Skip to main content

Denmark: Executive Order 811/2026 on Registered Bookkeeping Systems Sets 1 March 2027 for Providers to Request MitID Validation Ahead of Default E-Invoicing Enrolment

KGT Country Update | 5 October 2026 | VAT, e-invoicing and SAF-T monitor

On 28 September 2026, the Danish Business Authority (Erhvervsstyrelsen) announced that the new executive order on requirements for registered bookkeeping systems, BEK no. 811 of 22 September 2026, has been issued.

According to the Authority, providers of registered bookkeeping systems must by 1 March 2027 ask their customers to validate their company using MitID, after which customers are automatically enrolled to receive e-invoices unless they actively decline.

This replaces the 1 January 2027 date that appeared in the draft order published for consultation on 2 July 2026 and covered in our update of 15 September 2026.

Background

The Bookkeeping Act of 2022 obliges most Danish businesses to use a digital bookkeeping system, and that phase-in is complete. The Authority is using this installed base to promote e-invoicing without a mandate: the obligations fall on the system providers, not on the invoicing businesses.

The Authority puts potential annual savings for Danish businesses at up to DKK 9 billion and states that around 350,000 current users are affected by the automatic enrollment.

The Legislative Change

This is a binding executive order, now issued, and it supersedes the draft. It is made under the Bookkeeping Act and changes the conditions that a bookkeeping system must satisfy to stay registered. It does not impose a B2B e-invoicing mandate on businesses.

The Authority stresses that enrollment does not limit a business to sending and receiving e-invoices: other formats remain available, and a business that does not want e-invoicing must decline when its provider notifies it.

What is confirmed from the Authority's announcement is: the order number and issue date, the 1 March 2027 date for providers to request MitID validation, automatic enrollment following validation unless the customer opts out, the information duty towards customers, and the introduction of enhanced security measures.

The legal text on retsinformation.dk is rendered by JavaScript and could not be read, so the article-level wording and the commencement dates of the remaining requirements in the order (including the draft's separate 30 November 2026 date for notifying existing customers) are provisional until the text is obtained.

Scope

The order applies to providers of registered bookkeeping systems (97 standard systems from 75 providers at the Authority's spring 2026 measurement) and, through them, to Danish businesses whose bookkeeping is in those systems, whether they keep their own books or use a bookkeeping firm. It concerns enrollment in the Nemhandel register and the identity and security controls around it.

Timeline

  • 2 July 2026: draft order published for consultation (deadline 17 August 2026).

  • 22 September 2026: BEK no. 811 issued.

  • 28 September 2026: Business Authority announcement.

  • 1 March 2027: providers must have requested MitID validation from customers; automatic enrolment follows validation unless the customer opts out.

  • Provisional: commencement of the other requirements, to be confirmed against the order text.

Businesses Affected

Bookkeeping system providers carry the compliance burden. Danish group companies and subsidiaries of multinationals that use a registered system will be asked to validate with MitID and will be enrolled in Nemhandel unless they decline, which means they should expect to receive e-invoices from suppliers that use the default channel.

Required Actions

  • Identify which Danish entities use a registered bookkeeping system and who will receive the provider's MitID validation request.

  • Decide per entity whether to accept enrollment or opt out, and align this with how inbound e-invoices will be processed (ERP, AP workflows, Peppol or OIOUBL).

  • Confirm whether an entity that is also an SAP user has a Nemhandel endpoint and that it is correctly maintained.

  • Providers: plan system changes against the 1 March 2027 date and read the full order text.

Practical Implications

The date moved from 1 January 2027 to 1 March 2027 for the validation step, but the direction is unchanged: enrolment becomes the default. Treasury and accounts payable teams should anticipate a rise in structured inbound invoices in the first half of 2027, and should not assume a supplier's invoice can be refused for its format.

Expected Next Steps

We will review the order text once obtained and confirm the commencement dates of the remaining provisions. The Authority's wider timeline for a single Peppol specification (2029) is unchanged by this announcement as far as we have confirmed.

How Can KGT Support You?

KGT's SAP-integrated e-invoicing add-ons and SAP DRC services support inbound and outbound e-invoicing via Peppol and Nemhandel for Danish entities. We can help assess whether to accept default enrollment and prepare SAP for inbound structured invoices.

This update is general information on a regulatory development and does not constitute tax or legal advice. Please consult your tax adviser before acting.

Country update for Denmark
05 October 2026
Denmark
Stay informed about the latest indirect tax developments in Denmark, including regulatory changes, compliance requirements, and indirect tax guidance affecting businesses operating locally and cross-border. This page provides a structured overview of country-specific updates, such as new legislation, reporting obligations, digital tax initiatives, and implementation timelines.
These insights help tax, finance, and compliance professionals anticipate regulatory changes, adjust processes and systems, and maintain compliant operations in Denmark.