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Warning

UBL-CR-338: No agent party for the tax representative

In short

Warning: worth checking.

UBL-CR-338 means the seller's tax representative has an agent party (cac:AgentParty), which EN 16931 does not use. Remove the block.

On this page

What it means

The rule flags a cac:AgentParty under cac:TaxRepresentativeParty. In UBL this is another party that acts as agent for the tax representative, with its own name, address and tax details. EN 16931 has no field for it. The tax representative itself is described only by a name (BT-62), a VAT number (BT-63) and a postal address (BG-12). It applies to invoices and credit notes.

Why it matters

EN 16931 does not use an agent party within the tax representative's details.

How to fix it

Leave the agent details out of the tax representative's XML export. If your recipient needs to know who the agent is, agree another way to tell them, as EN 16931 does not use this element. If you build the XML yourself, delete cac:AgentParty from cac:TaxRepresentativeParty. 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 AgentParty

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-338 still fails, and which other rules do.

Updated 6 November 2026