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Warning

UBL-CR-328: No exemption reason code for the tax representative

In short

Warning: worth checking.

UBL-CR-328 means the tax details of the seller's tax representative contain an exemption reason code (cbc:ExemptionReasonCode), which EN 16931 does not use there. Remove the element to clear the warning.

On this page

What it means

The rule flags a cbc:ExemptionReasonCode inside cac:PartyTaxScheme of the seller's tax representative (BG-11). This is a code saying why that party is exempt from tax. It is not the same as the VAT exemption reason code (BT-121), which belongs in the VAT breakdown (BG-23) and is allowed. For the tax representative, EN 16931 only carries a name, a VAT number and an address.

Why it matters

EN 16931 does not use an exemption reason code in the tax representative's tax details; an invoice's VAT exemption reason belongs in the VAT breakdown (BG-23).

How to fix it

Remove the code from the tax representative's tax details. If the invoice has lines that are exempt from VAT, set the exemption reason (BT-121 or the text BT-120) on that VAT category in your invoicing software so it ends up in the VAT breakdown. If you build the XML yourself, delete cbc:ExemptionReasonCode from cac:TaxRepresentativeParty/cac:PartyTaxScheme. 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 PartyTaxScheme ExemptionReasonCode

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-328 still fails, and which other rules do.

Updated 6 November 2026