BR-O-04:Surcharge marked as not subject to VAT but seller has a VAT number
One of your document-level surcharges uses VAT category "O" (Not subject to VAT), but the seller has a VAT identification number. These contradict each other — if the surcharge is not subject to VAT, the seller should not have a VAT ID on this invoice.
Engine Classification
Present user with choice: remove seller VAT identifier (if truly not subject to VAT) or change the charge tax category (if VAT applies)
Confidence: 70% · Applied automatically in pipeline
What is BR-O-04?
BR-O-04 is a fatal validation rule defined in the EN 16931 specification. It validates the CompanyID element under Party > PartyTaxScheme 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: /Invoice/cac:AccountingSupplierParty/cac:Party/cac:PartyTaxScheme/cbc:CompanyID
Why This Error Matters
Invoice will be rejected. "Not subject to VAT" (category O) has strict rules: no VAT identifiers allowed, no other categories permitted, and exemption reason required. Non-compliance prevents validation.
BR-O-04 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-O-04
- ·Specification: EN 16931
How to Fix It
Before / After
<Invoice> <cac:AllowanceCharge>-100.00</cac:AllowanceCharge> </Invoice>
<Invoice> <cac:AllowanceCharge>100.00</cac:AllowanceCharge> </Invoice>
Technical Reference
/Invoice/cac:AccountingSupplierParty/cac:Party/cac:PartyTaxScheme/cbc:CompanyIDCommon Causes
- ·Category O charge found but seller VAT identifier present
- ·Document charge with O category conflicts with BT-31
- ·Seller VAT registration incompatible with O category charge
- ·"Not subject to VAT" charge must not have seller VAT ID
- ·Template structure incorrect for out-of-scope charges
Seeing this in production? The API handles BR-O-04 automatically. See the fix response →
See Also
Related Errors
Last updated: 27 February 2026
Handle BR-O-04 Automatically in Your Pipeline
The compliance engine auto-remediates this error with controlled safety policies and evidence pack generation.