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 |
Check your file
Drop your e-invoice to see whether UBL-CR-328 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-332 No tax type code in the tax representative's tax scheme
- UBL-CR-333 No currency code in the tax representative's tax scheme
- UBL-CR-334 No jurisdiction address in the tax representative's tax scheme