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Warning

UBL-CR-321: Leave the district out of the tax representative's address

In short

Warning: worth checking.

UBL-CR-321 means the tax representative's address (BG-12) has a district element, which EN 16931 does not use. Remove it, or write the district in an address line if the recipient needs 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. In UBL a postal address can carry a district or administrative area as its own element. EN 16931 has no field for it, because the address is given as address lines, city, post code, country subdivision and country. The rule fails when cac:TaxRepresentativeParty/cac:PostalAddress/cbc:District is in the file at all, even if empty.

Why it matters

EN 16931 does not use a separate district element in the tax representative's postal address (BG-12).

How to fix it

Leave the field exported as cbc:District out of the tax representative's address export. If the district is needed, add it to the second address line (BT-65). If you build the XML yourself, remove cbc:District from cac:TaxRepresentativeParty/cac:PostalAddress and, if needed, put the text in cbc:AdditionalStreetName. Recheck the exported 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 District

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-321 still fails, and which other rules do.

Updated 6 November 2026