DE-R-016
If both supplier and customer are located in Germany, and if one of the VAT codes S, Z, E, AE, K, G, L, or M is used, an invoice shall contain at least one of the following elements: "Seller VAT identifier" (BT-31) or "Seller tax registration identifier" (BT-32) or "SELLER TAX REPRESENTATIVE PARTY" (BG-11).
What does this rule mean?
For the VAT categories used, a seller tax identifier is missing.
When VAT categories such as S, AE, K etc. are used, the seller must give a VAT identifier (BT-31), a tax registration identifier (BT-32) or a tax representative (BG-11).
- BG-11
- Seller tax representative party (group)
- BT-31
- Seller VAT identifier
- BT-32
- Seller tax registration identifier
Official rule message (standard)
If both supplier and customer are located in Germany, and if one of the VAT codes S, Z, E, AE, K, G, L, or M is used, an invoice shall contain at least one of the following elements: "Seller VAT identifier" (BT-31) or "Seller tax registration identifier" (BT-32) or "SELLER TAX REPRESENTATIVE PARTY" (BG-11).
Where the rule applies
Syntax: UBL
Affected element (XPath):
(/ubl-invoice:Invoice | /ubl-creditnote:CreditNote)[$supplierCountryIsDE and $customerCountryIsDE]
Technical test
The rule passes when this Schematron expression holds true:
(not( ($BT-95-UBL-Inv = $supportedVATCodes or $BT-95-UBL-CN = $supportedVATCodes) or ($BT-102 = $supportedVATCodes) or ($BT-151 = $supportedVATCodes) ) or (cac:TaxRepresentativeParty, $BT-31orBT-32Path)) How to fix it
A missing or incorrect business entry only you can supply. Add or correct it, then re-check.
Add one of the three: a VAT identifier, a tax number, or a tax representative.
Correct the affected entry in your XML, then re-check the invoice. Validation runs locally in your browser — your file never leaves your machine.
Check an e-invoice here
Drop an XML or ZUGFeRD PDF file here. Validation runs locally in your browser against EN 16931 — your file never leaves your machine.