Denmark: Bookkeeping Systems Must Enrol Their Customers for E-Invoicing by Default from 1 January 2027

KGT Country Update | 15 September 2026 | VAT, e-invoicing and SAF-T monitor

On 1 July 2026, the Danish Business Authority published for consultation a draft executive order amending the requirements for registered digital standard bookkeeping systems, under case number 2025-11688. The draft obliges system providers to enroll their customers for electronic invoicing in the Nemhandel register unless the customer actively declines, to present electronic invoicing as the default channel where the recipient is registered, and to meet a set of new identity and master data controls.

The requirements take effect on 1 January 2027, but numbers 5 and 6 of Annex 2 commence earlier, on 30 November 2026, which is the deadline for informing existing customers. The consultation closed on 17 August 2026, and no final order had been published as at 15 September 2026.

Background

The Danish Bookkeeping Act of 2022 is the first phase of the Automatic Business Reporting programme. Under it, most Danish businesses have progressively become obliged to use a digital bookkeeping system, and that phase-in is now complete. The Business Authority is using that installed base as the mechanism for the next step.

The Authority is explicit about why. It estimates that full adoption of electronic invoicing would save Danish business up to approximately DKK 9 billion annually. It observes that several EU countries have overtaken Denmark in adoption and that many others have implementation plans. Under the ViDA rules adopted in 2025, Member States must have mandatory electronic invoicing for cross-border business-to-business trade by 1 July 2030, but the Authority judges that building the legal basis and administrative systems for ViDA in Denmark will take several years, during which Danish business would forgo the available savings unless voluntary adoption is promoted in the meantime.

The chosen approach is therefore deliberately not a mandate. Denmark is not making electronic invoicing compulsory. It is making it the default, by placing obligations on the software providers rather than on the invoicing businesses.

The Legislative Change

This is a draft executive order amending an existing executive order, made under the Bookkeeping Act. It is a change in the conditions a bookkeeping system must satisfy to remain registered, not a change in any business’s VAT or invoicing obligations. Its force comes from the fact that a system which does not meet the requirements cannot be a registered digital standard bookkeeping system, and most Danish businesses are obliged to use one.

It is worth being precise about what the draft does not do, because commentary has overstated it. It does not impose a business-to-business electronic invoicing mandate.

It does not change the document standards supported in Nemhandel: neither OIOUBL nor Peppol BIS is mentioned anywhere in the consultation package, and the text does not support the claim that this instrument moves Denmark to a single Nemhandel BIS standard. And it does not oblige any business to send an electronic invoice. Sending remains voluntary throughout.

The Three Changes

Default enrolment in the Nemhandel register. Under the current rules, a registered system must support a business choosing to enrol for electronic invoicing. Under the draft, the provider must enrol the businesses that use the system for their bookkeeping unless they actively decline. Enrolled businesses may still deregister at any time. Enrolment carries three consequences that the Authority states expressly: a recipient may not refuse an electronic invoice on the ground of its format alone; a recipient may not treat electronic invoice senders worse than other senders on the ground of format alone; and the customer may at any time ask their provider to be removed from the register.

Prioritized presentation of the electronic invoice. At every invoicing event, the system must automatically check whether the recipient is registered in Nemhandel and, if so, propose sending as an electronic invoice as the default option. The Authority is clear that this does not compel the sender to use that channel; the choice remains with the customers.

Supplementary security requirements. The provider must confirm the identity of every business whose bookkeeping is in the system, whether the business does its own bookkeeping or uses a bookkeeping firm, and the identity of every user with posting rights. Confirmation must be by MitID by default. Every electronic business document sent from the system must carry master data about the sending business. The CVR number, name and address must be taken directly from the Central Business Register and must not be editable by the user, although the user may choose which of the business's production units appears. Supplementary master data such as payment details and any SE, EAN or GLN number may only be added or changed where the user simultaneously confirms their identity. All bookkeeping material must be uniquely attributable to the business it concerns and searchable by that business’s master data. And the user must not be able to delete bookkeeping material held in the system.

Timeline

• 1 July 2026 draft order published for consultation by the Business Authority, case number 2025-11688.
• 17 August 2026 consultation deadline.
• In early September 2026, the Authority stated it expected to issue the order by publication in the Danish Law Gazette. No final order had been published as at 15 September 2026.
• 30 November 2026, Annex 2, numbers 5 and 6, enter into force. Last date for informing existing customers about enrolment for electronic invoicing in Nemhandel.
• After 30 November 2026, new customers must be informed when they are taken on and enrolled unless they opt out within four weeks of being set up in the system.
• 1 January 2027, the requirements take effect; existing customers are enrolled in Nemhandel unless they have actively opted out.

Businesses Affected

Two populations, with very different exposure. The first is the providers of registered bookkeeping systems. At the time of the Authority's cost measurement in spring 2026, there were 97 registered standard systems from 75 different providers.

The Authority estimates transition costs of approximately DKK 55 million and ongoing annual administrative costs of approximately DKK 14.6 million from 2027. It notes that transition costs would be higher if the MitID identity confirmation requirement were introduced later rather than now, since providers must adjust their systems for the other measures in any event.

The second is Danish businesses using those systems. The Authority estimates that approximately 125,000 additional businesses will be registered as recipients of electronic invoices, on top of the approximately 70,000 already registered, meaning that roughly half of all businesses subject to the digital bookkeeping requirement will be enrolled for electronic invoicing after 1 January 2027.

It is expected that about half of those businesses' invoices will become electronic after a transition period, realizing around 20 percent of the DKK 9 billion annual saving, approximately DKK 1.8 billion per year.

For a multinational, the practical significance is on the receiving side. If a Danish counterparty is enrolled in Nemhandel, that counterparty cannot refuse an electronic invoice because of its format, and cannot disadvantage a sender who uses one.

The addressable population of Danish customers reachable electronically roughly doubles in a single step on 1 January 2027.

Required Actions

• If the group uses a Danish-registered bookkeeping system for any entity, expect to be enrolled in Nemhandel by default from 1 January 2027 and decide deliberately whether that is wanted. Enrolment is the default, not the choice.
• Watch for the provider notification, which must be sent by 30 November 2026 for existing customers. That notification is the practical trigger for the opt-out decision, and it is easy for a local finance contact to receive it and not escalate it.
• The Business Authority is issuing guidance text that providers may use for this notification, so expect the wording to be broadly consistent across providers. Do not treat it as marketing material.
• The Authority recommends that customers own the endpoint identifiers registered in Nemhandel rather than using a GLN or EAN number owned by the provider, so that registrations can be carried to a new bookkeeping system later. Confirm who owns the endpoint identifiers for each Danish entity. This is a portability question with real switching costs attached.
• On the outbound side, review whether Danish customers are reachable through Nemhandel and plan for a materially larger reachable population from January 2027.
• Note the new prohibition on users deleting bookkeeping material, and the requirement that master data be drawn from the Central Business Register and be non-editable. Where local processes rely on adjusting name or address data on outgoing documents, those processes will stop working.
• Confirm that MitID-based identity confirmation is in place for every user with posting rights in a Danish system, including external bookkeeping firms.

Practical Implications

The Danish approach is worth understanding on its own terms because it is a genuine third way. Most European jurisdictions are choosing between a clearance mandate and waiting for ViDA. Denmark is doing neither: it is regulating the software rather than the taxpayer, and using default enrolment to shift behavior without imposing an obligation to invoice electronically.

The Authority's own reasoning is that a gradual transition materially reduces the adjustment burden for both businesses and providers, drawing on the experience of the digital bookkeeping rollout.

For groups operating across Europe, the implication is that Denmark should not be scoped as a mandate country, and equally should not be descoped as a country with no obligations. The obligations sit with the software, and they change what a Danish counterparty can and cannot refuse.

A group that ignores Denmark on the basis that there is no mandate will find its Danish customers enrolled and expecting electronic invoices, while a group that scopes Denmark as a clearance mandate will build something far heavier than is required.

The unresolved question is timing. The Authority was expected to issue the order in early September 2026, and it had not appeared by 15 September. The 30 November 2026 notification deadline is fixed in the draft, and the gap between issuance and that deadline is narrowing. Providers have a compressed window, and the notification obligation is the first thing that bites.

Expected Next Steps

The final executive order is awaited and should be published in the Danish Law Gazette. The Business Authority has also announced an information and communication campaign aimed at the users of registered bookkeeping systems, and has published a detailed reading guide for providers explaining how the new requirements are to be understood and implemented.

Separately, the Authority is presenting an infrastructure strategy for the future of Nemhandel, and has flagged forthcoming voluntary green data fields in the electronic invoice. KGT will report the final order when it is issued.

How Can KGT Support You?

KGT delivers SAP-integrated electronic invoicing and statutory reporting. For Denmark we assess which group entities are exposed through a registered bookkeeping system, advise on the enrolment and opt-out decision, and confirm endpoint identifier ownership so that registrations remain portable. On the outbound side we implement Nemhandel and Peppol delivery from SAP billing data so that the larger reachable Danish population from January 2027 can be served without manual routing.

Because the Danish requirements attach to master data integrity and identity controls rather than to a clearance interface, the work is largely about SAP master data governance and document output rather than about a new reporting channel. We scope it that way. For clients on SAP Document and Reporting Compliance, we support country activation and testing, and we advise where an add-on is the better fit.

This country update is provided for general information only and does not constitute tax, legal or professional advice.