Regulatory updates - Denmark

On March 20, 2025, executive orders BEK no. 297 and BEK no. 303 were issued, marking a significant extension to businesses needed to comply with the Danish digital bookkeeping obligation.

Who is in the scope?

The orders mandate compliance with the act for the following entities:

• Personally owned businesses with an annual turnover exceeding 300,000 DKK (ca. 40,000 EUR) for two consecutive years;
• Associations with a commercial turnover over 300,000 DKK (ca. 40,000 EUR) annually for two consecutive years;
• Subsidiaries of financial companies, insurance firms, and ATP that are required to submit financial reports, previously exempt due to group-linked accounting systems.

The decision follows an evaluation by the Danish Business Authority, revealing that the costs of implementing digital bookkeeping systems are lower than anticipated, while the potential cost savings are significantly higher.

Impact on businesses

Businesses must ensure their bookkeeping systems comply with the requirements of the Bookkeeping Act by the 2026 deadline. The transition aims to streamline financial reporting and enhance transparency through requirements on the digital bookkeeping systems, including the capability to issue, receive and archive electronic invoices.

The Danish Business Authority has announced postponing the final release date for the new version of the Danish e-invoicing format OIOUBL 3. The final release of the invoice package is now expected in October 2025.

The postponement follows several inquiries sent to the Danish Business Authority needing further analysis.

The authority informs that further announcements regarding the analysis's outcome will be made later. 

Nemhandel presented the release candidate of the OIOUBL 3 Invoice Package on 21 November 2024. The package contains:

• Business Interoperability Specification (BIS) for invoice, credit note and invoice reply;
• BIS for Message Level Response, containing two profiles: Message level response and Message Level Response – Network;
• Migration Plan, containing essential dates for the rollout and interaction with existing formats;
• Syntax bindings and specific field definitions for invoice, credit memo, invoice response and message level response.

Major changes

The release notes stipulate essential changes introduced in OIOUBL 3.

OIOUBL BIS Billing with Response will include the following changes:

• Separation of message level and business level responses: The ApplicationResponse document is no longer used for both business and message level responses; instead, they are split into different customization IDs and profiles;
• Two-way profiles only: All institutional end users are now expected and required to receive invoice responses at an endpoint registered to their business. Using several profiles is no longer allowed;
• Interpretations: Free-text fields are now marked as read-only, while some structured fields no longer are. Clarifications have also been made regarding supported, excluded and unsupported fields;
• Re-mapped fields, calculation changes and revised field definitions: Several alignments have been made towards EN16931 conformance, including re-mapping of fields, calculation changes, and replacing negative credit notes with invoices.

OIOUBL BIS Message Level Responses are also affected by changes in the separation of message level and business level responses, as well as the introduction of mandatory support for message level responses at business and service provider levels. Furthermore, there are many additional updates, such as field definitions and how to provide ESG (Environmental, social, and governance) principle-related data (e.g., CO2 emission data).

Necessary actions for invoice senders

OIOUBL 3 invoice senders must also be able to receive OIOUBL 3 Invoice Response and OIOUBL 3 Message-Level Response. This means the senders must be registered as Suppliers in Nemhandelsregistret (NHR) with both mandatory OIOUBL 3 document profiles.

Necessary actions for invoice receivers

Receivers should be able to receive both OIOUBL 2.1 invoices and OIOUBL 3 invoices during the entire migration timeline. Therefore, it is recommended that they register as invoice recipients in NHR with both mandatory OIOUBL 3 document profiles as Customers while keeping the existing OIOUBL 2.1 document profiles in NHR.

Migration plan

In addition, the Danish Business Authority has announced a migration plan, stipulating timelines for the migration between the current format OIOUBL 2.1 and its replacer OIOUBL 3:

• OIOUBL 3 release candidate: 15 November 2024;
• Deadline for remarks on release candidate: 6 March 2025;
• OIOUBL 3 final release: 10 April 2025;
• OIOUBL 3 voluntary support: 15 May 2025;
• OIOUBL 3 mandatory support: 15 November 2025;
• OIOUBL 2.1 no longer supported: 15 May 2026.

The Government of Greenland released an executive order on Digital Invoicing to enforce e-invoicing in the public sector in 2025.

The executive order released on 11 November 2024 mandates all legal and natural persons to send electronic invoices when delivering goods or services to public authorities. The obligation becomes effective as of 1 March 2025.

Learn more about the upcoming mandate here.

As previously reported by Pagero in an earlier update, Denmark is mandating the use of digital bookkeeping systems (DBS). There are two categories of DBS in Denmark: standard and custom (also known as specially developed).

The requirements for the standard DBS have been known for quite some time, such as stricter IT security and e-invoicing capabilities, and many accounting software providers have already been registered with ERST.

For the custom DBS, the requirements have just been released and are practically identical to the requirements of the standard systems. However, unlike the standard DBS, where the responsibility of fulfilling the requirements falls on the provider of the system, it will be up to the company using the custom DBS to ensure the requirements are met.

Danish companies using an accounting system classified as a custom DBS should start preparing for the obligation that will enter into force on 1 January 2025.