What it means
EN 16931 describes the seller's tax representative (BG-11) by a name (BT-62), a VAT number (BT-63) and a postal address (BG-12). The rule flags a cac:PhysicalLocation directly under cac:TaxRepresentativeParty, which is a separate place such as a site or office with its own name and address. UBL allows it, but EN 16931 has no field for it. The rule is the same for invoices and credit notes.
Why it matters
EN 16931 uses the tax representative's postal address (BG-12), not a separate physical location block.
How to fix it
Leave the tax representative's separate physical location out of the XML export. If you build the XML yourself, delete cac:PhysicalLocation from cac:TaxRepresentativeParty. You do not need to copy its address into the postal address to clear this warning. 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 PhysicalLocation 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-325 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-330 No registration address in the tax representative's tax details
- UBL-CR-331 No tax scheme name for the tax representative