Does your bookkeeping system meet the requirements?

The new rules in the Danish Bookkeeping Act mean that from 1 January 2025, companies must use a digital bookkeeping system that can receive electronic invoices, store these and other relevant documents electronically, and support the exchange of the company's bookkeeping data via a SAF-T standard file.

Failure to comply with the digital bookkeeping requirements can result in both a fine and a qualified opinion in the annual report.

Digital bookkepping – who is responsible?

The Danish Business Authority is currently sending out letters to a large number of companies to draw their attention to the new rules in the Danish Bookkeeping Act, which will come into force on 1 January 2025..

If your company is not exempt from submitting an annual report to the Danish Business Authority, you will be required to record all transactions electronically and to store these and a number of other documents (including invoice documents) in a digital bookkeeping system.

Transactions must be recorded accurately and as soon as possible in the digital bookkeeping system.

It is also a requirement that the bookkeeping system can receive electronic invoices.  

If you use a standard digital bookkeeping system approved by the Danish Business Authority, the provider of the digital bookkeeping system is responsible for ensuring that the system meets the requirements of the Bookkeeping Act. If your digital bookkeeping system is a so-called customised system and therefore not on the list below (such as SAP), your company is responsible for ensuring that the system meets the requirements of the Bookkeeping Act.

The Danish Business Authority has published the list of approved standard digital bookkeeping systems here: Registered bookkeeping systems.

Even if you use a standardised digital bookkeeping system approved by the Danish Business Authority, you still need to be aware that in addition to transactions, a number of documents must also be stored in the digital bookkeeping system. You should also be aware that it is your company, as a user of the system, that must also be able to use the functions offered by the standardised digital bookkeeping system.

SAF-T

One of the requirements of the new Bookkeeping Act is that the bookkeeping system must support the international standard file format SAF-T. The purpose is to make it easier and safer for companies to exchange bookkeeping data (e.g. with the Danish Tax Agency) and to change bookkeeping systems.

There are (currently) no requirements for companies to submit SAF-T files to the authorities on a regular basis, but the bookkeeping system must be able to generate, import, and export a SAF-T file if requested to do so by the Danish Tax Agency, for example in connection with a VAT or tax inspection.

E-invoicing

From 1 January 2025, in addition to generating SAF-T files, companies will be required to issue and receive electronic invoices (also known as e-invoicing). These invoices must also be able to be stored and archived.

It is not yet a requirement that your company actually uses electronic invoicing, but your digital bookkeeping system must be able to handle such invoices. 

Consequences of non-compliance with the Bookkeeping Act

The Danish Business Authority has announced that it will monitor whether companies comply with the digital bookkeeping requirements. The Danish Bookkeeping Act therefore also contains provisions that companies can be penalised with a fine (up to DKK 1.5 million) for violating the Act's requirements for digital bookkeeping.  

Similarly, auditors are aware of the need to comply with the requirements and will therefore also question your bookkeeping system. If it does not meet the requirements, you risk the auditor issuing a qualified opinion in the annual report. 

What actions should you take?

At KPMG Acor Tax, regardless of whether your bookkeeping system is on the Danish Business Authority's list of approved standard bookkeeping systems, we recommend that you test whether your system can generate electronic invoices (also in the Danish standard OIOUBL and the EU standard Peppol BIS), and whether the system can receive and store such invoices correctly.

In addition, we strongly recommend that you also test whether your system can generate a SAF-T file. As mentioned above, the bookkeeping system must be able to generate, import, and export an SAF-T file when requested to do so by the Danish Tax Agency, e.g. in connection with a VAT or tax inspection from 1 January 2025. We therefore recommend that you create a test file and then take a closer look at the information contained in the file. In this way, you can ensure that the SAF-T file contains the correct and necessary information and that you are ready when the Tax Agency announces its visit.

Contact us

If you need advice and guidance on creating SAF-T files or preparing for e-invoicing, feel free to reach out to us.

We are happy to arrange a no-obligation meeting to discuss how you should approach the new rules.