As per the CDR standard, the value for
state in the CommonSimpleAddress schema is mandatory and can be 'Free text if the country is not Australia'. Internationally, there are many countries in the world that do not have states as such. Considering this, can the data holder (DH) pass an empty string for countries other than Australia where the value of
state is not known or cannot be determined?
Yes. See Implementation Guide, Representing addresses.