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Warning

UBL-CR-519: A line should not have a free of charge flag

In short

Warning: worth checking.

UBL-CR-519 means an invoice or credit note line contains a free of charge flag (cbc:FreeOfChargeIndicator), which EN 16931 does not use. It is a warning. Remove the flag, but do not change the price just because the flag is present.

On this page

What it means

The rule checks every cac:InvoiceLine in a UBL invoice and every cac:CreditNoteLine in a UBL credit note for cbc:FreeOfChargeIndicator. It checks whether the element exists, regardless of whether its value is true or false. The unit price (BT-146) and line amount excluding VAT (BT-131) are separate fields.

Why it matters

EN 16931 does not use a separate free of charge flag on a line.

How to fix it

Delete cbc:FreeOfChargeIndicator from each cac:InvoiceLine or cac:CreditNoteLine. Its presence does not mean the line is free, because the flag may be false. Keep the unit price (BT-146), discounts, charges and line amount excluding VAT (BT-131) consistent with what you are charging. Recheck the 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 InvoiceLine FreeOfChargeIndicator

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-519 still fails, and which other rules do.

Updated 6 November 2026