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UBL 2.5 is here: what changes for your business, and what doesn’t

A new version of the standard behind Peppol and many national e-invoice formats. E-invoices you already send stay valid.

29 August 2026Updated 2 September 20268 min read

What happened

Key Stats

12 Aug 2026

Approved as an OASIS Standard

8

New document types

101

UBL document types in total, up from 93

On 12 August 2026 the Universal Business Language, better known as UBL, was approved as an OASIS Standard at version 2.5. OASIS announced it on 26 August.

The release adds eight new document types and a long list of smaller changes. It is backward compatible with every earlier 2.x version, which means an invoice that validated last month still validates today. This article sets out what the specification contains, and checks four claims made about the release against it.

What UBL is, and what it is not

UBL is a shared vocabulary for business documents: orders, despatch advices, invoices, credit notes and close to a hundred others. It defines what each piece of information is called and where it sits, so that two systems that have never met can still read the same invoice. It has been developed since 2001 and is published by ISO as ISO/IEC 19845.

Think of it as a dictionary. A new version adds words to the dictionary. It does not decide which words you must use, and it does not decide whether you must write at all. Those decisions sit one and two layers above UBL: in the specifications built on top of it, and in the law that points at those specifications.

That layering explains why a major standards announcement can be significant without, by itself, changing what businesses are required to do. The European standard for e-invoicing, EN 16931, can be written in two technical formats, which the European Commission’s eInvoicing resources list as UBL 2.1 and UN/CEFACT CII. Peppol BIS Billing 3.0, the invoicing specification used on the Peppol network, also checks invoices against UBL 2.1. A new UBL release does not change either of them by itself.

Where a UBL version sits
Layer 3The lawMust you do this at all?

National legislation and EU rules. Who must send and receive e-invoices, from when, and what happens if they do not.

National e-invoicing mandates and EU VAT rules

Sets the obligation
points at
Layer 2The specificationWhich fields, in which version?

The profiles built on top of UBL. They pin a version, narrow the vocabulary and add their own rules.

EN 16931, Peppol BIS Billing 3.0, national profiles. Both of the first two use UBL 2.1.

Sets the fields and the version
is built on
Layer 1The vocabularyWhat is each thing called?

UBL itself. A dictionary of business documents and the fields inside them. It defines what exists, never what you must use.

UBL 2.5, approved 12 August 2026

UBL 2.5 changed this layer, and only this layer
Read from the top down. A change at layer 1 reaches you only once layer 2 adopts it and layer 3 points at the result.

How big a release is this?

"UBL 2.5 is our most significant release since UBL 2.1." Kenneth Bengtsson, Chair of the OASIS UBL Technical Committee, 26 August 2026.

Counted by document types added, the eight in 2.5 compare with 34 in 2.1 (2013), 16 in 2.2, ten in 2.3 and two in 2.4.

The OASIS announcement points to other changes: 2.5 is the first release that can mark parts of the standard for possible removal, it adds support for ISO 14000 environmental information, and it lays the foundation for JSON and other formats in future releases.

UBL 2.1, the version the European standard and Peppol BIS Billing 3.0 use, was published in November 2013. Three releases followed it, adding 28 document types between 2018 and 2024.

Document types in the UBL library

UBL 1.0

2004

8

UBL 2.0

Dec 2006

31+23 new

UBL 2.1

Nov 2013

65+34 new

UBL 2.2

Jul 2018

81+16 new

UBL 2.3

Jun 2021

91+10 new

UBL 2.4

Jun 2024

93+2 new

UBL 2.5

Aug 2026

101+8 new
Total document types in the library at each release. Counts and dates from Appendix C of the UBL 2.5 specification. EN 16931 and Peppol BIS Billing 3.0 use UBL 2.1, the release of November 2013.

What is new

The release adds eight new documents, shown below in four groups by purpose. It also changes the invoice itself, adding lines for amounts collected on behalf of a third party.

Eight new document types
Invoice status

Between supplier and buyer

  • Invoice Status Request

    Ask where a previously issued invoice has got to.

  • Invoice Status Response

    Answer, covering one invoice or many, and carrying payment details where they exist.

Proof of delivery and work

Between supplier and buyer

  • Delivery Note

    Confirm what was actually delivered, with items, quantities and shipment detail.

  • Work Report

    Record the work that was carried out.

Waste and the circular economy

Between waste senders, receivers and authorities

  • Waste Notification

    Notify the competent authorities of a planned movement of waste.

  • Waste Movement

    Travel with each consignment, and may reference the notification.

Procurement progress

From contracting authority to supplier

  • Procurement Status

    Report the progress of a procurement procedure, project or lot.

  • Procurement Status Request

    Ask a contracting authority for that progress.

None of the eight is a tax reporting document. The specification states that UBL does not provide documents for tax reporting purposes.

The changes in more detail

Invoice status. The Invoice Status Request and Invoice Status Response give businesses a standard way to ask where an invoice has got to, and to answer. The response is not limited to one invoice at a time, and it can carry payment details alongside the status: amount paid, date paid, and a transaction reference.

Delivery notes and work reports. The Delivery Note confirms what was actually delivered, with items, quantities and shipment information. The Work Report records work carried out. Invoices, credit notes and debit notes can now reference both.

Waste, and procurement progress. The remaining four documents cover waste shipments and public procurement. OASIS describes the circular economy as a major focus of the release: Waste Notification tells the competent authorities about a planned movement of waste, and Waste Movement travels with each consignment. Procurement Status and Procurement Status Request let a contracting authority report on the progress of a procurement procedure, project or lot.

Collections for someone else, which is the change to the invoice. Invoices, credit notes and debit notes can now carry separate lines for amounts collected on behalf of a third party, and documents can identify a beneficiary party: the party a transaction is ultimately intended for, even where that party is not the buyer.

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Where the new documents sit in a transaction

Taken together, the new documents cover the stages around the invoice: what was delivered, what work was done, where the invoice has got to, and whether it has been paid.

Invoices could already reference the order, the despatch advice and the receipt advice in UBL 2.0 (2006), and line by line in UBL 2.1 (2013). UBL 2.5 adds references to the Delivery Note and the Work Report, and a status request and response built for invoices.

One transaction, end to end
  1. OrderAlready in UBL

    Order, Order Response

    Invoices could already reference the order in UBL 2.0 (2006), and line by line in UBL 2.1 (2013).

  2. DeliveryNew in 2.5

    Delivery Note

    Confirms what was actually delivered: items, quantities and shipment information. The invoice can reference it.

  3. Work performedNew in 2.5

    Work Report

    Records the work carried out, from supplier to buyer. The invoice can reference it.

  4. InvoiceExtended in 2.5

    Invoice, Credit Note, Debit Note

    Can now reference the delivery note and the work report, and carry lines collected for a third party.

  5. StatusNew in 2.5

    Invoice Status Request, Invoice Status Response

    A request for the status of one or more issued invoices, and the reply.

  6. PaymentNew in 2.5

    Carried inside the Invoice Status Response

    Amount paid, date paid and a transaction reference travel back with the status.

Every link in this chain is optional. UBL describes what can be exchanged; whether any of it is required is decided by the specification and the law above it.
What's changing
A general document status message (since UBL 2.1)
A status request and response built for invoices
Despatch and receipt advices (since UBL 1.0)
A Delivery Note the invoice can reference
No Work Report document
A Work Report the invoice can reference
Payment details in a separate remittance advice
Amount and date paid returned with the invoice status

What 2.5 flags for removal, and why nothing breaks

UBL 2.5 is the first version that can mark parts of the standard as deprecated, meaning flagged for possible removal. Five document types and a handful of fields are now flagged.

A deprecated component is still valid, still fully supported by the 2.5 schemas, and documents that use it remain conformant. OASIS says its use is discouraged and that it may be removed in a future major version. UBL has not had a major version since 2.0 in 2006. The release also includes optional versions of its schemas that leave out deprecated content, which software providers can use to find deprecated items in existing documents.

What is deprecatedWhat OASIS says to use instead
Freight Invoice, a separate document type for freightThe ordinary Invoice
Attached Document, a wrapper for carrying attachmentsA specialised document envelope, such as the OASIS XHE
Enquiry and Enquiry ResponseDocument Status Request and Document Status
Order Response SimpleOrder Response without order lines
Copy indicator, the flag marking a document as a copy, on most document typesNothing. OASIS records "no consensus of real use cases for this"
Buyer reference on the Invoice, Credit Note and self-billed documentsThe new buyer assigned reference structure
Deprecated in UBL 2.5, with the replacement OASIS names in each case. Every one of these remains valid and conformant.

Four claims, and what the standard says

Four claims have been circulating since the announcement. The right-hand column sets out what the specification and the OASIS announcement say.

The claimWhat the standard says
"UBL now supports JSON"Not in this release. UBL 2.5 is defined in XML. The OASIS announcement says the release "lays the foundation for JSON and other syntax bindings in future releases", and the specification lists JSON versions of UBL only as alternative representations outside the formal standard.
"Tax authorities will use delivery notes to check VAT returns"The specification states that UBL does not provide documents for tax reporting purposes; it provides structures to support the information on which taxes are based. Where tax authorities collect data beyond the invoice, they do so under their own national rules; nothing in UBL 2.5 creates an obligation.
"Invoices will now be matched line by line to orders and deliveries"Invoices could already reference orders, despatch advices and receipt advices in UBL 2.0 (2006), and line by line in UBL 2.1 (2013). UBL 2.5 adds references to the new delivery notes and work reports. All of these references are optional, and whether any of them ever becomes required is a matter for the rules that apply to you.
"Businesses need to upgrade to UBL 2.5"2.5 is backward compatible, and a new version of a standard is not a legal requirement in itself. Any obligation to use a particular version comes from the rules that apply where a business trades.

The bottom line

UBL 2.5 is the latest version of a standard OASIS describes as the leading interchange format for business documents. It adds document types for the stages around the invoice, including an invoice status request and response, a delivery note and a work report, without invalidating any document issued under an earlier 2.x version.

UBL 2.5 does not create an obligation by itself. Obligations to use e-invoicing, and any particular UBL version, are set by governments and tax authorities.

Sources. OASIS, Universal Business Language Version 2.5, OASIS Standard of 12 August 2026, in particular Section 5 on component deprecation and Appendix C, the revision history; and the OASIS announcement of the standard’s approval, 26 August 2026. Document counts, release dates and the deprecation list are taken from Appendix C.

European Commission: the eInvoicing Building Block, for EN 16931 and its syntax bindings.

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