Version 2 of the Bookkeeping System Guidance (19 October 2026) Confirms SAF-T 2.1 from 1 January 2027 and Staggers the MitID and Master Data Requirements to March 2027 and January 2028

KGT Country Update | 3 November 2026 | VAT, e-invoicing and SAF-T monitor

On 19 October 2026, the Danish Business Authority (Erhvervsstyrelsen) published version 2 of its combined guidance for providers of digital standard bookkeeping systems. Version 1 was dated 5 October 2026 and announced on 9 October. The guidance consolidates the requirements for registered systems after BEK no. 811 of 22 September 2026 and sets three dates providers must plan against: SAF-T version 2.1 and an expanded SAF-T content from 1 January 2027, automatic Nemhandel enrolment and a recipient check from 1 March 2027, and locked master data with continuous CVR validation from 1 January 2028.

Background

Denmark is not imposing a B2B e-invoicing mandate on businesses. It regulates the bookkeeping software instead: a system that does not meet the requirements cannot stay registered. KGT reported on the draft order (15 September 2026) and on BEK 811/2026 (5 October 2026), which fixed 1 March 2027 for providers to request MitID validation. This update adds the Authority’s detailed reading of those rules and a SAF-T and format roadmap, and it moves one element to 2028.

The Legislative Change

The guidance is not itself legislation. It is the Authority’s guidance document interpreting the requirements order (BEK 97/2023, as amended by BEK 811/2026) made under the Bookkeeping Act (Act 700/2022). It is binding in practice because registration of a system depends on meeting the order, and the guidance states how the Authority reads each requirement. Version 2 changed one point: chapter 7.9 now states that the requirements to lock the fields containing the end customer’s master data and to validate end customer master data continuously against CVR apply only from 1 January 2028.

Scope

The guidance applies to providers with a registered digital standard bookkeeping system and to providers who want to register one. Points confirmed on the Authority’s page:

• SAF-T (section 3.5 and chapter 7.9): today’s requirement covers only the end customer’s master data. From 1 January 2027 the file must also contain transaction-level data, more detailed master data (including debtors and creditors) and VAT information per transaction, and systems must support SAF-T version 2.1. The Authority’s standard chart of accounts page (updated 8 September 2026) likewise refers to version 2.1 from 1 January 2027, and to version 1.0, a header-only file, for non-registered systems. Earlier commentary, and our own earlier shorthand, referred to “SAF-T 2.0”; providers should work to 2.1 and confirm the schema on the Authority’s repository.
• E-invoicing from 1 March 2027: (1) when validating master data with MitID, providers must tell the customer that it will be automatically enrolled in the Nemhandel register; (2) when an end customer invoices another, the system must check whether the recipient is in the register and, if so, show clearly that e-invoicing can be used. Automatic enrolment: all end customers using the system are enrolled, after notice stating that enrolment happens after four weeks unless the customer objects. The customer can always opt out.
• From 1 January 2028: locked master data fields and continuous CVR validation (confirmed by the version 2 note); the Authority’s summary box also places CVR validation of the sender details on e-documents (CVR number, name, address) in this group.
• Formats: systems must send and receive e-invoices, credit notes and response documents in OIOUBL and Peppol BIS, to CVR, P, SE and GLN addresses with the correct scheme identifier.
• Roadmap 2028 to 2029: the next version of Danish e-business documents will be based on Peppol BIS 4; OIOUBL is to be phased out in favor of Nemhandel BIS 4. The Authority also refers to the ViDA date of 1 July 2030 for cross-border intra-EU B2B e-invoicing.
• AI-assisted booking: the Authority encourages automation but states that a user must approve purchase invoice bookings; if an AI agent books without user approval the provider becomes responsible.

Provisional: the guidance is internally inconsistent on one point. Chapter 4.1 says providers must ask all customers by 1 March 2027 to confirm their CVR number with MitID, and that changes to the locked fields must be MitID-validated from 1 January 2028. The summary box and the version 2 note place the locking and continuous validation in 2028. Our reading is that the MitID confirmation request starts on 1 March 2027 and the locking and continuous validation on 1 January 2028, but the legal text of BEK 811/2026 on retsinformation.dk, which could not be read, would settle it. Our 5 October update said the draft’s 30 November 2026 notification date was unconfirmed; the guidance does not state that date.

Timeline

• 22 September 2026: BEK 811 issued (announced 28 September).
• 5 October 2026: guidance version 1; 9 October: news item.
• 19 October 2026: guidance version 2.
• 26 November 2026: Nemhandelsforum online, on the status of the requirements order and the project for one common e-invoice including the transition to Peppol (Nemhandel announcement of 26 October).
• 1 January 2027: SAF-T 2.1 and expanded SAF-T content.
• 1 March 2027: MitID validation request, automatic enrolment with four-week notice, recipient check.
• 1 January 2028: locked master data, continuous CVR validation, CVR validation of e-document sender data.
• 2028 to 2029: transition to Peppol BIS 4 and phase-out of OIOUBL (planned).

Businesses Affected

Directly: providers of registered bookkeeping systems. Indirectly: Danish entities of multinational groups that keep their books in a registered system, which will be enrolled in Nemhandel by default, will need SAF-T 2.1 capable software from 1 January 2027, and may find their master data locked from 2028. Groups that send invoices to Danish customers should expect a growing share of those customers to be reachable electronically from March 2027.

Required Actions

• Identify which Danish entities use a registered system, and ask the provider in writing for its SAF-T 2.1 release date and test plan.
• Decide per entity whether to accept default enrolment or opt out, and confirm who owns the endpoint identifier.
• Plan the process for MitID confirmation of the CVR number, including who holds MitID authority in the entity.
• Review whether any process edits name or address on outgoing documents; from 2028 these fields are locked and sourced from CVR.
• Confirm that SAP outbound output supports OIOUBL or Peppol BIS to CVR, P, SE and GLN addresses.
• Obtain BEK 811/2026 and read the commencement provisions against the guidance.

Practical Implications

The SAF-T point is the most easily missed. The expansion to the transaction level and VAT per transaction from 1 January 2027 is a software release the provider must deliver, but the entity’s own chart of accounts mapping, VAT code mapping, and attachments must also be correct for the file to be useful. The staggering of the MitID elements gives providers and customers time, yet default enrollment is not delayed: from 1 March 2027, a Danish counterparty may be enrolled and expect structured invoices.

Expected Next Steps

The Nemhandelsforum of 26 November 2026 should clarify the status of the order and the common e-invoice project. The guidance has a change-notification service; further versions are likely. We will update this note when the BEK 811/2026 text is obtained.

How Can KGT Support You?

KGT delivers SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance (SAP DRC) services for statutory e-invoicing, e-reporting and SAF-T. For Denmark we assess entity exposure, prepare SAP for Nemhandel and Peppol delivery, and plan SAF-T data and VAT mapping so that the software provider’s SAF-T 2.1 release produces a complete file.

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