BR-O-03: VAT ID despite VAT category O on an allowance

What does BR-O-03 mean?

A document-level allowance has VAT category O (not subject to VAT, BT-95). The invoice must then contain neither the seller VAT identifier (BT-31), nor that of the seller's tax representative (BT-63), nor the buyer VAT identifier (BT-48).

Classification: Business rule error. This group covers calculation and consistency rules: details in the invoice do not add up or do not fit together.

A violation of this rule means the file does not meet the technical standard at this point. The check does not judge whether the invoice is correct in substance. The file should be corrected by the invoice issuer.

Which invoice fields are concerned?

The rule text names these EN 16931 business terms (BT) and groups (BG):

• BT-95
• BT-31
• BT-63
• BT-48

Who has to correct the error?

As a rule the invoice issuer, i.e. your supplier or its invoicing software: only the issuer can generate the e-invoice again. Do not edit the file you received; keep it and ask for a corrected e-invoice. Our knowledge article explains how to handle a faulty XRechnung overall.

Received a faulty XRechnung: what to do

E-mail to the supplier

Copy the template, add the invoice number and date, and send it to your supplier's accounts department.

Subject: Request for a corrected e-invoice (rule BR-O-03)

Dear Sir or Madam,

When we checked your e-invoice [invoice number] dated [date], the KoSIT validator reported a violation of rule BR-O-03 of EN 16931 / XRechnung:

A document-level allowance has VAT category O (not subject to VAT, BT-95). The invoice must then contain neither the seller VAT identifier (BT-31), nor that of the seller's tax representative (BT-63), nor the buyer VAT identifier (BT-48).

Please check VAT category O: if it applies, the e-invoice must not contain the VAT ID of the seller, the tax representative or the buyer; if it does not apply, use the correct VAT category.

Thank you for your support.

Kind regards

Source and date

This explanation is based on the official rule text. The message the validator reports for your file always takes precedence. As of October 2026.

EN 16931 validation artefacts 1.3.15 (CEN)