Denmark is pursuing the digitalisation of business transactions by encouraging the voluntary adoption of e-invoicing rather than imposing a general domestic B2B e-invoicing mandate.
Through several publications issued between September and October 2026, ERST, the Danish Business Authority, provided guidance on new requirements and implementation timelines for registered digital accounting systems, as well as measures to expand businessesâ use of e-invoicing through NemHandel, including a default registration mechanism with an opt-out option.
Denmark clarifies the objectives of its voluntary e-invoicing initiative
On September 28, 2026, the Danish Business Authority clarified the broader objectives of Denmarkâs initiative to promote the voluntary adoption of e-invoicing through NemHandel [âïž].
The initiative is designed to make it easier for Danish businesses to receive e-invoices through NemHandel, reducing manual processing and administrative costs. It will also help prepare them for the ViDA directive, whose cross-border B2B e-invoicing requirements will apply from July 1, 2030.
It is expected to benefit approximately 350,000 businesses using registered digital accounting systems.
8 new requirements for registered digital accounting systems
Under the Danish Bookkeeping Act, businesses in scope must use a registered digital accounting system or develop their own solution. These systems must meet government-set requirements, helping ensure secure record-keeping and enabling the authorities to carry out effective compliance checks.
On September 25, 2026, ERST published clarifications on eight of those requirements for registered digital accounting systems [âïž]:
- MitID verification of customers and end customers: Providers of registered digital accounting systems must verify the identity of the person acting on behalf of a Danish business before registering the business to receive e-invoices through NemHandel. This verification must be performed through MitID [âïž] (Denmarkâs national electronic identification system) and must be documented and traceable.
- Default registration for NemHandel with an opt-out mechanism: Businesses must be notified that they will be registered to receive e-invoices through NemHandel unless they opt out within four weeks. If they do not object, the provider has a further four weeks to complete the registration.
- Display of e-invoicing options when issuing invoices: When users manually prepare invoices, the accounting system must indicate whether the recipient is registered for e-invoicing through NemHandel and can receive an e-invoice.
- MitID verification for changes to critical business data: Users must verify their identity through MitID before adding or changing sensitive customer or supplier information, such as bank details, SE numbers or GLN/EAN identifiers.
- Search and retrieval of accounting records: Providers must ensure that each businessâs accounting records and supporting documents can be clearly identified and easily retrieved, including by the relevant authorities.
- Verification of official company information: Providers must retrieve official company information from Virk.dk [âïž], Denmarkâs public business portal, and ensure that protected master data cannot be modified directly within the accounting system.
- Company information on electronic business documents: Outgoing electronic business documents must include relevant company identification details retrieved from the CVR [âïž], Denmarkâs central business register, ensuring that the sender can be properly identified (i.e. end customer’s company name, address and CVR number).Â
- Document retention: Systems must prevent users from deleting business documents and supporting attachments, safeguarding accounting records and maintaining an audit trail.
Implementation timeline for the 8 requirements
ERST has set out a phased implementation timeline for the eight new requirements:
- March 1, 2027: Requirements 1 to 3, covering MitID identity verification, default NemHandel registration with an opt-out mechanism, and display of e-invoicing options when manually preparing invoices.
- January 1, 2028: Requirements 4 to 8, covering supplementary business information, accounting record retrieval, official company information, electronic document identification and document retention.
Consolidated guidance for registered digital accounting systems
Finally, on October 19, 2026, ERST published consolidated guidance for providers of standard digital accounting systems [âïž], bringing together relevant requirements and implementation timelines. Â The guide provides extensive information on the requirements that an acccouting system must meet to be registered with the Danish Business Authority:
- Registration requirements for digital standard accounting systems
- Registered digital standard accounting systems
- Key definitions, including e-invoices, NemHandel and SAF-T
- Functional minimum requirements for registered accounting systems
- IT security and backup requirements
- Automation and digitalisation requirements
- Ongoing obligations for providers of registered accounting systems
- Registration procedures
- Supervision, enforcement measures and penalties
- Recommendations for implementing automation in registered digital standard accounting systems
The guidance also covers SAF-T requirements, including the applicable data export format and the changes scheduled to take effect on January 1, 2027.
