Digital bookkeeping requirements in Denmark

Does your bookkeeping system meet the requirements?

The new rules in the Danish Bookkeeping Act, which entered into force on 1 January 2025, mandates the use of a digital bookkeeping system capable of receiving electronic invoices, storing these and other relevant documents electronically, and supporting the exchange of the company's bookkeeping data via a SAF-T standard file.

Non-compliance with these digital bookkeeping requirements can result in fines and a qualified opinion in the annual report.

Who is subject to the bookkeeping requirements?

All registered companies in Denmark, i.e., both established companies and companies solely registered for VAT in Denmark, are in general subject to the Danish Bookkeeping Act.

Furthermore, if your company is obligated to submit an annual report to the Danish Business Authority, your company must also comply with the rules relating to digital bookkeeping stated in the Bookkeeping Act. These companies must comply with the rules once they start a new financial year after 1 January 2025.

Further, companies exempt from filing annual reports in Denmark in accordance with the Danish Financial Statements Act and who generate an annual net turnover of more than 300,000 DKK for two consecutive years, must comply with the rules regarding digital bookkeeping once they start a new financial year after 1 January 2026. This includes:

1. Financial companies (e.g. banks and Investment management companies) subject to the Danish Financial Business Act (also including any potential subsidiaries who uses a group wide bookkeeping system), and

1. Foreign companies having a fixed establishment for VAT purposes or a permanent establishment in Denmark.

It is important to emphasize that companies that has not established a fixed establishment for VAT purposes nor a permanent establishment in Denmark, e.g. solely VAT-registered companies are not yet subject to the digital bookkeeping requirements. However, they are still subject to the general requirements in the bookkeeping act. Currently, there is no deadline for when these companies will become subject to the requirements for digital bookkeeping.

Digital bookkeeping – what are the current requirements?

Companies subject to the digital bookkeeping requirements are required to use a digital bookkeeping system that ensures all bookkeeping is carried out electronically and in a recognized digital format. All transactions must be recorded promptly and accurately, with proper documentation to guarantee traceability between supporting documents, accounting entries, and financial data.

The bookkeeping system must be able to issue, receive, and store electronic invoices (E-invoices). Furthermore, the system must be capable of generating a SAF-T file.

The VAT return must be reconciled with the bookkeeping records no later than the day the VAT is reported. All data must be stored securely for at least five years, with digital access available at all times. Please note that backup copies must be kept within the EU.

If you use a standard digital bookkeeping system pre-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, Oracle etc.), 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 when using an approved standardized digital bookkeeping system, you must ensure that, in addition to transactions, various documents are stored in the system. Your company, as the system user, must be able to utilize the functions offered by the standardized 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, including header information such as general company details and information about the bookkeeping system itself. There is currently no requirement for regular submission of SAF-T files to authorities, we expect in the future, that the requirements to the SAF-T file will expand including transactional data which will be used by the Danish Tax Authorities for audit purposes, and later on replace the VAT return.

The Danish Business Authority are currently working on a version 2.0 of the Danish SAF-T file. Version 2.0 is currently under consultation at relevant parties. The 'Changelog' and 'Technical description' can also be found here: Standardkontoplan og SAF-T | erhvervsstyrelsen.dk

E-invoicing

Besides generating SAF-T files, companies are also required to be able to issue and receive electronic invoices, which must also be stored and archived in the two formats OIOUBL 2.1 or Peppol Bis. While it is not yet mandatory for your company to actively use electronic invoicing, your digital bookkeeping system must be capable of handling such invoices.

Consequences of non-compliance with the Bookkeeping Act

The Danish Business Authority has announced its intention to monitor compliance with digital bookkeeping requirements. The Danish Bookkeeping Act includes provisions for penalties, with fines up to DKK 1.5 million for violations of digital bookkeeping requirements. Auditors are also vigilant about compliance and may issue a qualified opinion in the annual report if your bookkeeping system does not meet the requirements.

What actions should you take?

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 systems 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.