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 one country subdivision (BT-68), such as a region, county, state or province. UBL also has a separate region element, and the standard does not use it. The rule fails when cac:TaxRepresentativeParty/cac:PostalAddress/cbc:Region is in the file at all, even if empty.
Why it matters
EN 16931 uses the country subdivision field (BT-68), not the separate region element, for the tax representative's address.
How to fix it
If you need the region in the address, include it in the country subdivision field (BT-68), cbc:CountrySubentity. Check any existing subdivision text before changing it. Remove cbc:Region 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 Region 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-320 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-326 No registration name in the tax representative's tax details