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:Person under cac:TaxRepresentativeParty, which in UBL holds details of a natural person such as a first name, a family name or a job title. The standard has no field for this. The check is the same for invoices and credit notes.
Why it matters
EN 16931 uses the tax representative's name (BT-62), not a separate person block.
How to fix it
If the tax representative is a person, enter their full name in the tax representative's name field in your invoicing software, and leave the separate person block out of the XML export. If the software adds the block automatically, ask the vendor how to omit it. If you build the XML yourself, delete cac:Person from cac:TaxRepresentativeParty and put the name in cac:PartyName/cbc:Name. 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 Person 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-337 still fails, and which other rules do.
Related rules
- UBL-CR-338 No agent party for the tax representative
- UBL-CR-339 No service provider party for the tax representative
- UBL-CR-340 No power of attorney for the tax representative
- UBL-CR-341 No bank account for the tax representative
- UBL-CR-342 Leave out the delivery identifier
- UBL-CR-343 Leave out the delivery quantity