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

Last Update: February 28, 2026

Podcast on Spotify

 

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Summary

1. Executive Summary

Denmark has embarked on a comprehensive modernization of its bookkeeping and tax compliance framework, primarily driven by the 2022 Bookkeeping Act (Bogføringsloven) and its alignment with broader EU digitalization initiatives like the “VAT in the Digital Age” (ViDA) reforms. While Business-to-Government (B2G) e-invoicing has been mandatory since 2005 via the NemHandel platform, the new legislation significantly expands the scope, requiring nearly all businesses to adopt compliant digital bookkeeping systems capable of e-invoicing and generating standardized audit files (SAF-T).

The rollout is phased by company size, with large enterprises beginning compliance in 2024 and small and medium-sized enterprises (SMEs) following by January 2026, with some extensions until July 2026 for custom systems. The mandate focuses on digital record-keeping and e-invoicing capability for B2B/B2C transactions, rather than immediate real-time e-reporting to tax authorities for domestic transactions. Non-compliance carries substantial penalties, including fines up to DKK 1.5 million (approx. €200,000). This initiative aims to enhance efficiency, combat fraud, and prepare Danish businesses for future EU-wide digital reporting obligations.

2. Mandate Scope and Evolution

Denmark’s digital compliance framework differentiates between mandatory e-invoicing and the requirement for digital bookkeeping systems with e-invoicing capabilities:

• E-Invoicing Obligations (B2G): Electronic invoicing has been mandatory for all Business-to-Government (B2G) transactions since 2005. Suppliers to public authorities must issue invoices “in a structured electronic format (initially OIOXML/OIOUBL, now upgraded to OIOUBL/Peppol BIS) via the national NemHandel platform.”
• E-Invoicing Capability (B2B/B2C): While “Business-to-Business (B2B) e-invoicing is not yet universally mandatory,” the 2022 Bookkeeping Act stipulates that “all businesses must be capable of sending and receiving e-invoices in the standard formats by 2024–2026 (depending on company size and systems).” Business-to-Consumer (B2C) e-invoicing is not mandated.
• E-Reporting Obligations: Denmark’s current approach to e-reporting “centers on digital bookkeeping and SAF-T (Standard Audit File for Tax) requirements rather than real-time invoice reporting.” There is “no continuous real-time invoice data submission to tax authorities yet for domestic transactions.” Instead, businesses must maintain electronic accounting records and be ready to produce SAF-T files on demand.
• Transactions in Scope:Mandatory e-invoicing applies to domestic B2G supplies.
• B2B and B2C transactions are not subject to mandatory e-invoice exchange as of 2026, but businesses must have the capability to use e-invoices if requested.
• Intra-EU B2B supplies and exports are not yet subject to a Danish e-invoicing mandate. However, these will become mandatory for cross-border transactions under the EU’s “VAT in the Digital Age (ViDA)” reforms by 2028-2030, which Denmark, as an EU member, will integrate.
• Special Invoicing Scenarios: The framework covers all transaction types requiring VAT invoices under general law, including self-billing, triangulation, chain transactions, and special VAT regimes (e.g., margin schemes, zero-rated/exempt supplies). For self-billing, “the self-billed invoice must be generated in the required electronic format and transmitted via the designated platform just like any other e-invoice.” These scenarios require specific annotations or references on the e-invoice, which the standardized formats accommodate.

3. Taxable Persons in Scope

The Bookkeeping Act 2022 is broad, applying to almost all commercial entities operating in Denmark:

• Established Businesses: All Danish-registered companies, regardless of size, “must comply with the digital bookkeeping and e-invoicing readiness requirements by the applicable deadlines.” This includes sole proprietorships and partnerships.
• Non-Established & Foreign Businesses: Foreign companies “that are VAT-registered in Denmark are also in scope.” From 1 January 2026, “even foreign companies registered for VAT in Denmark (with local taxable activities) and exceeding the DKK 300,000 turnover threshold must use a compliant digital bookkeeping system.”
• Exemptions: Very small enterprises “below the annual revenue threshold of DKK 300,000 are presently exempt from the digital bookkeeping system mandate.” Certain non-profit associations or businesses with no VAT obligations may also be excluded if they don’t fall under VAT invoicing rules.
• Software Flexibility: Businesses can choose any certified software or service provider, “as long as it meets the official requirements.” The mandate is designed to “eventually encompass all VAT-registered businesses, domestic or foreign, above a low turnover threshold.”

4. Implementation Timeline

Denmark’s transition to mandatory digital bookkeeping and e-invoicing capabilities is a phased rollout between 2023 and 2026, stemming from the Bookkeeping Act passed in May 2022:

• May 2022: Legislative foundation laid with the passing of Law No. 700 of 24/05/2022 (Bogføringsloven).
• Early 2023: Preparatory phase; regulations took effect February 2023, requiring companies to register digital accounting systems by October 2023.
• Mid 2024 (July 1): Medium and large companies using standard (off-the-shelf) digital bookkeeping systems needed to migrate to certified systems, effectively meaning full compliance by 1 January 2025 for those on a calendar fiscal year.
• Start of 2025 (January 1): Large enterprises using custom-built or non-standard bookkeeping systems had to comply. By this date, “digital record-keeping and e-invoice capability became mandatory for all sizeable Danish businesses.”
• March 2025: Further legal developments mandated “all accounting data must reside in certified cloud-ready systems (no local-only storage for active records).”
• Late 2025: An update to the national e-invoicing standard (OIOUBL 3.0) was developed, but its full transition was “delayed… and ultimately cancelled in January 2026 in favor of maintaining stability.”
• January 2026: Full mandate for remaining businesses. “By 1 January 2026, all other businesses above the small-business threshold (DKK 300,000 annual turnover) must comply with the Bookkeeping Act’s digital requirements.”
• July 2026: Grace period for companies using self-developed (“in-house”) accounting systems ends, marking “the completion of the phased rollout.”
• Beyond 2026: Denmark anticipates integrating EU-wide mandates for cross-border e-invoicing and digital reporting under ViDA, expected by 2028–2030.

5. Technical & Functional Requirements

The Danish framework emphasizes structured data and interoperability:

• E-Invoice Specifications:Formats and Standards: Primary formats are OIOUBL 2.1 and Peppol BIS Billing 3.0. Both are “compliant with the European Norm EN 16931 semantic model for e-invoices.”
• Mandatory Invoice Content: Danish VAT invoices must include all information required by the EU VAT Directive and Danish VAT Act, such as seller/buyer identification, invoice number/date, line item details, tax details (rates, amounts, or exemption notations), and customer’s VAT ID with reverse charge statements where applicable.
• E-Reporting Format (SAF-T): The “primary ‘e-reporting’ data format in Denmark is the SAF-T (Standard Audit File for Tax).” Compliant digital systems must be able to produce a SAF-T file “on demand for tax audits.” The Danish SAF-T (version 2.0, updated 2025) is based on the OECD’s XML schema, covering 19 data sections of financial records.
• Validation & Integrity Requirements: “Digital signatures on e-invoices are not mandatory in Denmark.” Authenticity and integrity are ensured through “business controls and the secure transmission via NemHandel/Peppol networks.” Companies must also implement internal controls and preserve data integrity and readability for the retention period.

6. Correction, Transmission, and Workflow

• Correction of Errors: For e-invoices, errors must be corrected by issuing credit notes or debit notes; the original cannot be altered. B2G invoices with errors will typically be “automatically rejected by the recipient’s system.” For e-reporting (SAF-T), errors in records mean rectifying entries and submitting a revised SAF-T file if previously provided.
• Transmission to Authorities: Denmark uses an interoperability model. For B2G, the NemHandel platform acts as a national e-invoice gateway, integrated with the Peppol network. It operates as a four-corner model, with invoices exchanged via certified Access Points. For B2B, the exchange is typically voluntary via the same infrastructure.
• No Real-Time Clearance: Denmark operates a “post-audit” system for B2G e-invoicing; invoices are delivered and validated for format, but “they are not individually approved by tax authorities prior to being considered valid.” For B2B/B2C, there is no real-time government reporting or clearance.
• Workflow: Suppliers prepare invoices in their ERP, which are formatted (OIOUBL/Peppol) and sent via a certified Access Point to the buyer’s Access Point. The process is typically automated. SAF-T files are generated on request for audits, not as routine submissions.

7. Archiving & Retention

• Format: Records, including e-invoices, must be “stored electronically in their original structured format.” This means retaining the XML file, not just a PDF.
• Retention Period: A minimum of 5 years after the end of the financial year. For “invoices related to long-term assets (immovable property),” a 10-year retention period applies.
• Location of Storage: Electronic accounting records must be stored such that they are “accessible to Danish authorities.” If using cloud services, “the backup data must reside within the EU (or a country with equivalent data access provisions).”
• Integrity: Companies must guarantee the integrity, authenticity, and readability of archived invoices throughout the retention period.

8. Penalties & Enforcement

Denmark has robust penalties to ensure compliance:

• Failure to Issue E-Invoices (B2G): Non-compliant invoices are rejected, leading to payment delays and potential “breach of contract penalties, potential exclusion from future public procurement contracts, and administrative fines.”
• Non-Compliance with Digital Bookkeeping: Failure to implement a compliant system by deadlines, or disabling required features, can lead to “fines of up to DKK 1.5 million (approximately €200,000).” The Danish Business Authority actively monitors compliance.
• Late/Incorrect E-Reporting: While real-time e-reporting is not yet in force, existing VAT penalties apply for incorrect VAT returns. Inability to produce a correct SAF-T file upon audit, or significant discrepancies in digital records, can result in fines under the Bookkeeping Act.
• Archiving Violations: Failure to properly archive records for the full retention period also constitutes a violation, leading to fines.
• Intentional or Fraudulent Conduct: Egregious cases “could potentially lead to criminal charges under broader financial crime laws.” The authorities have signaled “increased oversight” and risk-based audits.

9. Impact on SMEs and Startups

The mandate has significant implications for smaller businesses:

• Phased Onboarding & Thresholds: SMEs benefit from a “longer lead time.” Businesses under DKK 300,000 annual turnover are exempt, and others have until January 2026 (or July 2026 for custom systems). This aims to prevent overwhelming smaller businesses.
• Simplified Regimes & Support: While no separate “simplified” e-invoicing regime exists, compliance is eased by a market of “cloud-based accounting and invoicing software… many of which are pre-certified by the Danish Business Authority.” The Business Authority also provides guidelines and open-source components.
• Compliance Costs: Involve software subscriptions, potential add-on modules, and staff training. However, “many vendors offer solutions at SME-friendly prices.”
• Administrative Burden vs. Simplification: Short-term, SMEs face “additional administrative tasks” and a learning curve. Long-term, “digital invoicing and bookkeeping can reduce manual data entry, minimize errors, and shorten invoice processing times,” leading to “streamlined compliance and potentially reduced accounting costs.”
• Cash Flow Effects: Digital invoicing can lead to “quicker payments” due to faster processing, especially with public bodies. Early detection of VAT errors also helps cash flow. However, upfront investment costs can be a concern.
• Market Impact: Accelerates digitalization. Early adopters may gain a competitive edge. The use of standardized formats (OIOUBL/Peppol) “is meant to prevent lock-in with any single IT provider.” The government provides guidance and outreach to support SME readiness.

10. Official References

Key legal and technical references include:

• Danish Legislation: Lov om bogføring (Bookkeeping Act), Law No. 700 of 24 May 2022.
• Government Portals: Danish Business Authority (Erhvervsstyrelsen) for guidance, certified systems lists, and SAF-T specifications. NemHandel official site for e-invoicing infrastructure.
• Technical Specifications: OIOUBL Standard documentation (v2.1) and Peppol BIS 3.0 documentation. SAF-T DK v2.0 schema.
• EU Law: Aligns with EU Directive 2014/55/EU for B2G, and future integration with EU VAT Directive amendments under “VAT in the Digital Age.”

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INDEPTH ANALYSIS

1. Scope of the Mandate

• E-Invoicing Obligations: Denmark has mandated electronic invoicing for all Business-to-Government (B2G) transactions. Since 2005, suppliers to public authorities must issue invoices in a structured electronic format (initially OIOXML/OIOUBL, now upgraded to OIOUBL/Peppol BIS) via the national NemHandel platform. Business-to-Business (B2B) e‑invoicing is not yet universally mandatory; however, under the 2022 Bookkeeping Act, all businesses must be capable of sending and receiving e-invoices in the standard formats by 2024–2026 (depending on company size and systems). Business-to-Consumer (B2C) e-invoicing is not mandated – paper or PDF invoices can still be used for consumer sales. [ec.europa.eu], [ec.europa.eu] [ec.europa.eu]
• E-Reporting Obligations: Denmark’s current approach to “e-reporting” centers on digital bookkeeping and SAF-T (Standard Audit File for Tax) requirements rather than real-time invoice reporting. From February 2023, regulations require companies to register their digital accounting systems with the Danish Business Authority (Erhvervsstyrelsen) in preparation for new reporting standards. There is no continuous real-time invoice data submission to tax authorities yet for domestic transactions. Instead, companies must maintain electronic accounting records and be ready to generate standardized tax audit files (SAF-T) on demand for authorities. (Denmark’s approach aligns with the EU’s “VAT in the Digital Age” initiative, anticipating future digital reporting for VAT). [fiscal-req…ements.com], [fiscal-req…ements.com] [avalara.com] [ec.europa.eu], [edicomgroup.com] [ec.europa.eu]
• Transactions in Scope: The mandatory e-invoicing currently applies to domestic B2G supplies (all levels of government). Domestic B2B and B2C transactions are not subject to mandatory e-invoice exchange as of 2026, but businesses must have the capability to use e-invoices in these contexts if requested. Intra-EU B2B supplies (e.g. cross-border sales to VAT-registered customers in other EU countries) and exports are not yet subject to an e-invoicing mandate in Denmark, although invoice data for such transactions must still be recorded for VAT and EC Sales List reporting (and included in SAF-T files upon request). At the EU level, new rules under the VAT in the Digital Age (ViDA) reforms will make cross-border B2B e-invoicing mandatory by 2028, with a full digital reporting system for intra-EU transactions by 1 July 2030 – Denmark, as an EU Member State, will incorporate these requirements in its framework by that time. For imports, e-invoicing is generally not applicable (import VAT is handled via customs procedures), and for exports and intra-EU supplies, invoices must still be issued (usually VAT-zero-rated) in accordance with EU VAT rules but need not be cleared through a domestic platform. [e-invoicin…asware.com], [fiscal-req…ements.com] [edicomgroup.com], [edicomgroup.com] [sovos.com], [e-invoice.app]
• Special Invoicing Scenarios: The Danish e-invoicing mandate and digital bookkeeping rules do not carve out specific exemptions for particular transaction types like self-billing, triangulation, or special VAT regimes – these scenarios are handled under general EU VAT invoicing rules:
  • Self-billing: Permitted when both parties agree in advance in writing (as per EU VAT Directive). The buyer issues the invoice on the supplier’s behalf, and the invoice must contain all standard fields plus the mention “Self-billing”. Where e-invoicing is mandatory (e.g. the buyer self-billing a public sector transaction or, in future, B2B), the self-billed invoice must be generated in the required electronic format and transmitted via the designated platform just like any other e-invoice. The supplier must approve self-billed invoices, and details such as valid VAT numbers and a formal self-billing agreement are required. [taxation-c….europa.eu] [tipalti.com], [tipalti.com]
  • Triangulation & Chain Transactions: These multi-party intra-EU transactions (where goods move through multiple EU countries via intermediaries) have no special exemption from e-invoicing; each leg of the transaction should be invoiced electronically if it falls under a mandate. The structured invoice must include all usual details, including any required VAT references. For example, in a triangulation scenario, the invoice from the intermediary to the final customer should invoke the EU VAT reverse-charge mechanism by stating “Reverse charge” on the invoice. This indicates the customer will account for the VAT. Similarly, any chain transaction or consignment should be documented with e-invoices for each supply, respecting the VAT treatment applicable (domestic or cross-border) and including references if needed to VAT Directive provisions (e.g. Article 141 for triangulation). [taxation-c….europa.eu]
  • Special VAT Regimes: Transactions under special VAT schemes (such as the second-hand margin scheme, travel agency margin scheme, agricultural flat-rate scheme, etc.) are not excluded from e-invoice requirements. Suppliers under these regimes must still issue invoices (electronically when mandated) and include any legally required references on the invoice. For instance, if the margin scheme applies, the invoice should state “Margin scheme – second-hand goods” or an equivalent remark as required by VAT law. Zero-rated and exempt supplies (e.g. exports, intra-EU supplies, financial or health services) likewise must be invoiced in compliance with normal rules – a proper description of the supply and an indication of the applicable VAT exemption or 0% rate is required on the e-invoice (usually by quoting the relevant legal provision or using the correct tax code in the e-invoice). These details are accommodated in the standard e-invoice format (EN 16931/OIOUBL) through specific tax category codes and reference fields. In summary, the Danish e-invoicing framework covers all types of transactions that currently require VAT invoices under general law, without introducing new exclusions; what changes is the format and method of issuance, not the fundamental VAT obligations. [taxation-c….europa.eu]

2. Taxable Persons in Scope

• Established Businesses: The Bookkeeping Act 2022 applies broadly to almost all businesses operating in Denmark. All Danish-registered companies – including domestic entities with legal establishment in Denmark – must comply with the digital bookkeeping and e-invoicing readiness requirements by the applicable deadlines. This includes companies of all sizes (with phased implementation based on turnover and reporting obligations, see Section 3) as well as sole proprietorships and partnerships engaged in commercial activities in Denmark. In practice, if a business is subject to the Danish VAT Act or to accounting laws, it falls under the scope of these requirements. Notably, businesses obliged to file annual financial statements (under the Danish Financial Statements Act, classes B, C, D) are required to adopt compliant digital systems early in the timeline. [fiscal-req…ements.com], [sovos.com] [cleartax.com] [kpmg.com]
• Non-Established & Foreign Businesses: Foreign companies that are VAT-registered in Denmark are also in scope. Initially, non-established businesses without a permanent establishment in Denmark were not given a fixed compliance date, but recent rules indicate that from 1 January 2026, even foreign companies registered for VAT in Denmark (with local taxable activities) and exceeding the DKK 300,000 turnover threshold must use a compliant digital bookkeeping system. In other words, foreign entities making taxable supplies in Denmark (even without a fixed establishment) are expected to adhere to the e-invoicing and digital record-keeping mandates by 2026 if they meet the turnover criteria. [fiscal-req…ements.com], [fiscal-req…ements.com]
• Exemptions & Special Cases: Very small enterprises below the annual revenue threshold of DKK 300,000 are presently exempt from the digital bookkeeping system mandate. Such micro-businesses (classified as Class A in Danish accounting terminology) that remain under this threshold are not yet required to implement e-invoicing or certified digital systems until further notice. Additionally, certain non-profit associations or businesses with no VAT obligations might fall outside the scope of VAT e-invoicing entirely (since VAT invoices are only required for taxable transactions). There are no sector-based exemptions explicitly written into the e-invoicing legislation – all industries are generally covered. However, some public sector entities and purely non-commercial bodies (e.g. small charities or associations with only exempt activities) that are not VAT-registered would not be “taxable persons” and thus not subject to VAT invoicing rules. [fiscal-req…ements.com] [taxation-c….europa.eu]
  • The law provides flexibility for phased compliance (see Section 3), but no optional/alternative compliance models are prescribed beyond using a compliant digital system. Businesses can choose any certified software or service provider that suits their needs – from enterprise ERPs to simple cloud accounting platforms – as long as it meets the official requirements. In summary, Denmark’s mandate is designed to eventually encompass all VAT-registered businesses, domestic or foreign, above a low turnover threshold, with only the smallest entities and purely non-VAT operations effectively carved out (at least in the initial phase). [sovos.com], [basware.com]

3. Implementation Timeline
   Denmark’s move to mandatory digital bookkeeping and e-invoicing capabilities is being rolled out in phases from 2023 through 2026, as stipulated in the 2022 Danish Bookkeeping Act (adopted 19 May 2022). Key milestones include: [ec.europa.eu], [ec.europa.eu]

• May 2022 – Legislative Adoption: The Danish Parliament passed Law No. 700 of 24/05/2022 (Bogføringsloven) – the Bookkeeping Act – which set the legal foundation for mandatory digital accounting systems, e-invoicing capability, and electronic record-keeping for businesses in Denmark. This law aimed to modernize bookkeeping, fight fraud, and align with EU digital initiatives. [ec.europa.eu]
• Early 2023 – Preparatory Phase: By 1 February 2023, new digital reporting regulations took effect. Companies were required to notify the Danish Business Authority by 31 October 2023 about their chosen digital bookkeeping system in order to register it for compliance. This allowed time for software providers and companies to prepare for the transition (e.g. obtaining certification for software solutions). There was a voluntary/pilot period in late 2023 for businesses to begin upgrading systems and for providers to get standard systems registered (“certified”) with authorities. No broad transaction-level reporting was required during this phase – the focus was on readiness (system registration and compliance planning). [fiscal-req…ements.com] [fiscal-req…ements.com], [edicomgroup.com]
• Starting 2024 – Phased Rollout for Large Companies: The first set of businesses had to comply from 2024. Specifically:
  • Q1 2024: Large enterprises (generally, Class C and D companies that must file annual reports) using “standard” accounting software were originally expected to begin using registered digital bookkeeping systems by the start of 2024. (Regulatory adjustments effectively gave most companies until mid-2024; see below.) [cleartax.com]
  • Mid 2024: By 1 July 2024, medium and large companies using a standard (off-the-shelf) digital bookkeeping system needed to migrate to a certified digital system and start keeping records electronically from the beginning of their next financial year. In practice, for companies on a calendar fiscal year, this meant full compliance effective 1 January 2025 for standard solutions. This mid-2024 milestone was effectively a grace period extension from an earlier plan of January 2024, giving businesses and software providers additional time (6 months) to ensure standard software was registered and compliant. [e-invoicin…asware.com], [fiscal-req…ements.com]
  • Start of 2025: By 1 January 2025, large enterprises using custom-built or non-standard bookkeeping systems (e.g. in-house ERP systems not pre-certified by the authority) had to comply. From the start of the first financial year beginning on or after 1 Jan 2025, these companies must use a digital bookkeeping system that meets the new requirements. This deadline applied broadly to all “large taxpayers… who use a specially designed or foreign bookkeeping system” and ensured that even those with tailored software were compliant by 2025. By this point, digital record-keeping and e-invoice capability became mandatory for all sizeable Danish businesses (generally those obliged to file annual accounts). [e-invoicin…asware.com], [e-invoicin…asware.com] [e-invoicin…asware.com] [kpmg.com], [kpmg.com]
• March 2025 – Further Legal Developments: New requirements under the Bookkeeping Act were fine-tuned or expanded. For example, from 1 March 2025, the Business Authority mandated that all accounting data must reside in certified cloud-ready systems (no local-only storage for active records) to facilitate real-time data availability and future digital reporting. Additionally, by mid-2025 the Danish authorities released updated technical specs (e.g. a draft SAF-T 2.0 schema in August 2025) and postponed the planned OIOUBL 3.0 rollout (initially expected in April 2025) to allow more testing (see below). [ec.europa.eu], [ec.europa.eu]
• Late 2025 – E-Invoice Format Update: The Danish Business Authority prepared a significant update to the national e-invoicing standard. OIOUBL 3.0, an enhanced UBL-based format including new invoice types and structured response messages, was introduced as a Release Candidate in October 2025. It was initially slated to become mandatory for use in B2G and other e-invoicing by 15 November 2025, with the older OIOUBL 2.1 to be deprecated by May 2026. However, after stakeholder feedback, the full transition to OIOUBL 3.0 was delayed (final rollout moved to October 2025) and ultimately cancelled in January 2026 in favor of maintaining stability and focusing on the core digital bookkeeping implementation. Thus, as of 2026, the accepted e-invoice syntaxes remain OIOUBL 2.1 (with national CIUS extensions) and Peppol BIS 3.0, both compliant with EN 16931 standards. [e-invoice.app] [ec.europa.eu]
• January 2026 – Full Mandate for Remaining Businesses: By 1 January 2026, all other businesses above the small-business threshold (DKK 300,000 annual turnover) must comply with the Bookkeeping Act’s digital requirements. This final phase captures smaller enterprises and any VAT-registered entities not previously covered, including “personal ownership” businesses (Class A sole proprietorships) and certain financial or nonprofit entities that are exempt from annual reporting but exceed the revenue threshold. From 2026 forward, virtually all active Danish businesses (and foreign registrants meeting the criteria) need to use digital bookkeeping systems capable of e-invoicing and SAF-T output. [ec.europa.eu], [fiscal-req…ements.com] [fiscal-req…ements.com], [fiscal-req…ements.com]
• July 2026 – In-House System Grace Period: Companies that were using self-developed (“in-house”) accounting systems were granted an additional grace period until 1 July 2026 to achieve full compliance. This extension recognizes the extra effort needed to upgrade custom IT systems. By mid-2026, even these companies must be fully compliant – marking the completion of the phased rollout. [ec.europa.eu]
• Beyond 2026: While no further national phases are scheduled, Denmark’s trajectory aligns with broader EU plans. Notably, the EU’s upcoming 2028–2030 deadlines (under the ViDA reforms) will introduce mandatory e-invoicing and “digital reporting” for cross-border EU transactions by 2030. Denmark is expected to integrate these requirements, meaning additional obligations (such as near-real-time reporting of EU sales/purchases data to tax authorities) could come into effect by 2028–2030. The Danish authorities are actively participating in these harmonization efforts, but as of early 2026 they have not announced any separate domestic continuous transaction control (CTC) system beyond the requirements already described. [e-invoice.app], [sovos.com]

4. Technical & Functional Requirements
   E-Invoice Specifications:

• Formats and Standards: Danish e-invoices must adhere to approved structured formats. The primary formats are OIOUBL (OFFENTLIG Information Online UBL) – the national XML standard based on Universal Business Language 2.0/2.1, and Peppol BIS Billing 3.0 (the Pan-European Public Procurement On-Line standard). These formats comply with the European Norm EN 16931 semantic model for e-invoices, ensuring all required data fields are present and interoperable across EU systems. Public authorities in Denmark are obliged to accept invoices in the EN 16931 format, and in practice OIOUBL (currently version 2.1) and Peppol BIS 3 are the accepted syntaxes for B2G invoicing. (OIOUBL 3.0, an updated UBL format with enhanced features, was developed and published in 2024 but as of 2026 its rollout has been put on hold by the authorities.) [fiscal-req…ements.com], [basware.com] [ec.europa.eu], [edicomgroup.com]
• Mandatory Invoice Content: Danish VAT invoices – whether electronic or paper – must contain all information required by the EU VAT Directive and Danish VAT Act. The e-invoice formats (OIOUBL/Peppol) are designed to capture these mandatory fields in structured form. Key data elements include:
  • Seller identification (name, address, CVR/VAT number) and buyer’s identification (name, address, and if B2B, their VAT number). [taxation-c….europa.eu], [taxation-c….europa.eu]
  • Invoice number (a sequential, unique identifier for the invoice) and invoice date. [taxation-c….europa.eu]
  • Line item details, including description of goods/services supplied, quantities, unit prices, and any discounts or rebates. [taxation-c….europa.eu]
  • Tax details, including the applicable VAT rate(s) for each line, the amount of VAT charged, or an explicit notation of any exemption or zero-rating (with reference to the legal provision allowing it) if no VAT is charged. The invoice should also show the net amount (tax base) and gross amount payable. [taxation-c….europa.eu]
  • Customer’s VAT ID and a statement of tax shift if the supply is subject to reverse charge (in which case the invoice must include the phrase “reverse charge” in accordance with EU rules). For example, services or goods where the buyer must account for VAT will have this indicated on the e-invoice. [taxation-c….europa.eu]
  • Reference to any special schemes if relevant (e.g. “Margin scheme – travel agents” or “Second-hand goods – margin scheme” for supplies under those regimes). [taxation-c….europa.eu]
  • Payment details (bank account, due date) are typically included as well, though not a VAT law requirement, and e-invoice schemas allow these details.
    E-invoices in Denmark use standardized code lists and data fields to ensure all required information is present. The NemHandel/Peppol networks rely on these structured fields to validate invoices. For instance, tax categories in the XML must be properly labeled (standard codes exist for standard-rated, zero-rated, exempt, etc.), and certain optional fields become mandatory in specific scenarios (like the reason for tax exemption or indication of self-billing must be provided if applicable). This guarantees that each e-invoice carries the data needed by both trading parties and the tax authorities for compliance and audit purposes. [taxation-c….europa.eu]
• E-Reporting Format (SAF-T): The primary “e-reporting” data format in Denmark is the SAF-T (Standard Audit File for Tax). Under the Bookkeeping Act, compliant digital systems must be capable of producing a SAF-T file on demand for tax audits. The Danish SAF-T is based on the OECD’s XML schema and includes a comprehensive data model of a company’s financial records. The current specification (version 2.0, as updated in 2025) defines 19 data sections (ledgers) covering: general ledger accounts, customer and supplier (accounts receivable/payable) ledgers, tax/VAT declarations, inventory movements, fixed assets, and more. Each SAF-T file must contain mandatory master data (e.g. company identity, VAT number, software details) and detailed transaction data for the period or scope requested by the authorities. While the SAF-T does not have to be filed periodically in Denmark, the data structure is used as a standardized electronic report to facilitate tax inspections. (For example, if audited, a business must export its financial records for the audited period in SAF-T format for submission to the Skattestyrelsen tax agency.) [kpmg.com], [kpmg.com] [edicomgroup.com], [edicomgroup.com] [edicomgroup.com] [kpmg.com], [edicomgroup.com]
• Validation & Integrity Requirements: Digital signatures on e-invoices are not mandatory in Denmark. Instead, authenticity and integrity of origin are ensured through business controls and the secure transmission via NemHandel/Peppol networks. When using NemHandel/Peppol, messages are exchanged over a secure, certified channel; this satisfies the requirement that the invoice’s contents remain tamper-proof and verifiable. Companies must also implement internal controls to guarantee the accuracy of e-invoice data and safeguard their accounting records. Data integrity and readability must be preserved for the entire retention period (see Section 9). Moreover, the Danish Business Authority has provided technical validation tools and guidance to help businesses ensure their e-invoice files meet the required format and data standards before transmission. In summary, while no specific digital signature or clearance by the tax authority is required for each invoice, the systems in place enforce format compliance and security to maintain trust in the electronic invoices and reports. [fiscal-req…ements.com] [avalara.com], [basware.com] [basware.com] [ec.europa.eu], [ec.europa.eu]

5. Correction of Errors in E-Invoices and E-Reporting
   E-Invoice Corrections: The Danish framework follows standard EU VAT practices for correcting invoice errors. Once an e-invoice is issued, it cannot simply be altered in the system; mistakes (e.g. wrong amount, tax rate, or buyer details) must be corrected by issuing proper adjustment documents: typically a credit note (or debit note) to cancel or amend the original invoice, followed by a corrected invoice if needed. The electronic invoice format OIOUBL supports credit notes as a specific message type linked to the original invoice. A credit note e-invoice will reference the initial invoice number and date, and negative line item values or adjustments as appropriate. Companies should ensure their digital bookkeeping system can issue credit memos in the required format and transmit them via NemHandel/Peppol just like a regular invoice, so the buyer and (if applicable) the tax authority receive the updated information. In practice, for a minor error (e.g. a typo or an incorrect detail that does not affect tax amounts), a credit note plus re-issued invoice is the safest approach to maintain clear audit trails. Public-sector (B2G) invoices that contain errors or non-compliant data will typically be automatically rejected by the recipient’s system. In such cases, the supplier must correct the mistake and resubmit a new e-invoice, which will have a new invoice number and reference the cancelled document if relevant. Notably, in May 2025 the Danish Tax Agency introduced simplified procedures for VAT corrections: if a business overcharged VAT by mistake, they may now obtain a refund from the tax authority once they issue a correcting credit note, without needing to prove the customer was reimbursed (this was a change from prior practice). This underscores that issuing proper credit notes for errors is essential to both commercial and tax compliance in Denmark. [vatcalc.com], [taxation-c….europa.eu] [taxation-c….europa.eu] [avalara.com] [vatcalc.com]

E-Reporting Corrections: Since Denmark does not yet require ongoing e-reporting of invoice data to the tax authority (beyond standard VAT returns), the concept of correcting “submitted reports” mainly applies to correcting one’s accounting records or VAT filings if an error is discovered. Under the digital bookkeeping regime, if a company identifies a mistake in its recorded transactions or an earlier provided SAF-T file, the company should rectify the entries in the digital bookkeeping system and, if necessary, submit an updated report to the authorities. For example, if a VAT return was filed with incorrect figures, the business must typically submit a corrected VAT return for the period or adjust it in a subsequent period, as per Danish VAT Act procedures (the Danish Tax Agency provides guidance on correcting VAT returns via its online system). In the context of SAF-T, if an error is found in a file that has been provided to the tax authorities during an audit, the business should generate a revised SAF-T file with the corrections and supply it to Skattestyrelsen, along with an explanation of the changes. The Bookkeeping Act does not prescribe a separate form solely for e-reporting corrections; standard tax administration rules apply (e.g. using the normal amendment process for VAT/Sales tax returns). It’s important to keep documentation of any corrections (audit trail), such as internal notes or metadata in the accounting system showing when and how an entry was corrected. If Denmark in the future implements a real-time e-reporting system for invoice data, it is expected that specific correction mechanisms (such as submitting adjustment reports or replacing/cancelling e-invoice records in the central system within a given timeframe) will be defined by the authorities. Until then, timely communication with the tax authority in case of significant errors is advised. Companies should correct errors as soon as detected to minimize compliance risk, and retain evidence of the correction (e.g. credit notes, amended returns) in their digital archives for at least 5 years in case of inspection. [vatcalc.com], [kpmg.com]

6. Transmission & Workflow
   Submission to Authorities: Denmark’s model for e-invoicing emphasizes interoperability networks rather than a single “clearance” portal. For B2G invoices, there is a central exchange infrastructure: the NemHandel platform, which acts as a national e-invoice gateway for public sector transactions. All invoices to public authorities must be sent in real-time via NemHandel (or via the Peppol network, which Denmark integrated with NemHandel) – this ensures government entities receive structured invoices directly into their financial systems. Notably, NemHandel functions as a four-corner model network: suppliers connect via accredited service providers or software solutions (Access Points) to transmit invoices to the public authority’s Access Point. There are 100+ certified e-invoicing solutions and 30+ providers connected to NemHandel, catering to various company sizes and needs. For B2B invoices, since no real-time clearance by tax authorities is mandated, the exchange typically occurs directly between businesses using the same infrastructure (NemHandel/Peppol) on a voluntary basis. Businesses can choose to route their B2B e-invoices through Peppol Access Points or other certified service providers, ensuring that the invoices meet the required format and security standards. This interoperability model means a Danish company can send a compliant e-invoice to any domestic or foreign trading partner that has a Peppol or NemHandel access point, without a government portal intervening in every transaction. There is no requirement to upload B2B invoices to a tax portal at the time of issuance; compliance is monitored through the requirement that the system itself is certified and capable of producing records for audit. [fiscal-req…ements.com], [fiscal-req…ements.com] [ec.europa.eu] [ec.europa.eu], [ec.europa.eu] [edicomgroup.com], [sovos.com] [kpmg.com], [kpmg.com]

• Deadlines for Transmission: Under the B2G mandate, electronic invoices should be sent to public authorities at the time of invoicing – in practice this means suppliers must submit the e-invoice as soon as goods or services are delivered and the invoice is issued, in line with normal invoicing timelines (typically no later than the 15th of the following month per VAT law). The NemHandel system delivers invoices almost instantly. If a B2G e-invoice is not in the correct format, it will fail validation and be rejected, potentially preventing timely payment. Thus, effectively Denmark operates a “post-audit” system for B2G e-invoicing – invoices are delivered through a central network and must meet format requirements to be accepted, but they are not individually approved by tax authorities prior to being considered valid (unlike a full clearance model). For B2B and B2C transactions, there is no real-time government reporting or clearance requirement as of 2026. Businesses may exchange invoices in real-time via their chosen e-invoicing provider, or even continue to use PDF/paper where acceptable, as long as their bookkeeping system captures the data electronically. [taxation-c….europa.eu] [avalara.com]
• Periodic Reporting: Denmark has not introduced T+1 or periodic e-invoice reporting for domestic transactions. Instead, the focus is on maintaining complete digital records that can be summarized in periodic VAT returns (which in Denmark are typically filed quarterly or monthly, depending on turnover) and being able to export data for audits. There is no requirement for supplementary monthly transactional listings to be submitted under the new system – the traditional VAT return and EU sales list (VIES) suffice, supported by the company’s digitally stored transaction data. Looking ahead, if Denmark aligns with EU-wide digital reporting, we may see near-real-time “transactional reporting” for cross-border invoices after 2028 as part of the ViDA reforms, but as of now, no local continuous transaction control (CTC) or e-reporting mandates are in force beyond the readiness to produce SAF-T files on request. [sovos.com] [kpmg.com], [edicomgroup.com]
• Workflow for E-Invoicing: To issue an e-invoice in Denmark, a typical workflow is: (1) The supplier prepares the invoice in their ERP or accounting system, ensuring all required fields are filled. (2) The system formats the invoice as a compliant XML file (OIOUBL or Peppol BIS) and sends it through a certified Access Point or through the supplier’s software’s integration to NemHandel/Peppol. (3) The invoice is transmitted via the network to the buyer’s Access Point, identified by a unique address (often the buyer’s EAN/GLN or VAT number in the network). (4) The buyer’s system receives the e-invoice, validates it, and if successful, the invoice is entered into their accounts payable workflow. For B2G, the NemHandel platform ensures that the invoice reaches the correct public authority’s financial system. The entire process is typically automated and occurs within seconds or minutes. Denmark supports several methods of connecting to this network: large companies often use fully integrated ERP solutions or middleware; smaller businesses may use either simplified software provided by certified vendors, the open-source tools and libraries provided by the Danish Business Authority, or a web-based invoicing portal for manual entry of invoices. [cleartax.com], [cleartax.com] [cleartax.com]
• Workflow for E-Reporting: Since there is no continuous e-reporting, the “workflow” is limited to ensuring that all transactions are entered into the digital system promptly and accurately. The Bookkeeping Act requires that transactions be recorded without undue delay and with a clear audit trail linking each transaction to supporting documents (invoices, receipts, etc.). In case of an audit or request, the company will generate a SAF-T file from its system and transmit it to the tax authority (e.g., via a secure upload). This SAF-T generation is not a recurring submission but a responsive process when authorities need to examine the records. Thus, the onus is on businesses to keep their digital books up-to-date so that any required report can be produced on short notice. [kpmg.com]

7. Self-Billing

• Permissibility: Denmark allows self-billing arrangements, as governed by EU-wide VAT rules. Self-billing means the customer (buyer) issues the invoice on behalf of the supplier. In Denmark (an EU member state), this practice is legal under the EU VAT Directive as long as certain conditions are met. [tipalti.com], [taxation-c….europa.eu]
• Conditions and Requirements: A prior mutual agreement is required – the supplier must agree in writing that the buyer will issue invoices on its behalf. The agreement should typically define the period it covers and procedures for approval of invoices. The supplier must be VAT-registered and both parties need to exchange valid VAT identification details. Self-billed invoices must contain all the mandatory information of a standard invoice (seller and buyer details, VAT number, invoice date/number, description, amounts, VAT breakdown, etc.) and additionally must be marked with the phrase “self-billing.” This is a requirement under EU and Danish rules to indicate why the supplier did not issue the invoice. [tipalti.com] [taxation-c….europa.eu], [taxation-c….europa.eu]
• Use of E-Invoicing Platform: If a transaction under a self-billing arrangement falls under Denmark’s e-invoicing scope (for example, a Danish buyer self-billing on behalf of a supplier for a B2G supply or, in the future, B2B transactions when generally mandated), the self-billed invoice must be exchanged through the same electronic platforms (NemHandel/Peppol) in the standard format. There is no exemption for self-billing: the buyer’s system would generate a compliant OIOUBL or Peppol BIS invoice in the name of the supplier and send it via the Access Point network just as any other e-invoice. The buyer effectively acts as both the issuer and recipient in the e-invoicing workflow: it issues the invoice to itself (or to the customer entity), and a copy is made available to the supplier for their records. The supplier is typically required to approve each self-billed invoice to ensure the details are correct – in an e-invoicing scenario, this might be done via an electronic workflow or mutual agreement that the supplier will accept all self-billed invoices unless disputed within a certain timeframe.
• Buyer-side Validation & Content Rules: In a self-billing scenario, the buyer (invoice issuer) must ensure the invoice complies with all content requirements (since they bear responsibility for the accuracy of the invoice they create). That includes correctly charging VAT when applicable or applying the reverse charge if appropriate, and including references to any VAT exemptions or special schemes just as a normal invoice would. The structured e-invoice format accommodates these needs. Self-billing does not change the tax point or deadlines for invoicing – the buyer must issue the invoice within the normal timeframe (generally within 14 days of the supply in Denmark). [tipalti.com], [tipalti.com] [invoicesolid.com], [invoicesolid.com]
• Restrictions & Notifications: There are no additional Danish-specific restrictions on self-billing beyond the EU requirements. Notably, if either party’s VAT number changes or a new VAT registration arises, a new self-billing agreement is required. Both parties should maintain copies of the self-billing agreement as part of their records. The Danish tax authority does not require a specific notification or approval for each self-billing agreement, but all self-billed invoices are subject to the same audit and retention rules as regular invoices. Therefore, businesses engaged in self-billing should be prepared to present the agreements and demonstrate how their systems ensure only agreed-upon self-billed invoices are processed. In summary, self-billing is allowed and can even be used within the e-invoicing framework, provided that the above conditions are met to safeguard tax compliance and the integrity of the invoicing process. [tipalti.com], [tipalti.com]

8. Triangulation & Special Scenarios
   Denmark’s e-invoicing and digital reporting framework does not single out specific cross-border or complex VAT scenarios for different treatment; such transactions are generally handled according to standard EU VAT rules, with appropriate information captured in the invoice and accounting records:

• Triangulation Transactions: In EU “triangulation” (three-party chain transactions under EU VAT simplification rules), the intermediate supplier’s invoice to the final customer must include a reference to the triangulation arrangement (often by stating “VAT: Article 141 – Triangulation, reverse charge” or similar wording) to indicate that the VAT is being accounted for by the final customer. Under Danish VAT law (aligned with the EU Directive), this reference is required on the invoice, but there is no prohibition on issuing such invoices electronically. In practice, a Danish company acting as the intermediary in a triangulation must still issue a compliant invoice (paper or electronic) to the final buyer fulfilling the content requirements (including the phrase “reverse charge” to denote the buyer’s tax liability). The e-invoicing systems can accommodate this via the standard “tax category code” for reverse charge intra-EU supplies. Thus, triangulation invoices can and should be e-invoiced when the mandate applies, just ensuring that the necessary informational elements (buyer’s VAT ID, reference to “reverse charge” etc.) are present. All legs of a chain transaction – whether domestic or cross-border – should be documented with invoices. If any leg of the supply involves a Danish public authority, that particular invoice must be electronic. Otherwise, for purely private-sector transactions, e-invoicing remains voluntary (until future mandates) – though voluntary use is encouraged to streamline processing of such complex transactions. [taxation-c….europa.eu]
• Cross-Border B2B Transactions: For now, Denmark has no real-time cross-border e-reporting of B2B sales/purchases (unlike, say, the Italian Sistema Tessera Sanitaria or the Spanish SII for domestic sales – Denmark hasn’t implemented such systems). Instead, companies continue to report intra-EU transactions via the EU Sales List (VIES) and import/export via customs & Intrastat, while maintaining those transactions in their digital books. For cross-border invoices, Danish businesses can use electronic invoicing on a voluntary basis through Peppol/NemHandel, enhancing efficiency in international trade. No additional fields beyond the usual are mandated specifically for cross-border scenarios; however, the VAT treatment must be correctly indicated: e.g., intra-Community supplies (goods sold from Denmark to a VAT-registered buyer in another EU country) are typically zero-rated with the customer’s VAT ID on the invoice, and exports outside the EU are zero-rated as well – these invoices should mention the applicable VAT exemption clause or at least clearly indicate “0% VAT – export” or “intra-Community supply” on the invoice. If a Danish company receives a service from an EU supplier under reverse charge, the foreign supplier’s invoice (which may or may not be electronic, depending on that supplier’s country rules) should state “reverse charge”, and the Danish recipient must account for VAT; the transaction must still be recorded in the Danish company’s digital system for inclusion in SAF-T and VAT returns. Future EU obligations (from 2028 onward) will likely require Danish businesses to electronically report details of cross-border B2B sales and purchases in (near) real-time. In anticipation, the Danish system is being aligned with these standards, but until those are in effect, cross-border transactions are handled with existing VAT reporting mechanisms. [fiscal-req…ements.com], [fiscal-req…ements.com] [taxation-c….europa.eu] [sovos.com], [e-invoice.app]
• Chain Transactions & Domestic Reverse Charges: For chain transactions (multi-party movements of goods within or outside Denmark), each transaction between parties is treated separately for invoicing. Denmark’s VAT rules require an invoice for any domestic B2B supply, including where a domestic reverse-charge mechanism applies (for example, certain supplies in the construction sector are subject to domestic reverse charge). In such cases, the supplier’s invoice must include the notation “reverse charge” (indicating the buyer will handle the VAT). Under the e-invoicing standards, there are dedicated fields to mark a line item or invoice as reverse-charged or exempt, so digital invoices can handle these scenarios. There is no need for paper invoicing – an electronic invoice can just as easily include the required text and tax category codes. All parties in a chain must retain their invoices (in digital form if applicable) for audit. [taxation-c….europa.eu]
• Zero-Rated & Exempt Supplies: Supplies that are VAT-exempt or zero-rated (such as exports, certain financial services, education, etc.) are not excluded from e-invoicing obligations when they involve B2G or (eventually) mandated B2B exchanges. The key requirement is that the invoice clearly indicates the nature of the exemption or 0% VAT rate. The EU law requires a reference to the legal provision or a phrase indicating the exemption on the invoice – for instance, an export invoice might state “VAT exempt – export (Section 34 of VAT Act)” or an invoice under reverse charge would state “reverse charge”. E-invoice schemas support these via standard fields (e.g., the <TaxCategory> element in the XML can specify codes like “Z” for zero-rated, and an additional text field can carry the reason or directive reference). These special scenarios do not change the requirement to issue (and archive) an invoice. The SAF-T reporting format also requires that such transactions be identified in the data (e.g., marking transactions with 0% VAT or reverse charge in the tax information segments), ensuring that when authorities review the data, they can see how these special cases were treated.
  In summary, Denmark’s digital compliance system is versatile enough to handle complex VAT scenarios – businesses must continue to follow existing VAT rules for these transactions (including necessary invoice annotations for self-billing, reverse charges, margin schemes, etc.), and ensure their digital systems correctly capture the details, but there are no additional burdens or exceptions specific to triangulation or special regimes beyond what general VAT law requires. [taxation-c….europa.eu]

9. Archiving & Retention
   Under the Bookkeeping Act and VAT law, businesses in Denmark have strict obligations to archive and retain invoices and accounting data in a secure digital form:

• Format of Archival: Records and source documents (including invoices) must be stored electronically in their original structured format. This means that an e-invoice exchanged as an OIOUBL or Peppol BIS XML file should be archived as that electronic file (not just a printed copy or PDF), in order to preserve its integrity and machine-readability. The law essentially requires digital archiving for companies under the mandate – paper-based record-keeping alone is no longer sufficient after the relevant compliance dates. Even supporting documents that originate on paper (like receipts or contracts) should be scanned and stored in the digital bookkeeping system. [basware.com], [basware.com] [fiscal-req…ements.com]
• Retention Period: Accounting records, including invoices (whether issued or received), must be kept for a minimum of 5 years after the end of the financial year to which they relate. This five-year retention period is stipulated by the Danish Bookkeeping Act and aligns with general VAT record-keeping requirements. In certain cases, a retention of up to 10 years can apply – for example, Danish guidance specifies that invoices related to long-term assets (immovable property) should be kept for 10 years, reflecting the longer period during which tax adjustments may occur for such assets. Businesses should check if any specific records they hold are subject to a 10-year retention (e.g. real estate, lease records, etc.), but for most invoices and VAT records, 5 years is the standard. [basware.com] [fiscal-req…ements.com], [cleartax.com]
• Location of Storage (Local/EU/Abroad): The Bookkeeping Act requires that electronic accounting records be stored in a manner accessible to Danish authorities. If using cloud services or external servers, the backup data must reside within the EU (or a country with equivalent data access provisions). In practice, Denmark mandates that a copy of the bookkeeping data is stored on a server within the EU to ensure regulators can obtain access if needed. Storing the sole copy of records in a non-EU (third-country) location is generally not permitted unless additional measures are in place to guarantee Danish authorities’ access and the data’s integrity. Many companies use local servers or EU-based cloud providers to comply with this rule. [kpmg.com]
• Integrity, Authenticity & Readability: Throughout the retention period, companies must guarantee the integrity and authenticity of the archived invoices. This means the content of an invoice cannot be altered once issued, and it must remain readable and accessible to auditors in a legible format for at least 5 years. Electronic archiving solutions often use access controls, audit logs, and checksums or digital signatures to ensure stored invoices aren’t tampered with. It is also important that the metadata linking invoices to accounting entries and possibly to SAF-T exports is preserved. Danish law doesn’t prescribe a specific format for long-term storage (e.g., PDFs or XML are acceptable), but since the working databases must be digital, in practice the invoices will already be in an electronic format. Audit Accessibility: If requested by the tax authorities or the Business Authority, companies must be able to retrieve and present their archived invoices and related records without delay. The requirement of using standard formats (like OIOUBL XML and SAF-T) is intended to facilitate easy sharing and reviewing of data. In sum, companies should implement robust digital archiving, ideally using either their certified bookkeeping system’s built-in archive or a compliant e-archiving service, to meet Danish rules. Non-compliance with archiving obligations (e.g., failing to retain invoices, or not ensuring their integrity/readability) is an offense that can result in penalties (see Section 10). [basware.com] [kpmg.com] [fiscal-req…ements.com]

10. Penalties & Enforcement
    Denmark has established strict penalties to ensure compliance with e-invoicing and digital bookkeeping requirements. Enforcement involves both administrative oversight by the Danish Business Authority and potential audits by the Danish Tax Agency, with sanctions for non-compliance as follows:

• Failure to Issue E-Invoices (B2G): If a supplier fails to send a required electronic invoice to a public authority, the immediate consequence is practical: the invoice will not be accepted or paid. Public sector systems reject non-electronic or non-compliant invoices, leading to payment delays. Repeated failure to use e-invoicing for B2G transactions can result in breach of contract penalties, potential exclusion from future public procurement contracts, and administrative fines. While the law doesn’t specify a fixed fine per invoice for B2G non-compliance, public entities have the right to refuse payment until a proper e-invoice is received, which serves as a strong incentive. [avalara.com]
• Non-Compliance with Digital Bookkeeping Requirements: The Bookkeeping Act includes explicit penalty provisions. Companies that do not implement a compliant digital bookkeeping system by the deadlines (see Section 3), or that disable required features (e.g. failing to store data electronically, not having e-invoice/SAF-T capability, or not using a certified system when required), face significant fines. The law authorizes fines of up to DKK 1.5 million (approximately €200,000) for serious or repeated violations of the digital bookkeeping rules. The Danish Business Authority has indicated it will actively monitor compliance – for instance, by sending warning letters and potentially conducting inspections of businesses’ accounting systems. In an enforcement scenario, lesser offenses or first-time non-compliance might result in lower fines or orders to rectify issues by a deadline, whereas intentional or grossly negligent breaches (especially if linked to tax evasion or fraud) could attract the maximum fines. Company directors could also face legal consequences under general Danish bookkeeping and tax laws if records are not properly kept. [kpmg.com], [fiscal-req…ements.com] [kpmg.com]
• Late/Incorrect E-Reporting: As full e-reporting (real-time VAT data submission) is not yet implemented in Denmark, specific penalties for late/incorrect e-reporting per se are not in force. However, the existing VAT compliance penalties would apply if a business fails to report transactions correctly on VAT returns or recapitulative statements. For example, errors in VAT returns can trigger penalties or interest under the Danish Tax Control Act. With the SAF-T requirement, if a business cannot produce a correct SAF-T file upon audit or has significant discrepancies in its digital records, the authorities could impose fines under the Bookkeeping Act for inadequate record-keeping. Companies are expected to ensure the accuracy of their e-invoices and digital books; submitting falsified or incorrect data to the tax authority (even as part of an audit) could potentially be treated as a bookkeeping offense or tax offense, depending on intent. Prompt voluntary disclosure and correction of errors (see Section 5) can mitigate the risk of penalties.
• Non-Compliance with Platform/Format Requirements: Using a non-certified system or failing to use the mandated e-invoicing platforms where required is treated as a compliance breach. For instance, if a company were to send paper or PDF invoices to a public authority (B2G) in violation of the mandate, the invoice would be rejected and the company could be subject to administrative fines. Under the Bookkeeping Act, not using a registered digital system when required, or not having the ability to connect to NemHandel/Peppol, is an offense subject to penalties (enforced by the Business Authority). Similarly, altering the mandated structure of an e-invoice (e.g. sending a non-compliant XML or omitting required fields) can lead to rejection of the invoice and potential sanctions if not promptly corrected. [fiscal-req…ements.com]
• Archiving Violations: Failure to properly archive invoices and records for the full retention period (e.g. deleting them early, or not maintaining backups in the EU) also constitutes a violation of the Bookkeeping Act. Such violations can lead to fines. For example, if a company cannot produce required accounting records during an audit because they failed to keep them electronically for 5 years, the company may be penalized. In addition to financial penalties, auditors may flag the issue in the company’s annual report (a qualified auditor’s opinion), which can have reputational and legal ramifications. [kpmg.com], [kpmg.com]
• Intentional or Fraudulent Conduct: The penalties above (up to DKK 1.5 million) can apply to both deliberate violations and cases of serious negligence. Particularly egregious cases (e.g. willfully not keeping any records, or falsifying electronic invoices) could potentially lead to criminal charges under broader financial crime laws, but typically enforcement of the e-invoicing/digital bookkeeping mandate is handled via administrative fines. The Danish authorities have signaled increased oversight (“skærpet tilsyn”) under the new law, including using risk-based selection for audits and cross-checking VAT returns against SAF-T data or e-invoices where available. Companies are therefore strongly encouraged to comply proactively. [fiscal-req…ements.com], [fiscal-req…ements.com]
• Relevant Legal References: The legal basis for these penalties can be found in Chapter 5 of the Bookkeeping Act (Lov om bogføring) and associated executive orders. For example, Section 37 of the Bookkeeping Act authorizes fines for violations of the digital bookkeeping system requirements. The specific B2G e-invoicing mandate is established by Executive Order (Bekendtgørelse) nr. 354 of 2013, updated by Bek. nr. 766 of 2019 and Bek. nr. 937 of 2021, which mandate public institutions to receive e-invoices and suppliers to use NemHandel. Additionally, Denmark’s VAT Act (Momsloven) contains general penalty provisions for failing to issue invoices or issuing incorrect invoices. In practice, enforcement to date has focused on ensuring companies implement the required systems; as of late 2025 the Business Authority had begun contacting companies about the impending 2025–26 deadlines and the potential for fines or audits if they do not upgrade their bookkeeping procedures. [ec.europa.eu], [ec.europa.eu] [kpmg.com], [kpmg.com]

11. Pre-Filled VAT Returns
    As of early 2026, Denmark does not yet provide pre-filled VAT returns to taxpayers, nor has it implemented an automated system of populating periodic VAT returns with invoicing data. The current VAT return filing process remains largely manual (or handled via businesses’ own accounting software) – taxpayers must compile their sales and purchase figures from their records and submit the VAT return through the online TastSelv Erhverv portal in the usual way. The new digital bookkeeping requirements do not include any immediate mechanism for tax authorities to pre-populate VAT returns from e-invoices or SAF-T data. However, the long-term direction in Denmark and the EU suggests movement towards greater automation of tax compliance:

• No Current Pre-population: Unlike some countries (e.g. Italy, which uses e-invoice data to pre-fill VAT returns and ledgers), Denmark has not introduced pre-completed VAT returns using live invoice data. Businesses must continue to calculate their VAT due and file returns as before. The structured data captured in e-invoices and accounting systems is primarily for the businesses’ own record-keeping and for potential audits, rather than for real-time submission to automatically fill returns.
• Planned Developments: The Danish authorities have indicated interest in leveraging digital records for tax administration efficiency in the future. For example, once all companies are using digital systems and SAF-T files, it could become feasible to have the Tax Agency cross-check or even pre-fill parts of the VAT return (such as total sales, purchase, and VAT amounts) by comparing reported data with the standardized records. This, however, likely hinges on broader EU-level initiatives. Under the EU’s ViDA proposals, member states will move toward more transaction-based reporting and possibly pre-filled VAT declarations by the end of the decade. Denmark’s current efforts (e-invoicing, SAF-T, digital VAT systems) are foundational steps that could support such a development. [sovos.com]
• Data from E-Invoicing/E-Reporting: If and when pre-filled VAT returns are implemented, it would rely on data from electronic invoices and digital reports. For instance, every B2B sale’s details (net amount, VAT rate) could be reported through the e-invoicing system to the tax authority, allowing the authority to draft a VAT return for the taxpayer. Such a system would likely use the SAF-T data model or a similar continuous transaction control to aggregate sales and purchase info. As of 2026, no official start date or system for pre-populated VAT returns in Denmark has been announced. Taxpayers must review and file their own VAT returns, ensuring consistency with their e-invoice records. Any future introduction of pre-filled returns would be communicated via official channels and would still require taxpayers to verify the data and supply any missing information (e.g. adjustments, exempt supplies, imports, etc., that may not be captured by domestic e-invoices).
• Ongoing Compliance: Even without pre-filled returns, the digitization mandate can indirectly help taxpayers. By requiring detailed digital records and e-invoices, Denmark aims to improve data quality so that businesses themselves have more accurate information when preparing VAT returns. Errors can be detected earlier (through validation rules in software or by reconciling VAT returns against the bookkeeping data, which is now required by law on each filing). This reduces mistakes in returns and could speed up any subsequent VAT refund processes. In summary, while Danish authorities don’t yet pre-complete your VAT return, the e-invoicing and e-reporting reforms are laying the groundwork for a future in which tax compliance (including VAT declarations) can be more automated and less burdensome on businesses. [kpmg.com]

12. Impact on SMEs and Startups
    The Danish e-invoicing and digital bookkeeping mandate has significant implications for small and medium-sized enterprises (SMEs) and startups. The government has consciously phased the implementation to give smaller businesses more time and has introduced measures to mitigate burdens, but challenges remain:

• Phased Onboarding & Thresholds: SMEs benefit from a longer lead time. Only medium and large companies were required to comply by 2024–2025, whereas small firms (Class A, typically those without a statutory audit requirement) under DKK 300,000 turnover are exempt until at least 2026. Those slightly above the threshold have until the start of 2026 to implement digital systems, and if using in-house software, until mid-2026. This phased approach was explicitly designed to prevent overwhelming smaller businesses and allow them extra time to adapt. Startups and micro-enterprises under the turnover limit can delay investing in potentially costly systems until they grow larger (and many very small businesses may remain exempt if their revenues stay below DKK 300k). [fiscal-req…ements.com], [fiscal-req…ements.com] [ec.europa.eu], [e-invoice.app]
• Simplified Regimes & Support: Aside from the threshold exemption, Denmark has not created a separate “simplified” e-invoicing regime for SMEs – instead, the core requirements (digital record-keeping, e-invoice capability, 5-year retention, etc.) apply uniformly once the business is in scope. However, the compliance burden is moderated via market solutions. A wide range of cloud-based accounting and invoicing software (including free or low-cost versions) has emerged, many of which are pre-certified by the Danish Business Authority. SMEs can choose an affordable, standard software from the official list of registered digital bookkeeping systems provided by the authority, rather than developing their own. The Business Authority has also released technical guidelines and even open-source components to help software vendors and businesses implement e-invoicing and SAF-T support. In essence, while the law doesn’t offer subsidies, it encourages a competitive marketplace of solutions tailored to smaller businesses. Additionally, training and informational resources (guides, webinars, helpdesk support) have been provided by government agencies and industry groups to assist SMEs in the transition. [basware.com], [basware.com] [kpmg.com] [ec.europa.eu]
• Compliance Costs: The main costs for SMEs involve upgrading or acquiring a digital accounting system that meets the new standards. This might entail subscription fees for cloud accounting software, possible investment in add-on modules for e-invoicing or SAF-T, and staff training. For many small businesses, the costs are expected to be manageable because numerous vendors offer solutions at SME-friendly prices (some basic cloud bookkeeping systems in Denmark cost little or even have free tiers, especially for startups). Moreover, if an SME already uses a modern cloud accounting tool, there’s a good chance it’s on the approved list and will handle compliance updates automatically. That said, there is an initial effort required – businesses need to ensure their customer and product data are correctly set up to populate e-invoices, potentially adjust their workflows for sending invoices through new channels, and possibly pay for support or new hardware (e.g. upgrades to scanners for archiving receipts). [kpmg.com], [kpmg.com]
• Administrative Burden vs Simplification: In the short term, SMEs and startups face additional administrative tasks: selecting and implementing a compliant software, changing internal processes, and learning new systems. There may be a learning curve and some disruptions as paper-based habits are replaced with digital processes. However, the policy goal is to ultimately simplify administration. Once in place, digital invoicing and bookkeeping can reduce manual data entry, minimize errors, and shorten invoice processing times. For example, an SME that switches from paper or PDF invoices to a unified e-invoicing process might find that reconciling accounts and preparing VAT returns becomes faster and more accurate, because the data is already structured and validated in real-time. Over time, routine tasks like compiling sales ledgers or calculating tax liability should require less effort. The automation of invoice handling can free up resources that small businesses can redirect to core activities, albeit after the initial implementation phase. [fiscal-req…ements.com], [fiscal-req…ements.com]
• Cash Flow Effects: Digital invoicing can have positive effects on cash flow for SMEs. Faster invoice processing – especially when dealing with large customers or public bodies – can lead to quicker payments. Public authorities in Denmark already pay e-invoices quickly once approved, and the electronic process eliminates postal delays and reduces disputes (since e-invoices have fewer errors due to format validations). Also, by enforcing real-time recording of transactions, the new systems help SMEs spot VAT errors early (e.g. missing an input VAT invoice or mis-posting a tax code), which can prevent cash flow surprises down the line. On the other hand, SMEs have raised concerns that the need to invest in new systems and possibly pay fees to service providers could strain their cash flow in the implementation phase. The government’s expectation is that the long-term gains (like reduced admin costs and faster VAT refunds due to accurate digital records) will outweigh the upfront expenses. [fiscal-req…ements.com], [fiscal-req…ements.com]
• Market Impact and Competitiveness: The e-invoicing mandate is accelerating the digitalization of business processes in Denmark. In the near term, this favors companies – including proactive SMEs – that quickly adapt to electronic invoicing and digital bookkeeping. Early adopters may gain a competitive edge: for instance, being able to transact efficiently with large customers (many large Danish companies prefer electronic invoices from their suppliers for efficiency, even when not legally mandated). Such firms might also benefit from improved financial transparency and data analytics in their operations. Conversely, some small businesses that delay digital adoption could face challenges in trading with e-invoice-compliant partners or might incur last-minute costs to catch up with the law. Interoperability between different software solutions is a key focus – the use of standardized formats (OIOUBL/Peppol) is meant to prevent lock-in with any single IT provider. Still, SMEs have voiced concerns (through industry associations) about possible complexity in choosing and integrating the right software and ensuring it works with their partners’ systems (interoperability is handled by the network, but businesses must still choose an access point or software provider). [e-invoicin…asware.com], [e-invoicin…asware.com]
• Readiness and Support: The Danish government has acknowledged the challenges for SMEs. As of late 2025, surveys indicated that many small firms were aware of the upcoming requirements but not yet fully prepared to comply, prompting additional outreach by the authorities. The Erhvervsstyrelsen (Business Authority) has published detailed guidelines (vejledning) on the Bookkeeping Act and maintains a support website (in Danish) to help businesses understand the rules. There have also been informational campaigns and collaborations with accounting firms, industry bodies, and solution providers to boost SME readiness. While no direct financial subsidies were provided, the emphasis has been on enabling a market of cost-effective solutions and providing grace periods to ease the transition. The intent is that digital compliance becomes a built-in feature of doing business in Denmark, rather than an ongoing burden. Over time, as digital bookkeeping becomes the norm, SMEs should experience streamlined compliance and potentially reduced accounting costs, but the success of the mandate in the SME sector will depend on continued guidance and possibly fine-tuning of requirements based on feedback. [kpmg.com]

13. Official References
    Below is a list of authoritative sources and references related to Denmark’s e-invoicing and e-reporting framework, including government portals, legislation, technical documentation, and expert commentary:

• Danish Legislation & Official Gazette: Lov om bogføring (Bookkeeping Act), Law No. 700 of 24 May 2022, available on Retsinformation. This is the primary law mandating digital bookkeeping, e-invoicing capabilities, and SAF-T readiness for businesses. Supporting regulations include Executive Orders such as Bekendtgørelse nr. 1306/2022 and others detailing requirements for digital systems (available via the Danish Business Authority). For the B2G mandate, see Bekendtgørelse nr. 354 of 2013, as amended by Bek. 346 of 15/03/2019, which implements EU Directive 2014/55/EU on electronic invoicing in public procurement (text available on Retsinformation). [ec.europa.eu], [ec.europa.eu]
• Government Portals: The Danish Business Authority (Erhvervsstyrelsen) provides a comprehensive official guide: “Vejledning om Bogføringsloven” (Guidance on the Bookkeeping Act), last updated June 2025, which covers digital bookkeeping system criteria, registration process, and compliance deadlines. The Authority’s website also lists “Registrerede bogføringssystemer” (registered digital bookkeeping systems) – i.e., the certified software solutions that meet Danish requirements. The NemHandel official site (nemhandel.dk) contains technical specifications and tools for the national e-invoicing infrastructure, and information on the upcoming (now postponed) OIOUBL 3.0 format. The Pan-European Public Procurement Online (PEPPOL) documentation site provides details on Peppol BIS 3.0 technical standards, which Denmark accepts as a compatible e-invoice format. The Danish Tax Agency (Skattestyrelsen) offers guidance on using the E-tax for businesses system (TastSelv Erhverv) for VAT reporting and corrections, as well as information on the SAF-T (Standard Audit File-Tax) schema and how it should be generated (see the Business Authority’s SAF-T technical description 2.0 draft released in 2025). [kpmg.com], [kpmg.com] [ec.europa.eu] [tipalti.com] [kpmg.com]
• Technical Specifications: For implementers, the OIOUBL Standard documentation (v2.1 and the draft v3.0) can be obtained via the Danish Business Authority’s digitalization portal and NemHandel website. These specs include the Danish CIUS (Core Invoice Usage Specification) for EN 16931 compliance. The SAF-T DK v2.0 (Danish Standard Audit File for Tax) technical schema and guidance were published by Erhvervsstyrelsen (with updates noted in August 2025 and February 2026) – covering the data structure businesses must support. [ec.europa.eu], [ec.europa.eu] [e-invoice.app], [e-invoice.app]
• Tax Authority Publications: The Skattestyrelsen has released materials such as “Opdateret vejledning: Indberetning og korrektion af moms” (Updated guidance on VAT reporting and correction) in 2025, reflecting changes like the new approach to correcting incorrectly charged VAT via credit notes. While most official guidance is currently in Danish, the European Commission’s website provides an English summary of Denmark’s e-invoicing system under the Digital Building Blocks – including key points of the law, standards, and contact information for the Danish authorities. [vatcalc.com] [ec.europa.eu], [ec.europa.eu]
• Legislative Texts & EU Law: Denmark’s B2G e-invoicing aligns with EU Directive 2014/55/EU on electronic invoicing in public procurement. For VAT content rules, Council Directive 2006/112/EC (the EU VAT Directive) Article 226 outlines required invoice particulars, and Article 219a allows electronic invoices given authenticity and integrity – these are reflected in Danish law. The upcoming EU proposal under “VAT in the Digital Age” (COM(2022) 703 final) will amend the VAT Directive to require e-invoicing for cross-border transactions; Denmark will implement these by the stipulated dates (likely 2028–2030). [ec.europa.eu] [sovos.com]
• Newsletters & Expert Analyses: Several global and local advisory firms have published analyses of Denmark’s e-invoicing reforms. Notable examples include: KPMG Acor Tax’s insight “Digital bookkeeping requirements in Denmark” (Oct 2025) highlighting who is in scope and what systems must do; Basware’s compliance blog “New E-Invoicing Mandate in Denmark” (Dec 2024) discussing key dates and format requirements; Sovos’s article “Denmark E-Invoicing” (2025) with a timeline and overview of B2G and B2B mandates; and VATupdate.com and Fiscal Solutions (fiscal-requirements.com) which regularly provide updates on Denmark (e.g. summaries in Nov 2024 and mid-2025 covering new bookkeeping rules and the postponement of OIOUBL 3.0). Additionally, software providers like EDICOM and Storecove have published whitepapers on the Danish Bookkeeping Act and e-invoicing status. These resources can be consulted for detailed interpretations and practical guidance, but for official requirements, the Danish statutory sources and official guidelines remain the primary reference. [kpmg.com], [kpmg.com] [e-invoicin…asware.com], [e-invoicin…asware.com] [sovos.com], [sovos.com] [vatupdate.com] [edicomgroup.com]

14. Summary
    Denmark’s adoption of e-invoicing and e-reporting is part of a broader push towards digitalization of business records and tax compliance. Below is a high-level overview of the framework and its implications:

• Scope: Electronic invoicing is mandatory for all B2G transactions – any invoice issued to a Danish public authority must be electronic in the specified format. B2B and B2C invoices are not yet universally mandated to be electronic; however, under the Bookkeeping Act 2022, all businesses must have digital bookkeeping systems capable of handling e-invoices (and indeed, from 2025–26, must use such systems for their accounting). In practical terms, this means even purely private-sector transactions are moving towards e-invoicing by virtue of systems requirements, although using e-invoices for B2B/B2C remains voluntary until further notice. Special transactions (self-billed, cross-border, etc.) are included under the general requirements – there are no separate exclusions other than the basic threshold exemption for very small businesses. [ec.europa.eu] [ec.europa.eu], [sovos.com]
• Timeline: The legal basis was established in May 2022 with the new Bookkeeping Act. Implementation has been phased by company size and system type: Large companies began complying in 2024 (or by January 2025 at the latest), while smaller businesses have until 2026 to fully transition. Key dates included 1 July 2024 (start of digital bookkeeping for large firms on standard software), 1 January 2025 (for large firms on custom systems), and 1 January 2026 for SMEs above DKK 300k turnover, with a final extension to 1 July 2026 for companies using in-house developed accounting systems. These deadlines have now set the stage such that, by mid-2026, nearly all active Danish companies need to be using certified digital accounting systems with e-invoicing and SAF-T capabilities. B2G e-invoicing has been compulsory since 2005 (with an update in 2019 to adopt the EU standard). Looking ahead, Denmark will also implement upcoming EU-wide mandates for cross-border e-invoicing and reporting (expected by 2028–2030). [ec.europa.eu] [e-invoicin…asware.com], [fiscal-req…ements.com] [fiscal-req…ements.com] [e-invoicin…asware.com] [fiscal-req…ements.com] [sovos.com]
• Key Obligations: Companies in scope must use a digital bookkeeping system (certified or self-developed to meet criteria) for all financial records. They must be able to issue and receive e-invoices in the UBL-based formats (OIOUBL 2.1 and Peppol BIS 3.0), and continue to provide standard VAT content on all invoices (invoice date, number, parties, amounts, tax details, etc.). Businesses must ensure electronic storage of invoices and accounting documents for at least 5 years with proper backup and security measures. Upon request, they must generate a SAF-T audit file containing detailed transaction data for tax authorities. There is currently no routine “e-reporting” of each invoice to the tax authority, but systems should essentially keep a running digital record of VAT transactions. [kpmg.com] [basware.com], [basware.com] [basware.com], [kpmg.com] [kpmg.com], [kpmg.com]
• Main Risks of Non-Compliance: Companies that do not comply with the mandate face heavy penalties and administrative actions. The Danish Business Authority can levy fines up to DKK 1.5 million for breaches of the digital bookkeeping rules (e.g. not using an approved system, failing to maintain electronic records). The Tax Agency and Business Authority have powers to audit businesses and will be monitoring compliance actively. For B2G suppliers, not sending an e-invoice means the government customer will reject the invoice and payment will be withheld. Non-compliance may also lead to reputational damage, potential exclusion from public tenders, and complications with auditors (for instance, auditors may flag non-compliance in published accounts). On the other hand, compliance can reduce certain risks – having accurate digital records minimizes the chance of VAT errors or missing documentation in the event of an audit, thereby avoiding penalties. [fiscal-req…ements.com] [kpmg.com], [kpmg.com] [avalara.com] [kpmg.com]
• Implications for SMEs: Small businesses and startups are both a focus and a concern in this transition. The law’s phased approach gives them extra time, and there is a low revenue threshold (DKK 300k) below which the rules don’t yet fully apply. This spares the tiniest businesses from immediate costs. For those that must comply by 2026, challenges include the cost of new software or upgrades, the need to train staff, and potential short-term disruption to established invoicing processes. However, there are also opportunities: digital tools can simplify bookkeeping, reduce errors, and speed up invoice payments – benefits that are particularly valuable for small firms with limited resources. Many accounting software options exist that cater to SMEs, and the government’s certification program ensures even affordable solutions meet the necessary standards. Over time, SME adoption of e-invoicing is expected to improve efficiency and competitiveness (for example, automation of invoice processing can free up time, and being able to connect to larger trading partners via Peppol opens access to wider markets). The Danish authorities and industry groups are actively monitoring SME readiness and providing guidance, recognizing that support may be needed to bring the long tail of smaller enterprises into the digital era. [fiscal-req…ements.com] [fiscal-req…ements.com], [fiscal-req…ements.com] [kpmg.com], [basware.com]
• Critical Dates & Next Steps: Companies should mark January 2026 as the major compliance milestone – by then, all but the very smallest businesses must be fully on digital bookkeeping systems and ready to use e-invoicing and SAF-T. Those with custom IT solutions have until July 2026 at the latest to finalize compliance updates. Leading up to these dates, businesses should verify that their chosen accounting software is registered with the Danish Business Authority or that their in-house system meets all criteria (capacity for e-invoicing, digital storage, SAF-T export, etc.). It’s advisable to conduct internal audits or tests – for instance, generating a test SAF-T file and sending some test e-invoices to ensure everything works properly. The authorities will continue to issue updated technical guidance (e.g. finalizing SAF-T v2.0 standards and any future e-reporting specifications). In the coming years, Denmark will likely refine its approach in line with EU developments. Businesses should stay informed via official channels and possibly participate in any pilot programs if offered. By embracing these changes early, companies – including SMEs – can turn compliance into an opportunity, modernizing their finance operations and ensuring they are well-prepared for the fully digital VAT landscape by the end of the decade. [fiscal-req…ements.com], [fiscal-req…ements.com] [ec.europa.eu] [kpmg.com] [e-invoice.app] [ec.europa.eu], [sovos.com]

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• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
  • Briefing / Comprehensive Guides (incl. podcasts)

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

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