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Spotlight PEPPOL BIS Billing 3.0 The EU e-invoicing mandate is here — France Sept 2026, Belgium Jan 2026, Germany 2025.

BR-O (Not subject to VAT rules)

BR-O is the set of European e-invoice rules for transactions not subject to VAT.

Definition

The BR-O prefix in EN 16931 covers category O, not subject to VAT (out of scope). The transaction falls entirely outside the scope of the tax: it is not an exemption but a complete absence of VAT liability.

What the rules check

The BR-O rules are the strictest about identifiers. For a category O breakdown:

  • no VAT rate is expected (the VAT amount is zero);
  • a reason must state why the transaction is out of scope;
  • the VAT identifiers of seller and buyer must not be provided for that category, and category O generally cannot coexist with other categories on the same invoice.

Good to know

Category O covers, for example, re-billed disbursements or transactions outside the territorial or material scope of the tax. The "no VAT identifier" constraint clearly sets it apart from categories E, Z, K, G and AE, which remain within the scope of VAT.

Last updated: June 23, 2026