This change affects entities that are not established in Denmark, such as those solely registered for VAT in Denmark.
In our recent newsletter, which can be found here, we provided an overview of the new digital bookkeeping requirements. These changes mandate the requirement for Danish established companies to use digital bookkeeping systems capable of issuing, receiving and storing electronic invoices (E-invoices), and supporting data exchange via SAF-T standard files. Please be aware that at this time there is no obligation to issue E-invoices, as the requirements pertain solely to the capability to do so.
The recent update published by the Danish Business Authorities extends these requirements to VAT-registered entities with turnovers exceeding the threshold of DKK 300.000 for two consecutive years, effective from January 2026. Consequently, companies solely holding a VAT registration in Denmark must also adhere to these Danish Digital bookkeeping requirements.
More information about the ViDA reform as published by the EC is available here.
The criterion of the turnover exceeding DKK 300,000 for two consecutive years refers to the actual net turnover, i.e. not budgeted net turnover or net turnover converted to 12 months. Therefore, if your company’s turnover exceeds DKK 300,000 from the activity in Denmark in both 2024 and 2025, you will be subject to the digital bookkeeping requirements starting from 1 January 2026.
New entities registered in Denmark after 1 January 2026 will be subject to the requirement once their net turnover exceeds DKK 300,000 for two consecutive fiscal years, based on actual net turnover and not expected turnover.
At KPMG Acor Tax, we advise you to conduct a thorough test of your bookkeeping system to ensure its capability to generate and receive the required electronic invoices (in the format OIOUBL and Peppol BIS). Additionally, we suggest testing your system's ability to generate SAF-T files. It is important to note that currently the requirement in relation to generating the SAF-T files is limited to extracting only header information. Further, there is as for now no requirement to provide the SAF-T files to the Danish Public Authorities.
If you need advice or guidance as to whether these new requirements apply to you – feel free to reach out to us.
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