Summary
- The Danish Business Authority has consulted on amendments requiring providers of registered digital bookkeeping systems to enrol business customers automatically in the Nemhandel Register, unless the customer actively opts out. The proposed rules would apply from 1 January 2027. [hoeringsportalen.dk], [erhvervsstyrelsen.dk]
- When preparing an invoice, compliant bookkeeping systems would have to check whether the recipient is registered and, if so, present a structured e-invoice as the first delivery option. Additional requirements would strengthen identity verification, master-data integrity and the security of electronic business documents. [hoeringsportalen.dk], [erhvervsstyrelsen.dk]
- The proposal is not a general B2B e-invoicing mandate. Instead, Denmark would reverse the default setting: businesses using standard digital bookkeeping systems would become reachable through Nemhandel unless they take action to opt out. The approach offers an alternative perspective for countries such as the Netherlands, which is still considering the scope of its future ViDA e-invoicing and digital reporting framework. [hoeringsportalen.dk], [erhvervsstyrelsen.dk], [kpmg.com]
Extended article
The Danish Business Authority, Erhvervsstyrelsen, has completed a consultation on proposed amendments to the regulation governing registered digital standard bookkeeping systems. Rather than immediately introducing a general B2B e-invoicing mandate, Denmark proposes to make electronic invoicing the default option within the software used by businesses.
The consultation was published on 1 July 2026 and formally closed on 17 August 2026. The proposed effective date is 1 January 2027. The measure would amend the executive order on requirements for digital standard bookkeeping systems, commonly referred to as the kravbekendtgørelsen, which operates under Denmark’s Bookkeeping Act. [hoeringsportalen.dk], [erhvervsstyrelsen.dk]
The proposal is notable because it seeks to increase e-invoicing adoption through infrastructure, software design and default settings, rather than through an immediate legal obligation requiring every business to issue structured electronic invoices.
Automatic registration in the Nemhandel Register
Under the first element of the proposal, providers of registered digital standard bookkeeping systems would be required to enrol business customers using their systems in the Nemhandel Register for e-invoicing.
The registration would be automatic unless the business actively indicates that it does not wish to participate. A business enrolled automatically would retain the right to withdraw from the register afterwards. The model is therefore based on an opt-out mechanism, not an unconditional mandate. [hoeringsportalen.dk], [theinvoicinghub.com]
Registration in the Nemhandel Register makes a business electronically discoverable and allows trading partners to determine whether it can receive structured electronic business documents. Nemhandel is Denmark’s common infrastructure for exchanging electronic documents between businesses and public authorities. It includes common document standards, a national recipient register and a transport layer based on European eDelivery standards. [erhvervsstyrelsen.dk], [erhvervsstyrelsen.dk]
Denmark has used Nemhandel for public-sector invoicing since 2005, when electronic invoicing became mandatory for invoices sent to Danish authorities. This longstanding infrastructure is an important factor in the feasibility of an opt-out model. The proposed change does not require Denmark to create a new recipient network from the ground up. Instead, it expands the use of an established infrastructure already embedded in the country’s digital bookkeeping system. [erhvervsstyrelsen.dk], [rtcsuite.com]
E-invoice to become the first delivery option
The second element concerns how an invoice is sent from a digital standard bookkeeping system. When a user creates an invoice, the system would be required to check automatically whether the recipient is registered in the Nemhandel Register.
If the recipient is registered, the system would have to show e-invoicing as the first available delivery method. The proposal does not appear to prevent the supplier from choosing another legally permitted method. However, it changes the practical sequence so that structured electronic invoicing becomes the easiest and most visible option. [hoeringsportalen.dk], [theinvoicinghub.com]
This apparently small user-interface requirement could have a significant behavioural effect. At present, businesses may continue using PDF or paper invoices simply because these are the default options in their systems. Under the proposed Danish model, the software would identify an electronically reachable recipient and place the structured e-invoice option first.
The compliance burden is therefore moved away from the user. Businesses would not need to search manually for the recipient’s electronic address or determine whether the recipient is technically capable of receiving an e-invoice. The bookkeeping system and the Nemhandel Register would perform that check automatically.
Additional security and master-data controls
The proposal also contains supplementary security measures intended to increase confidence in electronic invoicing. These include identity verification requirements, mandatory master data on outgoing electronic business documents and restrictions on changing company information in bookkeeping systems. [hoeringsportalen.dk], [erhvervsstyrelsen.dk]
These safeguards are important because wider use of automatic registration and electronic document exchange also increases the importance of reliable identities and accurate routing data. If company information can be changed without adequate controls, invoices may be redirected, falsified or linked to an incorrect business. Identity verification and restrictions on master-data changes can reduce these risks and strengthen the document audit trail.
The proposal therefore goes beyond increasing the number of registered recipients. It attempts to ensure that registration, document issuance and company data are supported by sufficient controls to make the resulting network trustworthy.
Not a general B2B e-invoicing mandate
The proposal must be read carefully. Denmark is not introducing a general obligation for all businesses to issue structured electronic invoices from 1 January 2027. Businesses would still be able to opt out of registration, and the bookkeeping system would present e-invoicing as the preferred option rather than necessarily making it the only permitted option. [hoeringsportalen.dk], [peppol.nu]
The policy nevertheless changes the practical default. Under a traditional voluntary system, a business must take active steps to register for e-invoicing and configure its software. Under the proposed Danish system, a business using a registered standard bookkeeping solution would be enrolled unless it actively refused.
This distinction matters. The proposal does not create a formal legal mandate, but it may deliver part of the adoption effect of a mandate by reducing friction. Businesses remaining passive would become reachable through Nemhandel, while businesses wishing to continue outside the network would have to make a conscious decision.
Difference from Belgium’s mandatory model
Denmark’s approach contrasts with Belgium, where structured e-invoicing has been mandatory since 1 January 2026 for most domestic transactions between Belgian VAT-taxable businesses. Belgium generally requires invoices within scope to be exchanged in a structured format through the Peppol network. A PDF sent by email does not qualify as a structured electronic invoice. [efactuur.belgium.be], [efactuur.belgium.be], [efactuur.belgium.be]
Belgium has therefore chosen a legal mandate supported by a decentralised Peppol infrastructure. Denmark is proposing a software-driven default supported by Nemhandel but without imposing a general private-sector obligation at this stage.
Both models depend on similar foundations: structured invoice standards, reliable recipient discovery, secure transmission and accounting software capable of sending and receiving electronic documents. The principal difference concerns how businesses are brought into the ecosystem. Belgium relies on a statutory obligation, while Denmark proposes automatic enrolment combined with a right to opt out.
Relevance for the Dutch ViDA discussion
The Danish proposal is particularly relevant to the Netherlands. The Dutch government is considering how to implement the EU’s VAT in the Digital Age rules and whether to extend mandatory e-invoicing and digital reporting beyond intra-EU transactions to domestic B2B supplies.
The options examined include a minimum ViDA-A approach, limited principally to the EU-required cross-border scope, and a broader ViDA-B model covering domestic B2B transactions as well. An advisory report submitted to the Dutch Parliament on 10 March 2026 recommended a decentralised, Peppol-based model and expressed a preference for extending the framework to domestic transactions. However, final legislation has not yet been adopted, and a public consultation on the draft legislation is expected towards the end of 2026. [kpmg.com], [sovos.com], [innovatetax.com]
Denmark demonstrates that the policy choice is not limited to deciding whether a mandate should cover cross-border or domestic transactions. Governments must also consider whether the underlying infrastructure is ready. This includes the availability of a national or interoperable recipient directory, widespread software connectivity, reliable business identifiers and accounting systems capable of checking recipient status automatically.
A broad legal mandate may produce limited benefits if suppliers cannot easily identify where to send an e-invoice or if smaller businesses must complete a complicated registration process. Conversely, a well-designed opt-out system could build substantial network coverage before a mandate becomes necessary.
Part of Denmark’s broader e-invoicing transition
The opt-out proposal should also be viewed alongside Denmark’s planned migration towards a unified e-invoicing specification based on Peppol BIS 4. Denmark is moving away from its longstanding OIOUBL environment towards a new Danish implementation generally referred to as Nemhandel BIS 4 or the Nemhandel e-Invoice. [rtcsuite.com], [peppolnews.com], [vatupdate.com]
The transition is expected to take place between 2028 and 2029, with the existing OIOUBL 2.1 format ultimately being phased out. The objective is to align Denmark more closely with international Peppol standards and prepare its invoicing environment for the structured data and interoperability requirements associated with ViDA. [peppol.nu], [peppolnews.com], [theinvoicinghub.com]
Automatic registration from 2027 could therefore expand the pool of businesses reachable through Nemhandel before the subsequent migration to the new standard. The two developments are legally distinct but strategically connected: one increases network participation, while the other modernises the format used to exchange documents.
A practical alternative or only an intermediate step?
The Danish model offers a pragmatic route to higher adoption without immediately imposing an obligation on all private-sector transactions. It reduces administrative barriers, uses existing bookkeeping software and preserves business choice.
Its effectiveness will depend on how many companies opt out and whether suppliers use the electronic channel when it is presented as the first option. If most businesses remain registered and software makes e-invoicing easier than sending PDFs, voluntary adoption could increase rapidly.
However, the approach may not provide complete coverage. Businesses using non-registered or specially developed systems may require separate treatment, and companies can still withdraw from the register. A later mandate may therefore remain necessary to achieve universal interoperability and meet future European requirements.
The Danish proposal nevertheless highlights an important principle for other countries: an e-invoicing policy is not only about imposing a legal obligation. It is also about designing the infrastructure and software defaults so that compliance becomes the easiest way of working.
