A new Annotation ABIE and corresponding Annotation ASBIEs on Invoice and CreditNote are required to address the EN 16931 requirement for 0..n business terms with subject codes. While this requirement is phrased as "invoice notes" in EN 16931, we've reviewed and discovered that the requirement is actually for structured document annotations providing contextual information or processing instructions rather than an "unstructured" Note element as understood in UBL.