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 the name of a district or borough within the city, in its own element. EN 16931 has a city field (BT-66), alongside address lines, postcode, country subdivision and country, but no separate city subdivision field. The rule fails when cac:TaxRepresentativeParty/cac:PostalAddress/cbc:CitySubdivisionName is in the file at all, even if empty.
Why it matters
EN 16931 does not use a separate city subdivision field for the tax representative's address. A district or borough can be included in an address line if needed.
How to fix it
If you need the district or borough in the address, include it in an address line, such as the second address line (BT-65), cbc:AdditionalStreetName. Remove cbc:CitySubdivisionName 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 CitySubdivisionName 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-318 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-323 No country name in the tax representative's address
- UBL-CR-324 No map coordinates in the tax representative's address