What it means
The rule checks that the delivery location (cac:Delivery/cac:DeliveryLocation) has no country subentity (cbc:CountrySubentity), meaning a region, state or province, directly under it. EN 16931 does have a place for this, the deliver-to country subdivision (BT-79), but it sits inside the address (cac:Address/cbc:CountrySubentity). Only the copy placed directly under the location is flagged.
Why it matters
EN 16931 places the deliver-to country subdivision (BT-79) inside the address, not directly on the delivery location.
How to fix it
If you need to keep the region, enter it as part of the deliver-to address in your invoicing software, in the field for state, province or region, and export again. If you build the XML yourself, put the value in cac:Address/cbc:CountrySubentity inside the same cac:DeliveryLocation if it belongs in the address and is not already there. Delete the cbc:CountrySubentity that sits directly under cac:DeliveryLocation.
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 Delivery DeliveryLocation CountrySubentity 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-353 still fails, and which other rules do.
Related rules
- UBL-CR-354 Leave out the region code on the delivery location
- UBL-CR-355 Leave out the type code of the delivery location
- UBL-CR-356 Leave out the information URI on the delivery location
- UBL-CR-357 Leave out the name on the delivery location
- UBL-CR-358 Leave out the validity period of the delivery location
- UBL-CR-359 Leave out the identifier on the delivery address