BR-20The Seller tax representative postal address (BG-12) shall contain a Tax representative country code (BT-69), if the Seller (BG-4) has a Seller tax representative party (BG-11).
Official rule text
Where the seller has a tax representative, that representative's address must carry a country code (BT-69) — the same requirement as BR-09 and BR-11, for a third party.
- Severity
- Error
- Applies to
- CII, UBL
- Rule set
- v2026-08-31
- Checked on
Written and checked against the official KoSIT rule set by Dmytro Yalanskyi, NormAPI.
Why does BR-20 happen?
As with the other two addresses: the country sits as free text on the last address line, or is not carried at all because it goes without saying.
What the validator checks
The expression the official KoSIT rule set evaluates — not paraphrased, but read from the Schematron file it ships. UBL and CII address different document trees, so the same rule reads differently in each.
- UBL
normalize-space(cac:Country/cbc:IdentificationCode) != ''- CII
normalize-space(ram:PostalTradeAddress/ram:CountryID) != ''
Source: rule set v2026-08-31
How do you fix BR-20?
Set the ISO 3166-1 code in cac:TaxRepresentativeParty/cac:PostalAddress/cac:Country/cbc:IdentificationCode in UBL, or the representative's ram:PostalTradeAddress/ram:CountryID in CII. If you have no tax representative at all, the country code is the wrong answer: delete the BG-11 group and BR-18, BR-19 and BR-20 fall away together.
In the XML
A UBL fragment. The CII path is named above — same change, different element names.
<cac:TaxRepresentativeParty>
<cac:PostalAddress>
<cbc:CityName>Berlin</cbc:CityName>
<cbc:PostalZone>10115</cbc:PostalZone>
</cac:PostalAddress>
</cac:TaxRepresentativeParty><cac:TaxRepresentativeParty>
<cac:PostalAddress>
<cbc:CityName>Berlin</cbc:CityName>
<cbc:PostalZone>10115</cbc:PostalZone>
<cac:Country>
<cbc:IdentificationCode>DE</cbc:IdentificationCode>
</cac:Country>
</cac:PostalAddress>
</cac:TaxRepresentativeParty>Related rules
- The core EN 16931 rules — which fields an invoice has to carry
- BR-19 — The Seller tax representative postal address (BG-12) shall be provided in the Invoice, if the Seller (BG-4) has a Seller tax representative party (BG-11).
- BR-21 — Each Invoice line (BG-25) shall have an Invoice line identifier (BT-126).
NormAPI provides technical validation, not tax or legal advice.