number (BT-63) is carried in a different field.

How to fix it

Remove cac:PartyIdentification from cac:TaxRepresentativeParty in your exported file. Keep the representative's name, VAT number (BT-63) and postal address. The VAT number is carried in cac:PartyTaxScheme/cbc:CompanyID under cac:TaxRepresentativeParty. Recheck the corrected file.

Once the file is corrected, check it again for free: Validate an invoice against EN 16931

Or fix the invoice in a form and download the corrected file, for 1 credit: Fix a rejected e-invoice

The rule as published

A UBL invoice should not include the TaxRepresentativeParty PartyIdentification

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-302 still fails, and which other rules do.

Updated 6 November 2026