- Denmark has cancelled the planned OIOUBL 3.0 e-invoicing format and will instead introduce a new standard, Nemhandel BIS 4 (Nemhandel 4.0), based on EN 16931, Peppol BIS 4.0, and a PINT-like methodology.
- The transition supports the final phase of Denmark’s Digital Bookkeeping Act (2026) and future EU VAT in the Digital Age (ViDA) requirements.
- OIOUBL 2.1 will remain in use until July 2029, with technical updates and a gradual migration to Nemhandel BIS 4 starting from 2028.
- Key open questions include whether Denmark will fully migrate to the Peppol network and the final technical specifications of Nemhandel BIS 4.
- The deadline for implementing the EU ViDA e-invoicing framework is July 2030.
Source: fiscal-requirements.com
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Detailed
Overview
Denmark has announced a major overhaul of its national e‑invoicing framework. The Danish Business Authority (Erhvervsstyrelsen, ERST) has officially cancelled the planned OIOUBL 3.0 format and confirmed a transition to a single, unified e‑invoicing standard: Nemhandel BIS 4. The new standard is aligned with EN 16931 and Peppol BIS 4, with migration expected to take place between 2028 and mid‑2029. These changes are part of Denmark’s broader digitalisation strategy and its preparation for the EU’s VAT in the Digital Age (ViDA) initiative. [theinvoicinghub.com], [fiscal-req…ements.com]
Cancellation of OIOUBL 3.0: From Dual Formats to a Single Standard
In early 2026, ERST confirmed that OIOUBL 3.0 will not be implemented, reversing earlier plans to modernise the national OIOUBL format. The decision followed extensive consultations with service providers and stakeholders, which highlighted that implementing OIOUBL 3.0 would require significant development and maintenance efforts without delivering sufficient long‑term benefits. [vatupdate.com], [rtcsuite.com]
Instead of maintaining parallel national and international formats, Denmark has opted for a single-standard strategy, abandoning the long‑standing dual use of OIOUBL and Peppol BIS. This strategic shift aims to simplify compliance, reduce market complexity, and improve cross‑border interoperability. [rtcsuite.com]
What Is Nemhandel BIS 4?
Nemhandel BIS 4 (also referred to as Nemhandel 4.0) is Denmark’s future e‑invoicing standard and will be a localized implementation of Peppol BIS 4, fully compliant with the updated EN 16931 European e‑invoicing standard, whose core semantics were approved in January 2026. [theinvoicinghub.com], [fiscal-req…ements.com]
Key characteristics include:
- Alignment with Peppol BIS 4.0, developed by OpenPeppol
- Use of a PINT‑like (Peppol INTernational) methodology to support global interoperability
- Danish national extensions (CIUS‑like) to meet local legal and business requirements
- Support for both domestic and cross‑border invoicing scenarios
This approach positions Denmark to better anticipate ViDA‑driven mandatory e‑invoicing for cross‑border EU transactions from July 2030. [fiscal-req…ements.com], [kpmg.com]
Migration Timeline: From OIOUBL 2.1 to Nemhandel BIS 4
Although OIOUBL 3.0 has been cancelled, OIOUBL 2.1 will remain in force for several more years and will continue to be updated to ensure legal and technical continuity during the transition period. For example, ERST postponed the implementation of OIOUBL 2.1 schematron version 1.17.1 to 18 May 2026. [theinvoicinghub.com], [fiscal-req…ements.com]
The currently announced migration roadmap includes the following phases:
- 2026 – mid‑2027
- Finalisation of the updated EN 16931 standard
- Development of Peppol BIS 4 and PINT methodology
- Shift from an opt‑in to an opt‑out registration model in Nemhandel for companies using certified digital bookkeeping systems
- 2026 – 2027
- Stakeholder workgroups defining the technical specifications of Nemhandel BIS 4
- 2028 – mid‑2029
- Release candidate and gradual migration from OIOUBL 2.1 to Nemhandel BIS 4
- Progressive phase‑out of OIOUBL 2.1
- Mid‑2029
- Nemhandel BIS 4 becomes the primary e‑invoicing standard in Denmark
[theinvoicinghub.com], [fiscal-req…ements.com], [europe.tho…euters.com]
Public Consultation and Open Design Questions
In March 2026, ERST launched a public consultation on its new document strategy for Nemhandel, running from 12 to 27 March 2026. Stakeholders were invited to comment on the proposed transition, governance model, and technical scope of Nemhandel BIS 4. [kpmg.com]
Several issues remain open, notably:
- Whether Denmark will fully migrate to the Peppol network for invoice exchange
- The final scope of mandatory vs. optional Danish extensions
- The treatment of non‑invoice documents (e‑orders, receipts), which for now will continue to be supported in both formats
Strategic Context: Digital Bookkeeping Act and ViDA
These developments are closely linked to Denmark’s Digital Bookkeeping Act, whose final phase enters into force in 2026, requiring wide adoption of certified digital bookkeeping systems. Although Denmark does not impose a general B2B e‑invoicing mandate, businesses must ensure their systems can send and receive structured electronic invoices using approved formats. [theinvoicinghub.com], [vatupdate.com]
By converging on Nemhandel BIS 4, Denmark is also aligning its domestic framework with the EU ViDA legislative trajectory, reducing future transition risks for businesses engaged in cross‑border trade. [fiscal-req…ements.com]
What Businesses and Providers Should Do Now
- Continue supporting OIOUBL 2.1 while monitoring updates
- Track the development of Peppol BIS 4 / Nemhandel BIS 4 specifications
- Participate in consultations and stakeholder workgroups where possible
- Assess long‑term roadmap alignment with ViDA and Peppol‑based models
Briefing Document & Podcast: E-Invoicing and E-Reporting in Denmark – VATupdate
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
- Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
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