Briefing Document: Digital Reporting and E-invoicing in Denmark

Review of recent developments and requirements in digital bookkeeping, SAF-T reporting, and e-invoicing in Denmark.

Summary:

Denmark continues its push towards comprehensive financial digitisation, extending digital bookkeeping mandates to a wider range of entities and implementing Standard Audit File for Tax (SAF-T) reporting. While B2G e-invoicing is mandatory, B2B remains widely adopted but not explicitly required by law, though the government is actively promoting its use. Key developments include new executive orders broadening the digital bookkeeping obligation, phased implementation deadlines for different entity types, and a delay in the final release of the OIOUBL 3 e-invoicing standard. Businesses operating in Denmark must ensure their systems are capable of generating SAF-T compliant files upon request and are aligned with current and upcoming digital bookkeeping requirements.

Key Themes and Important Ideas/Facts:

Broadening Digital Bookkeeping Mandate:

Effective from March 2025, new executive orders (Executive Order no. 297 and Executive Order no. 303) have expanded the scope of businesses required to adopt digital bookkeeping under the Danish Bookkeeping Act.
This expansion aims to create a more unified and transparent financial reporting landscape.
Newly included entities that must implement compliant digital bookkeeping systems by January 1, 2026, include:
Sole Proprietorships with an annual turnover exceeding DKK 300,000 for two consecutive financial years.
Associations and Foundations engaged in commercial activity with revenue over DKK 300,000 annually over two years.
Subsidiaries of Financial Institutions (previously exempt).
This change is estimated to impact an additional 118,000 businesses.
The Danish Bookkeeping Act, introduced in 2022, requires companies to register and archive bookkeeping records in approved systems and be able to send and receive structured electronic invoices.

Standard Audit File for Tax (SAF-T) Requirements:

Denmark introduced SAF-T reporting under its Bookkeeping Act in July 2022.
SAF-T mandates businesses to report tax and financial data to Denmark’s tax authority (SKAT) in a standardised electronic format, aligned with the OECD SAF-T version 2 model.
Denmark employs a demand-based approach to SAF-T submission. Companies are only required to submit SAF-T files upon explicit request from the tax authorities during audits or inspections. There are no periodic reporting deadlines.
Businesses must ensure their digital bookkeeping systems are capable of generating SAF-T compliant files when requested.
SAF-T files in Denmark follow the OECD SAF-T V.2 XML format and must be submitted through official channels such as TastSelv Erhverv (SKAT’s self-service portal), or via integration using web services (REST APIs) or secure FTP gateways. Email submissions are not accepted.
Authentication for submission is required using MitID/NemID or equivalent business credentials. Automated submissions require trusted certificates or tokens provided by SKAT.
The SAF-T file structure in Denmark includes a mandatory Header, with Master File, General Ledger accounts, and Source Documents currently optional but expected to become mandatory in future updates to facilitate data transfers.
The official XML schema is the Danish SAF-T Financial Data, version 1.0, and using the recommended standard chart of accounts (Standardkontoplan) mappings is required for accuracy.
Failure to provide SAF-T data when requested can lead to penalties or compliance issues.

E-invoicing Landscape and OIOUBL 3 Delay:

Electronic invoicing is widely adopted in Denmark.
B2G (Business to Government) e-invoicing has been mandatory for all transactions with government entities since 2005. The commonly used formats are PEPPOL BIS Billing 3.0 and the national Danish format OIOUBL.
B2B (Business to Business) e-invoicing is widely used but not yet mandatory by law. The most commonly used formats are PEPPOL BIS Billing 3.0 and OIOUBL.
The Danish Bookkeeping Act requires all standard and specialised bookkeeping systems to support the sending and receiving of electronic invoices.
The Danish Business Authority has delayed the final publication of OIOUBL 3, the latest version of its national e-invoicing format.
Initially planned for April 10, 2025, the launch has been rescheduled to October 2025.
Key changes in OIOUBL 3 include:
Required Two-Way Communication: Public sector recipients must be able to both send and receive invoice-related messages through a designated digital endpoint.
Improved Alignment with EN 16931: Further harmonisation with the European e-invoicing standard.
The delay is attributed to stakeholder feedback and the need for further technical clarification.
The Danish government is interested in further promoting e-invoicing in the private sector, suggesting potential future mandates.

Implementation Timeline for Digital Bookkeeping:

1 February 2023: Digital standard accounting system requirements became mandatory.
31 October 2023: Registration deadline for providers of standard bookkeeping systems.
1 January 2024: A public list of approved digital accounting systems is published.
1 July 2024: Companies submitting annual reports under the Danish Financial Statements Act must adopt digital accounting (based on their financial year start date).
1 January 2025: Companies using customised bookkeeping solutions must digitise their bookkeeping and be able to issue and receive structured electronic invoices and generate data in SAF-T format upon request.
January 2026: Sole proprietorships, partnerships, and financial companies with turnover exceeding DKK 300,000 in the two preceding income years must adopt digital bookkeeping.
No earlier than July 1, 2026: New regulations will apply to non-accounting companies with a net turnover exceeding 300,000 DKK in the two previous fiscal years using an unregistered accounting system.

Digital Bookkeeping System Requirements:

Digital bookkeeping systems must comply with requirements defined by the Danish government.
Basic requirements include:
Support for continuous transaction recording with documentation and reliable archiving for five years.
Compliance with recognised IT security standards, including user/access management and automatic backup.
Support for automation of administrative processes, including automatic sending/receiving of electronic invoices and managing bookkeeping according to a public standard chart of accounts in registered systems.

Recommended Actions for Businesses:

Review existing accounting systems to ensure compliance with the expanded digital bookkeeping mandate and the ability to generate SAF-T compliant files.
Monitor official regulatory updates from the Danish Business Authority (Erhvervsstyrelsen) and SKAT regarding digital bookkeeping requirements, SAF-T specifications (especially regarding mandatory data fields), and the OIOUBL 3 rollout.
For those impacted by the extended mandate, plan and implement compliant digital bookkeeping systems by the January 1, 2026 deadline.
Utilise available validation services provided by SKAT (e.g., sandbox environments) to test SAF-T file accuracy before potential submission requests.
Ensure appropriate authentication methods are in place for potential SAF-T submissions via official portals or integrated systems.
Stay informed about potential future m
andates for B2B e-invoicing.
Consider engaging with digital solution providers to ensure systems meet the defined requirements for digital bookkeeping and SAF-T.

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