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Fatal

UBL-SR-20: The payee can have one identifier and must differ from the seller

In short

Fatal: fails the selected checks.

UBL-SR-20 means the payee (BG-10) has more than one identifier (BT-60), the payee or seller name element is missing, or the two names are the same. Keep one payee identifier and only include a payee when it is a different party from the seller.

On this page

What it means

The payee identifier (BT-60) identifies the party that is paid when that is not the seller. The rule counts the cbc:ID elements in the payee's cac:PartyIdentification and allows one, ignoring any whose schemeID is SEPA, which is matched without regard to letter case and is used for the bank-assigned creditor identifier (BT-90) of a direct debit. The rule also repeats the name check of UBL-SR-19: the payee name must differ from the seller name, so it also fails if either name element is missing or the names are identical.

Why it matters

When you include a payee, EN 16931 allows at most one identifier not marked SEPA and requires the payee and seller names to be present and different.

How to fix it

In your invoicing software, open the payee or pay-to details and keep one identifier, for example a company number or a GLN. If you are paid yourself, clear the payee details so the file has no payee, because the payee name must differ from the seller name. If you include a payee, make sure the payee and seller name elements are both present. In the XML, keep one cbc:ID in cac:PayeeParty/cac:PartyIdentification, not counting any with schemeID SEPA in any letter case.

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

Payee identifier shall occur maximum once, if the Payee is different from the Seller

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-SR-20 still fails, and which other rules do.

Updated 6 November 2026