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Warning

UBL-CR-319: Leave the subdivision code out of the tax representative's address

In short

Warning: worth checking.

UBL-CR-319 means the tax representative's address (BG-12) in your UBL invoice or credit note has a country subdivision code element, which EN 16931 does not use. Remove that element and give the subdivision as text in the country subdivision field (BT-68) if you need it.

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. 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
Rule text from phive-rules 4.6.4.

Check your file

Drop your e-invoice to see whether UBL-CR-319 still fails, and which other rules do.

Updated 6 November 2026