errorEN 16931

BR-33:Document level allowance reason required

A document level allowance (discount) is missing both a reason text (BT-97) and reason code (BT-98). At least one must be provided to explain why this discount exists.

Severity
Fatal
Rule set
EN 16931
Country
All EU
Fix type
AUTO-FIX
Confidence
85%
Category
structural

Engine Classification

Add default item name when missing per EN16931 BR-33

Confidence: 85% · Applied automatically in pipeline

What is BR-33?

BR-33 is a fatal validation rule defined in the EN 16931 specification. It validates the Name element under Item in the UBL invoice XML.

When this rule fires, the invoice is non-compliant and will be rejected by Peppol access points and national validation services. The sending system receives a rejection response and the invoice does not reach the buyer.

Target path: //cac:InvoiceLine/cac:Item/cbc:Name

Why This Error Matters

Invoice rejected. Buyer needs to understand what the allowance is for.

BR-33 is a hard failure. Invoices that trigger this rule are rejected at the access point and never reach the recipient. In Peppol networks, this means your sending system receives an MLR (Message Level Response) with a rejection status. The invoice must be corrected and re-sent, adding delay to your payment cycle.

Invoice Navigator can automatically correct this error in your pipeline. The fix is applied with full audit evidence, so your compliance trail remains intact.

Validator Behavior

  • ·Causes invoice rejection
  • ·Error returned: BR-33
  • ·Specification: EN 16931

How to Fix It

1.

Find allowance

Locate the cac:AllowanceCharge with ChargeIndicator=false that is missing reason

2.

Add reason code

Insert <cbc:AllowanceChargeReasonCode>95</cbc:AllowanceChargeReasonCode> (95 = Discount)

3.

Or add reason text

Alternatively add <cbc:AllowanceChargeReason>Discount</cbc:AllowanceChargeReason>

Before / After

Failing XML
<Invoice>
  <!-- Issue: Each Document level allowance shall have a Document level al -->
</Invoice>
Corrected XML
<Invoice>
  <!-- Issue resolved per EN 16931 -->
</Invoice>

Technical Reference

XPath//cac:InvoiceLine/cac:Item/cbc:Name
SpecEN 16931
Operationset_default
StrategyAdd default item name when missing per EN16931 BR-33

Code Example

<cac:InvoiceLine>
  <cbc:ID>1</cbc:ID>
  <!-- line content -->
</cac:InvoiceLine>
<cac:InvoiceLine>
  <cbc:ID>2</cbc:ID>
  <!-- next line -->
</cac:InvoiceLine>

Common Causes

  • ·Document allowance has no reason text or code
  • ·AllowanceChargeReason and ReasonCode both empty
  • ·Generic discount applied without categorization
  • ·Export template missing reason field mapping
  • ·Allowance reason not mandatory in source system

Seeing this in production? The API handles BR-33 automatically. See the fix response →

Commonly Seen In

All invoicing software

Frequently Asked Questions

Each invoice line must have a unique identifier.

Add unique ID to each invoice line. You can also use Invoice Navigator's automatic Fixer tool to correct this instantly.

Yes, BR-33 is a critical error that will cause invoice rejection. It must be fixed before submission to ensure your invoice is accepted by the recipient's system.

Many instances of BR-33 can be automatically corrected using Invoice Navigator's Fixer tool. Upload your invoice and the tool will identify and fix common issues, including invoice line identifier required.

BR-33 is commonly seen in exports from All invoicing software. These software packages sometimes generate invoices that need adjustment to meet full compliance standards.

See Also

Related Errors

Last updated: 27 February 2026

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Handle BR-33 Automatically in Your Pipeline

The compliance engine auto-remediates this error with controlled safety policies and evidence pack generation.