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. In UBL a postal address can carry a 'care of' name, meaning a person or organisation at whose address the addressee can be reached, in its own element. EN 16931 has no separate field for it, because the address is given as address lines, city, postcode, country subdivision and country. The rule fails when cac:TaxRepresentativeParty/cac:PostalAddress/cbc:MarkCare is in the file at all, even if empty.
Why it matters
EN 16931 does not use a separate care-of field for the tax representative's address. A care-of name can be included in an address line if needed.
How to fix it
If you need the care-of name in the address, include it in an address line, such as the second address line (BT-65), cbc:AdditionalStreetName, for example 'c/o Example Services'. Remove cbc:MarkCare from cac:TaxRepresentativeParty/cac:PostalAddress and 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 PostalAddress MarkCare 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-316 still fails, and which other rules do.
Related rules
- UBL-CR-317 Leave the separate plot identifier field out of the tax representative's address
- UBL-CR-318 Leave the separate city subdivision field out of the tax representative's address
- UBL-CR-319 Leave the subdivision code out of the tax representative's address
- UBL-CR-320 Leave the separate region field out of the tax representative's address
- UBL-CR-321 Leave the district out of the tax representative's address
- UBL-CR-322 No time zone offset in the tax representative's address