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Warning

UBL-CR-601: Exemption reason text belongs in the VAT breakdown, not on a line

In short

Warning: worth checking.

UBL-CR-601 means the VAT category of an item on an invoice or credit note line has exemption reason text (cbc:TaxExemptionReason), which EN 16931 does not use at line level. It is a warning. Remove it from the line. If you need to include the reason text (BT-120), put it in the matching VAT breakdown entry (BG-23).

On this page

What it means

The rule looks at the item on every invoice line (or credit note line) in a UBL file. It warns when the item's VAT details (cac:ClassifiedTaxCategory) contain a cbc:TaxExemptionReason, a written reason why no VAT is charged. The VAT exemption reason text (BT-120) belongs in a VAT breakdown entry (BG-23), not in the line's classified tax category. This rule does not check whether a reason is present or required in the breakdown.

Why it matters

EN 16931 does not use exemption reason text within a line's classified tax category.

How to fix it

Check the export mapping for the exemption reason text in your invoicing software. If you need to include the text, such as Reverse charge or Intra-community supply, put it in the matching VAT breakdown entry. If you build the XML yourself, use cbc:TaxExemptionReason in cac:TaxTotal/cac:TaxSubtotal/cac:TaxCategory for that entry. Then delete it from cac:ClassifiedTaxCategory under cac:InvoiceLine/cac:Item (cac:CreditNoteLine in a credit note).

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 Item ClassifiedTaxCategory TaxExemptionReason

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-601 still fails, and which other rules do.

Updated 6 November 2026