We have attended an information meeting with the Danish Business Authorities (DBA) who shared their latest work and agenda for 2026 in relation to digital bookkeeping requirements in Denmark. In this update we are sharing the key take aways from the meeting.
The meeting primarily concerned the extension of the requirements for companies using a registered bookkeeping system. These changes may affect your invoicing and reporting processes.
Below, you will therefore find a summary of the latest updates on digital bookkeeping and e‑invoicing in Denmark, based on the DBA’s recent communication:
E-invoicing: Voluntary campaign and future default use of e‑invoicing
The DBA is now starting to launch a voluntary campaign to promote e‑invoicing. This campaign is focusing on all the companies who are using a registered bookkeeping system, which is why there is currently no update or timeline for companies not using a registered bookkeeping system.
Their expectation is that, from 1 July 2026, all entities using a registered bookkeeping system will, as a starting point, issue invoices as e‑invoices by default.
Concretely, this means that registered bookkeeping systems will be required to:
- Automatically check NemHandel when a user creates an invoice and selects a recipient; and
- If the recipient is registered for e‑invoicing, the system must automatically prompt or nudge the user to issue the invoice as an e‑invoice.
E-invoicing: Automatic registration in NemHandel’s registry for users of registered bookkeeping system
In order to make the above possible, all entities using a registered bookkeeping system are expected to be automatically enrolled in NemHandel’s registry from 1 July 2026, unless they actively opt out.
In practice, this means that approximately four (4) weeks before the tentative go‑live date (1 July 2026), affected companies will receive a notification informing them that they will be automatically registered in NemHandel’s registry unless they object within the four‑week deadline. If no opt‑out is submitted within this period, the company will be registered by default and thus able to receive e‑invoices which is exchanged through NemHandel.
Please note that the timeline of 1 July 2026 is still tentative. Since the Danish Parliamentary election was announced after the information meeting, the Authorities are currently unable to publish the proposed amendments and draft executive orders, which will set out all the requirements for the suppliers of registered bookkeeping systems. Nevertheless, this is the timeline they expect to be able to follow.
What this means for you: If you are using a registered bookkeeping system, we suggest taking the decision of whether you will enjoy the benefits of e-invoicing, or whether you would like to opt out.
If you are a user of a non-registered bookkeeping system, there is no news affecting your business in relation to e-invoicing, except if you choose to register in the NemHandel registery or already have a registration in the NemHandel registry. In this case, you can expect to receive more electronic invoices in the near future.
E-invoicing: Format requirements and planned transition to Peppol PINT
As the rules stand today, the Danish Bookkeeping Act requires that companies are able to process e‑invoices in both OIOUBL and Peppol BIS formats. As part of NemHandel’s new documentation strategy, The Danish Tax Authorities (DTA) plans to transition to Peppol’s new architecture, Peppol PINT, in the course of 2028, with full implementation expected to be completed by mid-2029.
Consequently, OIOUBL is expected to be phased‑out, and the Danish Bookkeeping Act will be be updated accordingly so that, going forward, only one format will apply. As the DBA is awaiting for the publication of the final version of Peppol PINT, the timeline remains tentative. Unfortunately, no indication has been given as to when e‑invoicing will become mandatory.
The DBA has now presented its documentation strategy, under which it will transition to Peppol as the primary framework. The next step will be to review its infrastructure strategy, i.e. how electronic documents – including invoices – must be exchanged in practice. We will of course keep you informed as soon as we have any further information in this regard.
What this means for you: For now, there is no change. However, in the future, you can look forward to being able to send, receive and store e-invoices in the same format, regardless of whether the transaction is domestic in Denmark or cross‑border.
SAF-T: The new version 2.0 is now published
You may also be aware that the updated SAF‑T 2.0 standard was published in mid-February. For entities using a registered bookkeeping system, this implies a requirement to map their own chart of accounts and VAT codes to the standard chart of accounts (“Standardkontoplanen”). and VAT codes published by the DBA
From 1 January 2027, it is expected (although the date remains tentative and the legislation has not yet been drafted or published) that companies with a registered bookkeeping system must be able to generate a complete SAF‑T file - including transaction‑level data - based on the new standard 2.0. For entities not using a registered bookkeeping system, the publication of SAF‑T 2.0 does not in itself introduce any changes; for these companies, the only requirement remains the ability to produce a SAF‑T file containing header information based on the existing SAF‑T 1.0 standard.
Our recommendations
Although a number of important details are still pending, and the new updates mainly focus on companies using a registered bookkeeping system, we expect that once the legislation on the future developments has been drafted and approved (currently planned for late 2026 and 2027), there will only be a relatively short implementation period before the rules take effect for both registered bookkeeping systems and non-registered bookkeeping systems.
Based on our experience from other countries (including recently in Poland and Belgium), we recommend that companies begin preparing for the upcoming requirements even if they are not using a registered bookkeeping system. The tentative timelines published so far leave very limited room for implementation on the company side. We therefore advise initiating this work as early as possible, including:
- Assessing your current invoicing and bookkeeping setup, to ensure your company is fully ready for e-invoicing.
- Beginning the mapping exercise of the chart of accounts and VAT codes, including making sure that transactions are captured with the correct VAT treatment.
Even if you are not yet formally required to use a registered bookkeeping system, your auditor may, over time, view failure to adapt to the new framework as gross negligence. This could result in a remark for your annual financial statements.
Contact us
If you need advice or guidance on how this new framework agreement applies to you - feel free to reach out to us.
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