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Warning

UBL-CR-322: No time zone offset in the tax representative's address

In short

Warning: worth checking.

UBL-CR-322 means the address of the seller's tax representative contains a time zone offset (cbc:TimezoneOffset), which EN 16931 does not use. It is a warning. Remove the element from the exported file to clear it.

On this page

What it means

If the seller has appointed a tax representative to account for VAT on its behalf, that party sits in cac:TaxRepresentativeParty (BG-11) and its postal address is BG-12. EN 16931 only has fields for the address lines, city, post code, country subdivision and country code. The rule flags a cbc:TimezoneOffset in that address, a value such as +01:00 that UBL allows but EN 16931 has no field for. It applies to invoices and credit notes alike.

Why it matters

EN 16931 does not use a time zone offset in the tax representative's postal address (BG-12).

How to fix it

Remove cbc:TimezoneOffset from cac:TaxRepresentativeParty/cac:PostalAddress in the exported XML. Do not leave an empty cbc:TimezoneOffset element behind. If your software adds it automatically, ask the vendor how to omit it. 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 TimezoneOffset

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-322 still fails, and which other rules do.

Updated 6 November 2026