You can create a UBL invoice without an ERP system: UBL is a structured XML format, and an ERP is only one way to generate it. You still need to use the version and business profile your recipient requires, validate the file against the right rules, and send it through an accepted channel. The exact legal fields, tax treatment and delivery route depend on your country, buyer and invoice type, so confirm those requirements with the recipient or relevant tax authority.
What a UBL invoice is—and what it is not
UBL (Universal Business Language) is an XML standard for business documents. A UBL Invoice is structured data intended for software to process; it is not a PDF invoice template. OASIS publishes the UBL 2.1 specification, schema resources and sample invoice documents at OASIS UBL 2.1.
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OpenPeppol’s May 2024 guide defines an e-invoice as “an invoice that is created in a structured digital data format, designed for machine-to-machine processing without the need for manual intervention.” The guide also says an e-invoice is not a PDF, digital image or spreadsheet document. A PDF may accompany a transaction, but by itself it is not the machine-readable UBL file. See the OpenPeppol guide.
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Before creating XML, ask the buyer or authority which UBL version, business profile or national customization it accepts, what identifiers it requires, and how it expects to receive the invoice. “UBL invoice” does not identify one universal set of business rules or a single delivery method.
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For example, Peppol BIS Billing 3.0 is a specific profile. The cited 2025-Q4 documentation specifies UBL Invoice 2.1 and lists profile identifiers for that release. Those identifiers are not instructions to copy blindly into every invoice: check the release and requirements applicable to your recipient in the Peppol BIS Billing 3.0 documentation.
Requirements may vary with the seller’s jurisdiction, buyer type, recipient, invoice type and sending channel. The general workflow below does not determine your tax treatment or establish a country-specific legal checklist.
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Gather transaction data before building the XML
Collect the information that the applicable profile and jurisdiction require. As a working checklist, this may include:
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- Seller and buyer details and required party identifiers.
- Invoice number and issue date, plus any other required dates.
- Line descriptions, quantities, prices and currency.
- Tax categories, rates and amounts appropriate to the transaction.
- Line totals, document totals and payment information.
- Purchase-order numbers or other references required by the recipient.
This is a planning list, not a universal list of legally mandatory fields. Verify each business term against the recipient’s actual profile and the rules for your jurisdiction.
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Create the UBL XML file
The practical alternatives are an invoicing application that generates the required UBL profile or manual authoring with an XML editor. In either case, confirm that the tool produces the right UBL version and profile, rather than merely exporting a PDF or a spreadsheet. OASIS’s UBL 2.1 specification and examples can serve as a technical reference when the recipient requires that version.
Manual XML authoring is possible, but the document must use the correct namespaces and element structure, valid code values and applicable business rules. A file can look plausible to a person and still be rejected by a receiving system.
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Validate syntax and business rules in layers
“Valid XML” is incomplete unless you say which checks it passed. An XML parser can confirm that markup is well-formed; that does not establish that the invoice conforms to the required UBL schema or business profile.
- Check well-formedness and schema conformance. Parse the XML, then validate it against the schema for the required UBL version. OASIS describes validation in phases, including structural and vocabulary checks and checks involving default code-list values.
- Run profile and business-rule validation. Apply the code lists, business rules and, where required, EN 16931 and Peppol checks for the selected profile. Peppol’s documentation describes syntax and EN 16931 validation stages; use the rules for the relevant release, not a validator configured for a different profile.
- Apply any recipient-specific or national checks. Confirm whether the buyer or authority requires additional validation beyond the general UBL or Peppol rules.
- Resolve errors before sending. Keep the validator’s output and correct reported errors, then validate the revised file again with the applicable ruleset.
A passing schema check alone does not prove that the invoice meets every profile, tax or recipient requirement. Record which validator and ruleset you used so the scope of the result is clear.
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Send the invoice through an accepted route
Creating a UBL file does not transmit it. OpenPeppol distinguishes structured invoice data from the sending and receiving mechanism. Your buyer may require a Peppol route, a portal upload, a web service or another specifically supported channel; confirm the route before sending.
Austria’s government service is one jurisdiction-specific example: it accepts UBL 2.1 through Peppol and provides invoice upload and web-service delivery options. Those options describe that service, not what every country or buyer supports. See the Austrian government guidance.
Keep the submitted file and its receipt
Retain the exact XML you submitted and any delivery, processing or acceptance response. A successful export only shows that a file was generated; it does not by itself show that the network delivered it or the recipient accepted it. Keeping both records helps distinguish those outcomes if an invoice is rejected or needs to be traced.
Check special rules before copying technical values
Profile-specific rules can affect even familiar UBL elements. For example, the cited Peppol self-billing rules page says: “A UBL invoice should not include the UBLVersionID or it should be 2.1”. That instruction is attached to the self-billing rules in question; do not treat it as a universal rule for other invoice profiles. Check the Peppol self-billing rules and the profile your recipient requires.
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