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Denmark Advances Digital Requirements Under the Bookkeeping Act: Key Changes Ahead for Businesses

The implementation of the primary digital requirements outlined in the Danish Bookkeeping Act is currently in progress.

A significant phase of this initiative is set to take place in January 2026, impacting private businesses with a turnover exceeding DKK 300,000.

As stipulated by the 2022 Danish Bookkeeping Act, Danish-resident businesses are required to adhere to several key obligations:

  1. Recording and Storing Accounting Records: Businesses must use approved accounting or ERP systems to record and store their financial data.
  2. Structured E-Invoicing: Companies are required to facilitate the sending and receiving of structured e-invoices.
  3. SAF-T Reporting: Businesses must support Danish SAF-T reporting, based on the OECD model, which will be required upon demand by the tax authorities.

The phased implementation of these requirements has already commenced and is scheduled as follows:

  • July 1, 2024: Medium and large taxpayers that have existing annual reporting obligations to the Erhvervsstyrelsen will need to comply with the new requirements.
  • January 2025: This obligation will extend to medium and large companies utilizing self-developed digital bookkeeping systems that lack certified accounting systems.
  • These businesses must:
    • Maintain digital bookkeeping.
    • Be capable of issuing and receiving e-invoices.
    • Produce SAF-T format data when requested by the tax authority.
  • January 2026: All other private businesses with a turnover exceeding DKK 300,000 will need to meet these requirements, with a deadline of July 2026 set for in-house developed accounting systems.

Foreign entities will only be subject to the provisions of this act if they maintain a permanent establishment in Denmark and have annual revenues exceeding DKK 300,000. Regardless of their status under the act, all taxpayers must remain compliant with Danish VAT legislation where applicable, including adherence to Danish invoicing requirements and maintaining VAT bookkeeping documentation for VAT returns.

Denmark has mandated e-invoicing for B2G (business-to-government) transactions since 2005, utilizing the PEPPOL BIS 3.0 standard along with its own OIOUBL format via the NemHande portal. A new version of the OIOUBL format, version 3, was initially scheduled for introduction on April 10, 2025, but has been postponed to October 2025. This updated version will feature mandatory invoice message responses and will align with the European e-invoicing standard (EN 16931).

As these changes are rolled out, businesses must proactively prepare to adjust their systems and processes to ensure compliance with the new requirements. Adapting to these digital mandates will not only facilitate smoother operations but also enhance transparency and efficiency in financial reporting. Companies are encouraged to review their current practices, invest in the necessary technological solutions, and engage with advisors to ensure they meet these evolving regulatory expectations.

How Can KGT Support You?

KGT has created an SAP-integrated SAF-T add-on solution for Denmark, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic SAF-T files in the legal format and controls before submission. When SAP DRC launched the Danish SAF-T solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Danish SAF-T services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.

KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409