Significant changes to the previously communicated timeline for the rollout of e-invoicing.

The Danish Business Authority has just held a NemHandelsforum and, in connection with this, issued an amendment to the Regulation on Requirements, which contains the detailed requirements for providers of registered accounting systems.

The previously expected deadline for the new requirements for registered bookkeeping systems was January 1, 2027. This has now been changed to March 1, 2027.

What are the current requirements?

Businesses subject to the digital bookkeeping requirements must use a digital bookkeeping system that ensures electronic bookkeeping in a recognized format. The system must be capable of issuing, receiving, and storing electronic invoices (e-invoices) in the OIOUBL and Peppol BIS formats, as well as generating a SAF-T file in accordance with the Danish standard. At present, the SAF-T file is only required to contain header information. The timeline for expanding the SAF-T reporting requirements has not yet been published. This is expected to be clarified during 2027.What are the current requirements?

What are the upcoming e-invoicing requirements?

Through the Executive Order on Requirements, the Danish Business Authority has increased its focus on the use of e-invoicing. E-invoicing will not be made mandatory at this time, instead, the Authority is launching a voluntary campaign to promote its use. This voluntary campaign will be implemented through the Executive Order on Requirements. The new rules are now expected to take effect on March 1, 2027, and include, among other things, the following requirements for providers of registered bookkeeping systems:

• Users must be notified that they will be automatically registered in the NemHandelRegister, with the option to opt out within the following four weeks. The notice may be provided either when the user first logs in to the bookkeeping system on or after March 1, 2027, or through a separate communication. The provider must then register the user in the NemHandel Register within four weeks.
• When an invoice is created manually, it must be clear to the user when the invoice recipient is registered in the NemHandel Register, so issuing an e-invoice is presented as a clear and straightforward option.

The purpose of the Danish Business Authority’s initiative is to have more businesses register in the NemHandel Register so they can receive and send e-invoices. The Authority’s goal is to significantly increase the number of businesses registered in the NemHandel Register during 2027.

Besides the new requirements for registered bookkeeping systems, the Danish Business Authority has also announced that the current two e-invoice formats (OIOUBL and Peppol Bis) will gradually be phased out in favor of a single, common e‑invoice specification based on Peppol, the same standard already used in most EU countries. The transition to this common format is expected to begin in mid‑2028, with the existing formats fully phased out by mid‑2029. This is scheduled to take place one year before the EU’s ViDA initiative is expected to take effect, introducing mandatory B2B e‑invoicing for trade between EU Member States.

What does this mean for your business?

If your business uses a registered bookkeeping system, the provider is responsible for ensuring that the system complies with the current and upcoming requirements of the Danish Bookkeeping Act, including the requirements related to e-invoicing and registration in the NemHandel Register. As mentioned above, your business will be automatically registered in the NemHandel Register, with the option to opt out within four weeks. Once the registration has been completed, your business must be ready to receive and process e-invoices from suppliers.

If, on the other hand, your business uses a non-registered bookkeeping system, typically a customized system such as SAP or Oracle, the business itself is responsible for ensuring that the system complies with the Danish Bookkeeping Act’s digital bookkeeping requirements. Your business will therefore not be automatically registered in the NemHandel Register.

If your business is already registered in the NemHandel Register, for example because it does business with public-sector entities (B2G), you should expect to receive more e-invoices after March 1, 2027, even if you do not use a registered bookkeeping system.

In addition to the measures described above, the Danish Business Authority’s voluntary campaign calls on utility companies, among others, to send e-invoices to businesses and encourages large companies to actively request e-invoices from their suppliers. Based on discussions with both businesses and the Danish Business Authority, we expect many businesses to increase their use of e-invoicing during 2027 and impose corresponding requirements on their trading partners. The campaign may therefore quickly become a practical “must,” even though e-invoicing is not formally mandatory in Denmark. Businesses must therefore be technically and organizationally prepared to avoid disruptions in your business relationships.

Our recommendations

Regardless of whether your business uses a registered or non-registered bookkeeping system, we recommend that you:

• Check whether your business is already registered in the NemHandel Register—and whether it is operationally ready to receive, send, and process e-invoices.
• Assess whether your current system landscape supports the receipt, issuance, and storage of e-invoices in OIOUBL/Peppol BIS format.
• Develop a concrete plan for how the business will manage a growing number of e-invoices from suppliers, including processes, systems, roles, and controls.

In addition, we recommend strengthening the data quality in your bookkeeping system now so that, over time, it can support full SAF-T reporting when the requirements are expanded, including the correct setup of VAT codes and related transactions.