What it means
The rule checks that the delivery location (cac:Delivery/cac:DeliveryLocation) has no country subentity code (cbc:CountrySubentityCode) directly under it. This is the coded form of a region, state or province. EN 16931 only has a text field for it, the deliver-to country subdivision (BT-79), inside the address.
Why it matters
EN 16931 uses the deliver-to country subdivision (BT-79) inside the address, not a country subentity code directly on the delivery location.
How to fix it
Clear the region code in the delivery data of your invoicing software. If you need to keep the region, write its name in the state, province or region field of the deliver-to address. If you build the XML yourself, delete the cbc:CountrySubentityCode that sits directly under cac:DeliveryLocation. If you want to keep the region, put its name in cac:Address/cbc:CountrySubentity.
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 CountrySubentityCode 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-354 still fails, and which other rules do.
Related rules
- 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
- UBL-CR-360 Leave out the address type code on the delivery address