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Briefing Document & Podcast: E-Invoicing and E-Reporting in Denmark

Last Update: October 27, 2025

Podcast on Spotify

Video on You Tube

Summary

Executive Summary:

Denmark is actively implementing electronic invoicing (e-invoicing) and digital VAT reporting (e-reporting) to modernize tax compliance. A phased rollout, driven by the Bookkeeping Act of 2022, mandates e-invoicing capabilities for nearly all businesses. Unlike some EU nations, Denmark currently operates under a post-audit model, meaning invoices aren’t transmitted to the tax authority in real-time. Instead, businesses must maintain digital records in standardized formats, ready for audit. The ultimate goal is full B2B e-invoicing, aligned with anticipated EU-wide reforms by 2027-2030.

Key Themes and Ideas:

Mandatory E-Invoicing Rollout:

  • Denmark has a long history with e-invoicing, with mandatory B2G e-invoicing in place since 2005. The current focus is on extending this to B2B transactions.
  • “Public-sector e-invoicing has been mandatory since 2005”.
  • The Bookkeeping Act of 2022 provides the legal framework for B2B e-invoicing.
  • The implementation is phased:
    • Large and medium companies (filing annual financial statements): January 1, 2024 (with some grace periods).
    • Small companies and sole proprietorships (with turnover above DKK 300,000 in two consecutive years): January 1, 2026.
  • The aim is to have “all B2B invoices will be electronic by 2027–2030 at the latest” to align with EU requirements.

Post-Audit Model vs. Real-Time Reporting:

  • Denmark currently uses a post-audit model where invoice data isn’t transmitted to the tax authority in real-time. This contrasts with real-time reporting systems in other countries.
  • “Denmark’s model is post-audit – there is no real-time transmission of invoices to the tax authority yet.”
  • Instead, companies must “produce a Standard Audit File for Tax (SAF-T) upon request,” containing comprehensive accounting data.

Scope of the Mandate:

  • The mandate has a very broad scope, covering “almost all businesses and organizations engaged in commercial activities in Denmark”.
  • This includes Danish-established businesses (of all sizes) and foreign businesses with activities in Denmark (particularly those VAT-registered).
  • Starting in 2026, “foreign taxable persons registered for Danish VAT will be subject to the same digital bookkeeping and e-invoicing rules if their turnover in Denmark exceeds DKK 300,000 for two consecutive years.”
  • B2G transactions are fully in scope.
  • B2C transactions are not mandated to be electronic unless the customer consents.

E-Invoice Formats and Standards:

  • The mandated e-invoice formats are OIOUBL (UBL 2.0, UBL 2.1) and Peppol BIS 3.0, both XML formats.
  • “The Danish national format OIOUBL (Offentlig Information Online – Universal Business Language) is based on UBL 2.0 and already includes all the standard VAT invoice fields.”
  • OIOUBL version 3.0 will be compulsory from November 2025 onward.
  • “Peppol BIS 3.0” is also accepted.
  • PDF and paper invoices are not acceptable as they don’t allow for automatic processing.
  • Digital signatures are not required.

SAF-T Reporting:

  • Companies must be able to produce a Standard Audit File for Tax (SAF-T) upon request.
  • “The SAF-T is a standardized data export (developed by OECD) that contains comprehensive accounting data , including: general ledger entries, account balances, customer and supplier master data, and invoice line items for a given period.”
  • The SAF-T is not continuously uploaded.

No Pre-Filled VAT Returns (Currently):

  • Denmark does not offer pre-filled VAT returns based on e-invoice data at this time.
  • “Because Danish authorities are not yet collecting all invoice data continuously, they do not have a complete dataset to pre-populate a VAT return.”
  • VAT returns are still prepared and filed by the taxpayer.

Penalties for Non-Compliance:

  • Significant penalties exist for non-compliance.
  • “Businesses that violate the bookkeeping and e-invoicing obligations can face substantial fines . The Bookkeeping Act prescribes fines that may reach up to DKK 1.5 million (approximately €200,000) for serious or repeated non-compliance.”
  • Other penalties include qualified auditor’s reports, orders to comply, and potential exclusion from public tenders.

Future Outlook:

  • Denmark is preparing for anticipated EU-wide “VAT in the Digital Age” (ViDA) reforms.
  • A “common public data reception” for e-documents is a possibility, hinting at a future central invoice exchange platform.
  • This might involve real-time reporting and potential pre-filled VAT returns in the future, but not yet.

Key Data Requirements (E-Invoice Content):

E-invoices must conform to the EN 16931 standard and include:

  • Seller and Buyer details (names, addresses, VAT numbers)
  • Invoice details (unique number, date, reference to order/contract)
  • Line item details (description of goods/services, quantity, unit price)
  • Tax details (VAT rate, net amount, VAT amount, total amount)
  • Other mandatory info (payment due date, tax exemptions, reverse charge notation)

Implications and Recommendations:

  • Businesses operating in Denmark should ensure they meet the phased implementation deadlines for e-invoicing.
  • They should adopt accounting systems that support OIOUBL and Peppol BIS 3.0 formats.
  • Businesses must be able to generate SAF-T files on demand.
  • Foreign businesses with VAT registrations in Denmark must be aware of the compliance requirements and deadlines.
  • Given the significant penalties, compliance should be a high priority.

INDEPTH ANALYSIS

Overview: Denmark is expanding its use of electronic invoicing (e-invoicing) and digital VAT reporting (e-reporting) to modernize tax compliance. Public-sector e-invoicing has been mandatory since 2005, and a new Bookkeeping Act (Act No. 700 of 24 May 2022) now phases in requirements for nearly all businesses to issue and record invoices electronically. Unlike some EU countries, Denmark’s model is post-audit – there is no real-time transmission of invoices to the tax authority yet. Instead, companies must use approved digital systems capable of e-invoicing and of producing standard audit files on request. Below is a structured outline of the Danish e-invoicing and e-reporting mandate, including timeline, scope, data requirements, deadlines, penalties, formats, and the status of pre-filled VAT returns. [cleartax.com], [pwc.dk] [avalara.com]

 

Implementation Timeline in Denmark

  • 2005 (B2G Mandatory): Denmark was an early adopter – since February 2005, electronic invoicing has been compulsory for all business-to-government (B2G) transactions. Suppliers to public authorities must send invoices in a structured electronic format. This established the NemHandel network and OIOUBL format for public e-invoices. [cleartax.com], [avalara.com]
  • May 2022 (Legal Framework): The Danish Parliament passed a new Bookkeeping Act (effective 1 July 2022) which requires digital bookkeeping and lays the groundwork for mandatory B2B e-invoicing. This law obliges virtually all enterprises to keep accounting records electronically and be able to exchange invoices digitally. [storecove.com], [danishbusi…thority.dk]
  • Phased Roll-out 2024–2026 (B2B E-Invoicing): The mandate for business-to-business (B2B) e-invoicing is being introduced in stages:
    • 1 January 2024: Large and medium companies that must file annual financial statements (Classes B, C, D under Danish accounting law) must use digital bookkeeping systems and e-invoicing from the start of financial year 2024. (Those using in-house/self-developed bookkeeping software were given a grace period until 1 July 2024 to comply.) [storecove.com]
    • 1 January 2025: By this date, remaining large companies had to fully transition. In particular, companies that filed annual reports but had been using non-registered (non-approved) accounting systems needed to submit their 2024 accounts digitally and ensure their systems are compliant. (October 31, 2023 was the deadline to notify authorities of which digital system would be used, in preparation for 2024 reporting.) [fiscal-req…ements.com]
    • 1 January 2026: Small companies and sole proprietorships not required to file annual reports but with annual turnover above DKK 300,000 (≈€40,000) in two consecutive years must comply with the digital bookkeeping and e-invoicing requirements from the start of fiscal year 2026. This brings virtually all remaining private businesses into scope by 2026. [storecove.com], [erhvervsstyrelsen.dk]
    • 1 July 2026: Small businesses using in-house developed systems have until mid-2026 to get those systems compliant. By this date, even companies with custom bookkeeping software must meet the digital standards (effectively completing the rollout of mandatory e-invoicing capability to all Danish businesses). [storecove.com]
  • Future Outlook: While the national mandate will cover all domestic businesses by 2026, Denmark plans a full B2B e-invoicing mandate by around 2027–2030, in line with upcoming EU requirements. The current approach is to prepare businesses ahead of anticipated EU-wide “VAT in the Digital Age” reforms. For now, B2B e-invoicing in Denmark remains under a post-audit model (no clearance by tax authority), but real-time reporting may be introduced once the B2B mandate is in force. [avalara.com]

Transactions Subject to the Mandate

  • B2G (Business-to-Government): All invoices sent to Danish public sector entities must be electronic, using the approved formats. This has been required since 2005. Central, regional, and municipal authorities only accept e-invoices, and any supplier invoice not in the mandated electronic format is rejected. Thus, B2G transactions are firmly within scope: Danish government agencies and institutions demand structured e-invoices for all purchases of goods and services. [avalara.com]
  • B2B (Business-to-Business): Domestic B2B transactions are becoming subject to mandatory e-invoicing as the Bookkeeping Act phases in. Currently (2025), electronic invoicing for B2B is not yet legally compulsory for every transaction; paper or PDF invoices are still allowed if both parties agree. However, companies are strongly encouraged to use structured e-invoices (and larger companies are already required to have the capability). Once the phased deadlines are reached (by 2024–2026), businesses will effectively be required to issue their invoices electronically for domestic trade, making B2B e-invoicing de facto mandatory. Denmark’s target per EU alignment is that all B2B invoices will be electronic by 2027–2030 at the latest. [avalara.com]
  • B2C (Business-to-Consumer): Invoices to consumers are not mandated to be electronic. Businesses can continue to issue paper or PDF invoices to private individuals. E-invoices for B2C are voluntary – they may be used with the customer’s consent. (For example, a utility or retailer may send an e-invoice to a consumer who agrees to receive it, but this is not enforced by law.) If a business chooses to e-invoice a consumer, it must still include all required VAT information on the invoice (buyer and seller details, date, invoice number, description, tax amount, etc.) to remain compliant. [avalara.com]
  • Cross-Border Transactions: There is currently no special real-time e-invoice mandate for cross-border sales. Invoices for international B2B sales (e.g. to EU customers) are not required to go through a Danish platform. However, under the new rules, Danish companies and foreign companies doing business in Denmark must be able to handle e-invoices, so in practice they may use electronic invoices for cross-border transactions as well. Notably, the NemHandel/Peppol network used in Denmark allows easy exchange of e-invoices across Europe. For foreign businesses selling in Denmark: starting in 2026, those registered for Danish VAT will also need to comply with Denmark’s digital invoicing rules once they exceed the turnover threshold (see Taxable Persons in Scope below). [storecove.com], [storecove.com] [vatabout.com]
  • Other Transactions: The mandate primarily targets standard VAT-liable sales of goods and services (invoices that would be part of the company’s accounts). Certain transactions might be outside the scope of VAT invoicing requirements (for example, purely private/non-commercial activities or exempt supplies) and thus not subject to e-invoicing rules. Public grants/subsidies: Entities that receive government grants are also drawn into scope – if a grant’s conditions require providing accounting info, the recipient must comply with digital record-keeping (unless explicitly exempted by the authority). [danishbusi…thority.dk]

Taxable Persons in Scope

Denmark’s e-invoicing/digital bookkeeping mandate has a very broad scope. Essentially, almost all businesses and organizations engaged in commercial activities in Denmark are covered. Key in-scope categories include:
  • All Danish-Established Businesses: “Commercial enterprises of any kind established in Denmark” fall under the Bookkeeping Act. This covers companies of all sizes and legal forms – from large corporations to SMEs and sole proprietors – as long as they carry out economic activities. It includes public and private limited companies (A/S, ApS), partnerships, foundations, cooperatives, self-employed traders, etc., regardless of ownership structure. Even very small enterprises (Class A) are included once they cross the modest turnover threshold of 300,000 DKK (approx €40k) in two consecutive years. (Truly tiny or inactive entities below that threshold are temporarily out of scope, but if they grow, they become subject to the mandate.) [danishbusi…thority.dk] [pwc.dk] [storecove.com], [erhvervsstyrelsen.dk]
  • Foreign Businesses with Activities in Denmark: The law explicitly applies to “commercial activities carried out in Denmark by companies domiciled abroad.”. Foreign companies operating in Denmark – for example, via a branch, or those merely VAT-registered in Denmark without a local establishment – must comply once certain criteria are met. Denmark has announced that from 1 January 2026, foreign taxable persons registered for Danish VAT will be subject to the same digital bookkeeping and e-invoicing rules if their turnover in Denmark exceeds DKK 300,000 for two consecutive years. This ensures that foreign businesses (e.g. an EU company selling into Denmark and registered for VAT) are not exempt from the e-invoicing requirements. Newly VAT-registered foreigners will become in-scope once they too cross the threshold in two years of activity. [danishbusi…thority.dk] [vatabout.com]
  • Entities Filing Annual Reports: Any company obliged to submit an annual financial statement to the Danish Business Authority (i.e. those in Accounting Classes B, C, D) is in scope immediately for the digital invoicing requirements. These are typically incorporated businesses of any appreciable size. They were required to adopt an approved digital accounting system by 2024, as noted above. [storecove.com]
  • Associations and Organizations: Non-corporate entities like associations or foundations that engage in commercial operations or are subject to tax in Denmark are included. For example, a sports club or charity with business income (say from a clubhouse bar or ticket sales) must follow the digital bookkeeping rules if they meet the threshold. Purely non-commercial, voluntary associations (with only philanthropic or social activities and no significant business revenue) are exempted from the e-invoicing mandate. Essentially, if an organization has a VAT or tax obligation in Denmark and significant economic activity, it must use digital invoicing and records. [storecove.com]
  • Public Sector & Grant Recipients: Government bodies themselves must use e-invoices (as recipients for B2G, and presumably when acting as issuers). Also, any enterprise receiving public funds with a requirement to report financial information has to comply with the Bookkeeping Act, unless expressly exempted by the granting authority (with tax authority consent). [danishbusi…thority.dk]
  • Excluded Persons: The mandate does not apply to purely private individuals or purely non-commercial undertakings. Also, entities already governed by other public sector accounting laws (e.g. government departments under state accounting rules, or municipalities under local government accounting rules) are outside this Act. But these are generally not “enterprises” issuing VAT invoices in the normal sense. [danishbusi…thority.dk]
In summary, any taxable person (company or trader) doing business in Denmark is either already required or will soon be required to use e-invoicing, unless they are below the very low revenue threshold or fall into a narrow nonprofit exception. This includes Danish companies and foreign firms with Danish VAT registrations. The mandate’s reach is comprehensive, aiming to leave no significant business transactions outside the digital system. [storecove.com], [storecove.com]

Data to be Provided (Content Requirements)

E-Invoice Content: Under the Danish e-invoicing framework, an electronic invoice must contain all the information normally required on a VAT invoice, structured according to the European standard. Denmark’s system adheres to EN 16931, the EU standard for e-invoice data, ensuring that required fields like:
  • Seller and Buyer details – names, addresses, and VAT identification numbers (CVR for Danish businesses); [avalara.com]
  • Invoice details – a unique invoice number, invoice date, and reference to any order or contract;
  • Line item details – description of goods or services supplied, quantity, unit price;
  • Tax details – the applicable VAT rate(s), the net amount, VAT amount per rate, and total amount payable;
  • Other mandatory info – such as payment due date, and if relevant, any tax exemptions or reverse charge notation.
These elements are encoded in the required XML format (OIOUBL or Peppol BIS 3.0) so that the invoice can be automatically processed by the recipient’s system. The Danish national format OIOUBL (Offentlig Information Online – Universal Business Language) is based on UBL 2.0 and already includes all the standard VAT invoice fields. Likewise, Peppol BIS 3.0 is an EU-standard XML format. If issuing a consumer e-invoice (optional scenario), the same core data must be provided – the invoice should clearly show the tax calculation and customer info (even if the customer is not VAT-registered). [avalara.com]
E-Reporting Data: Denmark’s current approach does not require taxpayers to send each invoice’s details to the Tax Agency in real time. Instead, the focus is on maintaining digital records that can be reported or inspected when needed. Under the Bookkeeping Act, companies must be prepared to produce a Standard Audit File for Tax (SAF-T) upon request. The SAF-T is a standardized data export (developed by OECD) that contains comprehensive accounting data, including: general ledger entries, account balances, customer and supplier master data, and invoice line items for a given period. In practice, this means all transactional data (sales, purchases, payments, etc.) must be recorded in the company’s system in a structured way, and upon audit or inquiry, the company can provide authorities a SAF-T file containing those records. The SAF-T format for Denmark has been defined to align with the national chart of accounts and VAT reporting needs. It’s not continuously uploaded, but must be generated on-demand. [vatcalc.com]
Apart from SAF-T, the law also newly requires that when filing annual financial statements, companies disclose what bookkeeping system they use (name of the software/provider) and whether it’s a registered (approved) system. This indirectly provides authorities data about compliance. [pwc.dk], [pwc.dk]
In the future, if Denmark implements a real-time reporting or clearance system, the data to be provided could shift to transactional invoice reporting (as seen in e.g. Italy or France). As of the latest reforms, however, the data provision is “keep and produce when asked” rather than “transmit each invoice”. Businesses still submit periodic VAT returns summarizing sales/purchases in aggregate (see Pre-filled Returns section), but individual invoice data isn’t routinely sent to Skat (the tax authority) yet. [avalara.com]

Deadlines for Transmitting Data to Authorities

One notable aspect of Denmark’s approach is the absence (so far) of strict real-time or near-real-time reporting deadlines that some other countries have. Key points:
  • No Continuous Transaction Reporting (Yet): Denmark does not require live or immediate reporting of invoice data to the tax authorities for domestic transactions. In other words, there’s no requirement to upload each invoice to a government portal within X days of issuance (unlike Spain’s SII 4-day rule or Italy’s clearance through SDI). Because of this, there are no specific periodic e-reporting deadlines for invoices beyond the normal VAT return schedule. The focus is on maintaining compliant digital records. Tax authorities gain access to data either through the VAT return or by requesting the SAF-T audit file or performing an inspection. [avalara.com]
  • VAT Return Deadlines Unchanged: Businesses must continue to file their periodic VAT returns (Momsrapport) by the standard due dates. For most companies, this is quarterly or monthly depending on turnover, with deadlines on the 25th of the following month or every quarter (e.g. a Q1 return due by April 25). These returns summarize sales and purchases totals. The new e-invoicing rules do not alter the schedule of VAT filings; rather, they should improve the accuracy of record-keeping that underlies those filings. (There is no system of automatic VAT draft returns being sent to taxpayers in Denmark at this time – see Pre-Filled VAT Returns below.)
  • Implementation/Compliance Deadlines: Instead of reporting cut-offs, Denmark imposed deadlines for businesses to implement digital systems: notably the 31 October 2023 system registration date, and the phased start dates in 2024 and 2026 for using e-invoices (as detailed in the Timeline above). Missing these dates could expose businesses to penalties, even though there isn’t a continuous upload requirement. For example, a Class B company needed to begin e-invoicing by January 1, 2024 – failing to do so by that “deadline” would be a compliance violation. [fiscal-req…ements.com]
  • B2G Invoice Submission: For invoices to public authorities, while there isn’t a “report to tax authority” deadline, there is a de facto requirement to submit the e-invoice promptly in the required format in order to get paid. Public contracts usually stipulate that invoices must be sent through NemHandel/Peppol upon delivery of goods or services. If a supplier attempts to send a paper invoice, it will be rejected immediately by the government’s system. Thus, B2G suppliers must ensure timely submission of a compliant e-invoice (typically within the normal invoicing timeline agreed in the contract). A non-compliant invoice effectively misses the payment deadline until fixed. [avalara.com]
  • Future Real-Time Reporting: The Danish government has the legal authority (in the Bookkeeping Act) to establish a “common public data reception” for e-documents. This hints that in the future, a central invoice exchange or clearance platform could be introduced by regulation. If and when such a continuous transaction control (CTC) system is implemented, specific transmission deadlines will be defined (e.g. reporting invoices within a day of issue). As of late 2025, however, no such real-time mandate is in effect – the authorities rely on post-audit access to data. [pwc.dk] [avalara.com]
Bottom line: There are no daily or transactional e-reporting deadlines currently imposed in Denmark. The critical dates for businesses are the ones by which they must be ready and using the digital invoicing system (2024/2026, depending on size), and the usual tax filing dates. Tax authorities can request data at any time, so in practice businesses must keep records up-to-date continuously (the law says transactions should be recorded “as soon as possible” and reconciled regularly to be ready for any statutory reporting). But unlike some regimes, you don’t have to continuously push each invoice to Skat within a set number of days at this point. [danishbusi…thority.dk], [danishbusi…thority.dk]

Penalties for Non-Compliance

Denmark’s regulations impose significant penalties for failing to comply with the e-invoicing and digital bookkeeping requirements:
  • Fines: Businesses that violate the bookkeeping and e-invoicing obligations can face substantial fines. The Bookkeeping Act prescribes fines that may reach up to DKK 1.5 million (approximately €200,000) for serious or repeated non-compliance. The exact fine depends on factors like the company’s turnover, the severity and duration of the violation, and whether it’s a repeat offense. Minor violations would incur smaller penalties, but particularly extensive breaches (such as persistently not using any digital system, or willfully destroying records) trigger higher fines. These are criminal fines, and legal entities (companies) can be held liable under the law. [vatabout.com], [vatabout.com] [danishbusi…thority.dk]
  • Inspection and Audit Consequences: The Danish Business Authority and Tax Agency have enhanced powers to audit compliance. If a company’s invoicing system is not compliant, authorities may conduct a special audit. For instance, an auditor reviewing the annual accounts will check whether the bookkeeping system meets the new requirements; if not, the auditor’s report can be qualified (negative), which has legal and reputational consequences. In addition, the Business Authority can issue orders to comply and even daily fines (coercive fines) until issues are fixed. In extreme cases, failure to keep proper books could lead to further legal action or business license repercussions. [vatabout.com] [danishbusi…thority.dk]
  • Public Sector Enforcement (B2G): For B2G supplies, non-compliance is immediately penalized by the system: any invoice to a government entity that is not in the required electronic format is rejected and will not be paid. This not only delays payment, but can also lead the supplier to incur breach of contract penalties or cash flow problems. Moreover, government agencies may report serious supplier compliance failures. Administrative fines can be imposed on suppliers who try to circumvent the B2G e-invoicing mandate. Importantly, companies that repeatedly fail to send proper e-invoices to the public sector can be excluded from future public tenders or contracts – a strong deterrent for businesses that rely on government clients. [avalara.com]
  • Offenses Under Other Laws: The bookkeeping requirements tie into broader tax compliance. If e-invoicing failures result in VAT not being reported correctly, the company could also face penalties under general tax law (e.g. fines or liability for any underpaid VAT). The Bookkeeping Act notes that if a more severe penalty is applicable under other legislation, that can take precedence. For example, in cases of fraud or deliberate tax evasion, criminal charges could be brought beyond just the bookkeeping fine. [danishbusi…thority.dk]
  • Enforcement Start: The increased enforcement began in 2023–2024. Companies had to register their digital systems by late 2023, and the authority can inspect whether a company’s bookkeeping system is approved. There is an expectation of stepped-up inspections to ensure businesses are following the new rules. Companies that haven’t switched to a compliant accounting system by their applicable deadline risk immediate fines or orders once discovered. [pwc.dk], [pwc.dk]
In summary, Danish authorities have put both financial penalties (fines up to DKK 1.5 million) and operational consequences (audit qualifications, payment rejections, exclusion from contracts) in place to drive compliance. Businesses are advised to adapt on time to avoid these outcomes. The severity of the maximum fine underscores that Denmark views proper digital bookkeeping as crucial, with non-compliance viewed on par with serious regulatory violations. [vatabout.com], [avalara.com]

Formats for E-Invoicing and E-Reporting

Denmark mandates specific standardized formats for electronic invoices and data reporting to ensure interoperability and compliance:
  • OIOUBL (UBL 2.0): The primary national e-invoice format is OIOUBL, an XML format based on the Universal Business Language 2.0. OIOUBL has been the norm since 2005 for B2G invoicing. It encapsulates all required invoice information in a structured form and is compliant with the European Norm EN 16931 for e-invoices. In 2024, Denmark updated OIOUBL to version 3.0 (aligned with UBL 2.1 and EN 16931 standards) which, for example, includes mandatory responses/receipts for invoices. Use of OIOUBL 3.0 will be compulsory from November 2025 onward. This ensures Danish invoices meet the latest EU semantic standard and can be understood across systems. [avalara.com] [vatcalc.com] [cleartax.com]
  • Peppol BIS 3.0: Denmark is also fully onboard with the Peppol BIS 3 format, which is another implementation of EN 16931. Businesses can issue invoices in the Peppol BIS 3.0 XML format for both domestic and cross-border transactions. In fact, NemHandel (the Danish e-invoicing network) is interoperable with the Peppol network, so a Danish company can send a Peppol BIS 3 invoice to any trading partner on Peppol (inside or outside Denmark). Peppol BIS and OIOUBL carry essentially the same information; the main difference is the network envelope. By accepting Peppol BIS, Denmark aligns with the broader European e-invoicing infrastructure. [avalara.com] [storecove.com], [storecove.com]
  • NemHandel Network: Rather than a format, this is the transport infrastructure. NemHandel is Denmark’s e-invoice exchange network (a “four-corner model” similar to Peppol). All public institutions are on NemHandel, and private companies use it or Peppol to send/receive invoices. NemHandel uses the aforementioned formats (OIOUBL or Peppol BIS). The government is gradually transitioning fully to Peppol for message transport, effectively merging NemHandel with the Peppol network. For users, the practical format remains XML invoices that conform to EN 16931, sent via an Access Point. There are no proprietary or PDF formats allowed for mandated e-invoicing – only structured XML. [storecove.com], [storecove.com] [fiscal-req…ements.com]
  • No PDF or Paper: It’s important to note that under the mandate, traditional formats like PDF, Word, or paper do not meet the requirement for an e-invoice. An “e-invoice” is legally defined as an invoice issued, transmitted, and received in a structured electronic format that allows for automatic processing. Thus, a PDF sent by email, although electronic, is not a structured e-invoice. Companies in scope must use OIOUBL or Peppol XML formats (often generated by their accounting software). [danishbusi…thority.dk]
  • Digital Signatures: Denmark does not require an electronic signature on e-invoices. The authenticity and integrity of invoices are ensured by the controlled systems and networks. However, businesses should use secure channels (NemHandel/Peppol) and maintain appropriate IT controls. (Digital signatures can be used voluntarily for security, but they are optional.) [avalara.com]
  • Archiving Format: Invoices must be archived electronically in their original format for 5 years (for most records) or 10 years if they relate to immovable property. This means keeping the XML file and not just a printout. The archival format should preserve the data structure. [avalara.com], [cleartax.com]
  • Standard Audit File (SAF-T): For e-reporting, the format in play is the SAF-T (Standard Audit File for Tax), which in Denmark is an XML schema conforming to the OECD’s model. Companies’ bookkeeping systems must be capable of exporting financial data in the SAF-T format on demand. While SAF-T is not regularly submitted, it is the standardized format for delivering a full set of accounting information to tax auditors. Ensuring the accounting system maps data correctly to the SAF-T schema is part of compliance. [vatcalc.com]
  • Other Data Exchange: The Bookkeeping Act also contemplates a “common public data center/receipt” which might introduce standardized channels for exchanging e-documents with authorities. If implemented, this could mean a government portal where structured data (invoices, records) are uploaded in a set format. Future regulations under the Act could specify new formats or protocols, but as of now OIOUBL/Peppol and SAF-T are the main standards in use. [pwc.dk]
In summary, the required e-invoice format is XML (OIOUBL or Peppol BIS) sent via the NemHandel/Peppol network. These formats comply with EU standards (EN16931) and ensure that all necessary invoice data is included in a machine-readable way. For reporting and audit, the key format is SAF-T XML for exchanging entire ledgers and transaction data. Danish businesses must ensure their software supports these formats – indeed, one of the legal requirements is that the accounting system must be able to “automatically distribute and receive e-invoices” in the standard format. [avalara.com] [vatcalc.com] [pwc.dk]

Pre-Filled VAT Returns

Some countries that have introduced e-invoicing or real-time reporting use the data to pre-fill taxpayers’ VAT returns (for example, Spain’s SII and Hungary’s live invoice reporting feed into draft returns). Denmark, however, does not currently offer pre-filled VAT returns based on e-invoice data. There are a few reasons and notes on this:
  • No Real-Time Data Collection: Because Danish authorities are not yet collecting all invoice data continuously, they do not have a complete dataset to pre-populate a VAT return. VAT returns in Denmark are still prepared and filed by the taxpayer (or their accounting software), not automatically generated by the tax authority. Businesses must compile their sales and purchase figures from their records and submit the numbers in the usual way (typically via the online TastSelv Erhverv portal or through authorized software). The new digital bookkeeping systems make it easier for businesses to do this accurately, but the tax authority isn’t doing it for them. [avalara.com]
  • Government’s Access to Data: The Bookkeeping Act’s vision of a “common public data repository” in the future suggests that Denmark is considering greater data sharing, but as of 2025 there is no system of Skat sending you a draft VAT return. The authorities can request your SAF-T file or audit your records, but that’s post-reporting verification, not automated return prep. In Denmark’s current VAT regime, even with mandatory e-invoicing, the taxpayer remains responsible for preparing the VAT return (ensuring all output and input VAT are accounted for) and submitting it by the deadline.
  • Possible Future Developments: Denmark is attentive to EU digital VAT initiatives. The EU Commission’s “VAT in the Digital Age” (ViDA) proposals include real-time digital reporting which could eventually enable pre-filled VAT returns EU-wide. If Denmark in coming years moves to more frequent reporting of transaction data, the concept of pre-filled returns might emerge. For example, if every invoice were reported to a central system, the tax authority could theoretically total up a business’s sales and purchases and present a draft return. As of now, though, Denmark has not implemented this. There are no official statements indicating near-term plans for pre-filled returns, beyond the existing optional automation tools that taxpayers themselves can use (many companies use accounting software to compute and even submit the VAT return electronically, but that’s done by the taxpayer’s system, not by Skat pre-filling the form).
  • Confirmation: Multiple tax tech sources note that unlike countries with real-time invoice reporting, Denmark will continue with periodic VAT reporting until further notice, since “Denmark does not currently require live VAT reporting” and thus cannot generate live VAT assessments. For now, businesses should treat the e-invoicing mandate as a compliance measure and efficiency tool, but they must still actively file VAT returns. No automatic relief like pre-filled returns is provided – if anything, the authorities expect that digital bookkeeping will make it easier for businesses to themselves file correct returns on time (reducing errors and fraud). [avalara.com]
Conclusion: Denmark’s e-invoicing and e-reporting initiative modernizes how invoices and accounting data are handled, but it stops short of real-time government intervention in invoicing. The timeline requires large companies to be e-invoice compliant by 2024 and all companies by 2026. In-scope transactions cover all B2G and (soon) all B2B invoices, with almost every business entity (including foreign VAT registrants) required to participate. The data captured in each invoice must meet detailed VAT requirements and be available in standard digital formats (XML and SAF-T). While there are no continuous reporting deadlines yet, companies must adhere to the phase-in dates and existing VAT filing deadlines. Penalties for non-compliance are significant, including hefty fines up to DKK 1.5 million and other sanctions. The formats mandated are OIOUBL and Peppol BIS 3.0 for e-invoices, ensuring interoperability and alignment with EU standards, and SAF-T for data export. Pre-filled VAT returns are not provided in Denmark at this stage, given the post-audit system – businesses must continue to compile and file their VAT obligations manually. All official regulations (such as the Bookkeeping Act and related executive orders) are published by Danish authorities, and guidance is available via the Danish Business Authority and SKAT websites to help companies adapt to these changes. [vatabout.com], [avalara.com] [avalara.com] [vatcalc.com] [pwc.dk]
Sources:

  • Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE

 



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