What it means
EN 16931 identifies the country in the tax representative's postal address (BG-12) by its two-letter country code (BT-69), such as NL or DE. The rule flags a cbc:Name inside cac:Country, where the country is also written out in words. UBL allows this, but EN 16931 has no field for it. The check is the same for invoices and credit notes.
Why it matters
EN 16931 uses the country code (BT-69), not a separate country name, in the tax representative's postal address.
How to fix it
Keep the country code (cbc:IdentificationCode) and drop the name. In your invoicing software, check that the tax representative's country is chosen from a list or entered as a two-letter code. If you build the XML yourself, delete cbc:Name from cac:TaxRepresentativeParty/cac:PostalAddress/cac:Country. 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 Country Name 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-323 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-327 No tax level code for the tax representative
- UBL-CR-328 No exemption reason code for the tax representative
- UBL-CR-329 No exemption reason text for the tax representative