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Warning

UBL-CR-329: No exemption reason text for the tax representative

In short

Warning: worth checking.

UBL-CR-329 means the tax details of the seller's tax representative contain exemption reason text (cbc:ExemptionReason), 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:ExemptionReason inside cac:PartyTaxScheme of the seller's tax representative (BG-11), free text saying why that party is exempt from tax. It is not the same as the VAT exemption reason text (BT-120), 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 exemption reason text 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 text from the tax representative's tax details. If part of the invoice is exempt from VAT, enter the reason on that VAT category in your invoicing software, so it ends up as BT-120 in the VAT breakdown. If you build the XML yourself, delete cbc:ExemptionReason 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 ExemptionReason

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-329 still fails, and which other rules do.

Updated 6 November 2026