Denmark Completes the Bookkeeping Act Phase-In and Moves to Default NemHandel E-Invoicing Registration, with a Consultation Open Until August 17, 2026
On July 1, 2026, the final phase-in stage of Denmark’s 2022 Bookkeeping Act (Bogføringsloven) took effect, and the Danish Business Authority (Erhvervsstyrelsen) began automatically enrolling businesses that use registered digital bookkeeping systems in NemHandel, Denmark’s Peppol-based e-invoicing infrastructure, on an opt-out basis.
In parallel, the authority is consulting — with responses due by August 17, 2026 — on requiring providers of compliant bookkeeping software to register their business customers to receive e-invoices via NemHandel by default.
Background
Denmark has operated e-invoicing for B2G transactions through NemHandel since 2005, and the network — a four-corner model aligned with Peppol — has increasingly become the de facto channel for B2B invoicing.
The 2022 Bookkeeping Act digitalizes bookkeeping in stages: companies were progressively required to adopt registered or approved digital bookkeeping systems, with small Class A enterprises (turnover above DKK 300,000) in scope from January 1, 2026 for registered systems and from July 1, 2026 where they use custom-built (in-house) systems.
With this last stage, the phase-in of the Act is complete. Denmark has also announced its longer-term roadmap: transition from the national OIOUBL format to the Peppol PINT-based "NemHandel BIS 4" specification toward 2028–2029, and SAF-T 2.0 file generation capability for registered bookkeeping systems from January 1, 2027.
The Change
Two related measures now push e-invoicing toward becoming the default for Danish businesses:
- Default NemHandel enrollment — from July 1, 2026, entities using registered digital bookkeeping systems are automatically registered in the NemHandel registry (NHR) so they can receive structured e-invoices, following advance notification approximately four weeks before registration and with an opt-out window.
- Consultation on default registration by software providers — the Danish Business Authority is consulting on executive-order changes that would oblige providers of registered bookkeeping software to enroll their business customers to receive e-invoices via NemHandel unless the customer actively opts out. The consultation runs until August 17, 2026.
Denmark thus follows an "opt-out" adoption model: rather than legislating a hard B2B mandate, it makes e-invoicing capability the default state of every business running compliant software, in combination with the Bookkeeping Act’s requirement that registered systems must support sending and receiving e-invoices.
Scope
The measures cover businesses subject to the Danish Bookkeeping Act that use registered or approved digital bookkeeping systems, as well as the software providers that operate those systems. Foreign-owned Danish entities running local bookkeeping software are equally in scope; group ERP systems (such as SAP) used as in-house bookkeeping systems fall under the digital bookkeeping requirements applicable from July 1, 2026.
Timeline
- January 1, 2026 — small Class A enterprises (turnover above DKK 300,000) must keep digital records in a registered bookkeeping system.
- July 1, 2026 — the requirement extends to businesses using non-registered (custom/in-house) systems; default NemHandel registration of businesses on registered systems begins.
- August 17, 2026 — deadline for responses to the consultation on default e-invoice registration by software providers.
- January 1, 2027 — registered bookkeeping systems must be able to generate SAF-T 2.0 files.
- 2028–2029 — announced migration from OIOUBL to the Peppol PINT-based NemHandel BIS 4 specification, with OIOUBL phase-out by mid-2029.
Businesses Affected
All Danish-registered businesses within the Bookkeeping Act’s scope are affected, from micro-enterprises to Danish subsidiaries of multinationals. Companies running SAP as an in-house bookkeeping system should note that the digital bookkeeping requirements now apply to them and that SAF-T 2.0 capability becomes relevant from 2027. Non-compliance with the Bookkeeping Act can attract fines of up to DKK 1.5 million.
Required Actions
- Verify whether your Danish entities have been (or will be) auto-enrolled in the NemHandel registry, and make a deliberate decision whether to remain registered — receiving e-invoices by default is generally advantageous.
- Confirm that your bookkeeping system setup (registered system or in-house ERP such as SAP) meets the digital bookkeeping requirements in force since July 1, 2026.
- Software providers and in-house system owners should assess the consultation proposal and, where relevant, respond before August 17, 2026.
- Plan for SAF-T 2.0 file generation from January 1, 2027 and for the OIOUBL-to-Peppol PINT migration in AP/AR integrations.
Practical Implications
Default registration means Danish trading partners will increasingly expect to send and receive structured e-invoices through NemHandel/Peppol, even without a formal B2B mandate.
Accounts payable departments should prepare for a rising share of inbound structured invoices, and billing teams should treat Peppol delivery as the primary channel for Danish customers. For multinationals, Denmark’s opt-out model is a reminder that e-invoicing readiness can become commercially unavoidable before it becomes legally mandatory.
Expected Next Steps
After the consultation closes on August 17, 2026, the Danish Business Authority is expected to finalize the executive orders implementing default registration by software providers. Businesses should also monitor the previously announced transition to a single Peppol-based e-invoice specification (NemHandel BIS 4) and the SAF-T 2.0 requirements taking effect in January 2027, both of which will shape system requirements for 2027–2029.
How Can KGT Support You?
KGT supports multinationals operating SAP in Denmark with SAP-integrated e-invoicing add-ons for Peppol/NemHandel invoice exchange and with SAP Document and Reporting Compliance (DRC) implementations covering Danish e-invoicing and SAF-T obligations. We can assess your Danish entities’ readiness for default NemHandel registration, prepare SAP for SAF-T 2.0 generation ahead of January 2027, and plan the migration from OIOUBL to the Peppol PINT-based specification.
Official Sources
- NemHandel — official portal (Danish Business Authority)
- KPMG Denmark — News regarding digital bookkeeping requirements in Denmark (Danish Business Authority briefings)
- European Commission — eInvoicing in Denmark country factsheet
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
