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. EN 16931 lets its address carry a country subdivision (BT-68), such as a region, county, state or province, written as text. UBL also has a separate element for a code of that subdivision, and the standard does not use it. The rule fails when cac:TaxRepresentativeParty/cac:PostalAddress/cbc:CountrySubentityCode is in the file at all, even if empty.
Why it matters
EN 16931 uses the country subdivision field (BT-68), not the separate subdivision code element, for the tax representative's address.
How to fix it
If you need the subdivision in the address, enter its name or abbreviation in the country subdivision field (BT-68), cbc:CountrySubentity. Remove cbc:CountrySubentityCode 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 CountrySubentityCode 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-319 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-325 No physical location for the tax representative