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PEPPOL-EN16931-CL003: Reason code MUST be according to UNCL 7161 D.16B

Peppol BIS Billing 3.0 rule · Error · UBL / CII

StandardPeppol BIS Billing 3.0 (OpenPeppol)SeverityError: the invoice is rejectedSyntaxUBL, CIIApplies toInvoices and credit notes sent over the Peppol network (UBL) and, because XRechnung embeds the Peppol rule set, every XRechnung as well.

Official rule text

[PEPPOL-EN16931-CL003] Reason code MUST be according to UNCL 7161 D.16B.

Why this error occurs

The element is mandatory in this standard but is missing or empty in your file. Typical causes: the field is not filled in the invoicing software, the ERP export does not map it, or the element is present but contains only whitespace.

How to fix it

Add the element with a non-empty value at the position given by the context above. Check the master data (seller, buyer, payment) in your invoicing software; most tools expose the field under the business term name shown here. Re-validate after the change.

What the validator checks

Checked element (context):

UBL

cac:AllowanceCharge[cbc:ChargeIndicator = 'true']/cbc:AllowanceChargeReasonCode

Test (XPath):

some $code in $UNCL7161
            satisfies normalize-space(text()) = $code

CII

ram:SpecifiedTradeAllowanceCharge[normalize-space(ram:ChargeIndicator/udt:Indicator) = 'true']/ram:ReasonCode

Test (XPath):

some $code in $UNCL7161
                        satisfies normalize-space(text()) = $code

Check your invoice

Drop your XML or PDF on the validator and every failed rule is linked to its page here. Free, no account, the file is not stored.

Check your invoice →

Same check via API:

curl -F file=@invoice.xml https://einvoicechecker.com/v1/validate

Related rules

Frequently asked questions

What does PEPPOL-EN16931-CL003 mean?

PEPPOL-EN16931-CL003 is a peppol bis billing 3.0 rule: Reason code MUST be according to UNCL 7161 D.16B.

Will my invoice be rejected because of PEPPOL-EN16931-CL003?

Yes. PEPPOL-EN16931-CL003 is flagged "fatal"; validators (KoSIT, Peppol access points, the German ZRE/OZG-RE portals) reject the invoice until it is fixed.

Which formats does PEPPOL-EN16931-CL003 apply to?

Invoices and credit notes sent over the Peppol network (UBL) and, because XRechnung embeds the Peppol rule set, every XRechnung as well. Syntax: UBL and CII.

Source: Peppol BIS Billing 3.0.20 (November 2025). Catalogue generated from the official schematron on 2026-10-14.