BR-S-02 Seller VAT ID missing for standard-rated VAT
An invoice with VAT needs the seller's VAT number (or tax number).
What the rule says
An Invoice that contains an Invoice line (BG-25) where the Invoiced item VAT category code (BT-151) is "Standard rated" shall contain the Seller VAT Identifier (BT-31), the Seller tax registration identifier (BT-32) and/or the Seller tax representative VAT identifier (BT-63).
The rule's official wording (CEN / KoSIT). The German XRechnung rules are published in German.
Why it happens
The invoice charges VAT at the standard rate, but the seller has no VAT ID, tax registration or tax representative.
How to fix it
Add your VAT ID (or tax number) to your company settings. If you don't charge VAT, choose the right exemption instead.
Applies to
Every EN 16931 e-invoice: XRechnung, ZUGFeRD / Factur-X, Peppol and others.
More about BR-S-02
Only a business registered for VAT may charge VAT. So when an invoice contains anything in the standard-rate category (S), the seller must show a VAT ID (BT-31), a tax registration such as the German tax number (BT-32), or a tax representative's VAT ID.
Unlike BR-CO-26, here the German tax number does count. A German seller with only a tax number passes this rule, as long as the number is written with schemeID="FC". If you're a small business under § 19 UStG and don't charge VAT, the fix is different: the lines shouldn't be in category S at all, but in E (exempt) with the § 19 note.
The fields involved
- BT-31 Seller VAT identifier
- CII
ram:SellerTradeParty/ram:SpecifiedTaxRegistration/ ram:ID schemeID="VA" - UBL
cac:AccountingSupplierParty/cac:Party/ cac:PartyTaxScheme/ cbc:CompanyID (TaxScheme VAT) - BT-32 Seller tax registration identifier (tax number)
- CII
ram:SellerTradeParty/ram:SpecifiedTaxRegistration/ ram:ID schemeID="FC" - UBL
cac:AccountingSupplierParty/cac:Party/ cac:PartyTaxScheme/ cbc:CompanyID (TaxScheme other than VAT)
Typical situations
- The VAT ID is printed in the PDF footer but wasn't entered in the company settings.
- A small business that doesn't charge VAT left the default 19 % rate on the lines.
- The VAT ID was entered in the wrong field, such as the company registration.
Example
A seller's VAT ID in CII:
<ram:SpecifiedTaxRegistration>
<ram:ID schemeID="VA">DE123456789</ram:ID>
</ram:SpecifiedTaxRegistration>