BR-38:Document level charge reason required
Fix: Invoice Navigator automatically fixes this Invoice compliance issue by updating the relevant XML elements (BR-38). Upload your invoice to fix this automatically.
A document level charge is missing both a reason text (BT-104) and reason code (BT-105). At least one must be provided to explain what this charge is for.
Engine Classification
Ensure seller postal address includes country code per EN16931 BR-38
Confidence: 85% · Applied automatically in pipeline
What is BR-38?
BR-38 is a fatal validation rule defined in the EN 16931 specification. It validates the IdentificationCode element under PostalAddress > Country in the UBL invoice XML.
When this rule fires, the invoice is rejected by Peppol access points and never reaches the buyer.
Target path: //cac:AccountingSupplierParty/cac:Party/cac:PostalAddress/cac:Country/cbc:IdentificationCode
Why This Error Matters
Invoice rejected. Buyer needs to understand what they are being charged for.
BR-38 is a hard failure — the invoice must be corrected and re-sent before it can reach the recipient.
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-38
- ·Specification: EN 16931
How to Fix It
Find charge
Locate the cac:AllowanceCharge with ChargeIndicator=true that is missing reason
Add reason code
Insert <cbc:AllowanceChargeReasonCode>SAA</cbc:AllowanceChargeReasonCode> (SAA = Shipping and handling)
Or add reason text
Alternatively add <cbc:AllowanceChargeReason>Service charge</cbc:AllowanceChargeReason>
Before / After
<Invoice> <!-- Issue: Each Document level charge shall have a Document level charg --> </Invoice>
<Invoice> <!-- Issue resolved per EN 16931 --> </Invoice>
Technical Reference
//cac:AccountingSupplierParty/cac:Party/cac:PostalAddress/cac:Country/cbc:IdentificationCodeCode Example
<cac:TaxSubtotal>
<cbc:TaxableAmount currencyID="EUR">1000.00</cbc:TaxableAmount>
<cbc:TaxAmount currencyID="EUR">210.00</cbc:TaxAmount>
<!-- 1000 × 21% = 210 -->
</cac:TaxSubtotal>Common Causes
- ·Document charge has no reason text or code
- ·ChargeReason and ReasonCode both empty
- ·Generic surcharge applied without categorization
- ·Export template missing charge reason mapping
- ·Charge reason not mandatory in source system
Seeing this in production? The API handles BR-38 automatically. See the fix response →
Commonly Seen In
Frequently Asked Questions
Each TaxSubtotal must include the calculated TaxAmount.
Add TaxAmount to each TaxSubtotal. You can also use Invoice Navigator's automatic Fixer tool to correct this instantly.
Yes, BR-38 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-38 can be automatically corrected using Invoice Navigator's Fixer tool. Upload your invoice and the tool will identify and fix common issues, including tax subtotal tax amount required.
BR-38 is commonly seen in exports from All invoicing software. These software packages sometimes generate invoices that need adjustment to meet full compliance standards.
Related Errors
Related Content
Last updated: 27 February 2026
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