BR-CO – Conditions and calculations
BR-CO-18: no VAT breakdown (BG-23) in the invoice
ErrorEN 16931 business rule (CEN)
Official message
[BR-CO-18]-An Invoice shall at least have one VAT breakdown group (BG-23).Source: CEN EN 16931, version 1.3.16
How to fix it
Create under cac:TaxTotal at least one cac:TaxSubtotal per VAT category, with taxable amount, tax amount, category code and rate; for an exemption with category E, rate 0, amount 0 and an exemption reason. In CII the counterpart is ram:ApplicableTradeTax.
<cac:TaxTotal>
<cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
</cac:TaxTotal><cac:TaxTotal>
<cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
<cac:TaxSubtotal>
<cbc:TaxableAmount currencyID="EUR">1000.00</cbc:TaxableAmount>
<cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
<cac:TaxCategory>
<cbc:ID>E</cbc:ID>
<cbc:Percent>0</cbc:Percent>
<cbc:TaxExemptionReason>Exempt under § 19 UStG</cbc:TaxExemptionReason>
<cac:TaxScheme><cbc:ID>VAT</cbc:ID></cac:TaxScheme>
</cac:TaxCategory>
</cac:TaxSubtotal>
</cac:TaxTotal>What the message means
Your invoice lacks the VAT breakdown, the group in which the taxable amount, the rate and the tax amount stand per VAT category. The norm requires at least one such group in every invoice, even when no tax is due: then it holds the category of the exemption with an amount of zero. Without the breakdown the recipient can neither check nor book the tax, and an invoice without tax details would be incomplete for VAT purposes too.
Common causes
- For exempt invoices the software writes no breakdown because there is no tax amount.
- The tax details stand only in the lines, not at invoice level.
- A small-business mode leaves the tax group out entirely.
Frequently asked
Do I need a breakdown as a small business exempt from VAT?
Yes. It holds the category E with rate 0, tax amount 0 and the reason for the exemption; that is how the recipient knows why no tax is shown.
How many breakdowns does an invoice with 7 and 19 percent need?
Two, one per rate. Every combination of category and rate that occurs in the lines gets its own breakdown.
Fields concerned
- BG-23
- BT-116
- BT-117
- BT-118
Related rules
- BR-O-14
- BR-O-13
- BR-O-12
Check your invoice
The EN 16931 validator reports this rule with the line number and location – right in your browser, without upload.
Technical details
- UBL · Context (XPath)
/ubl:Invoice | /cn:CreditNote- UBL · Schematron test
exists(cac:TaxTotal/cac:TaxSubtotal)- CII · Context (XPath)
//ram:IncludedSupplyChainTradeLineItem- CII · Schematron test
//rsm:SupplyChainTradeTransaction/ram:ApplicableHeaderTradeSettlement/ram:ApplicableTradeTax
Explanation written on 14 September 2026