Regulatory updates - Denmark

The update to the SAF-T stems from Art. 15 paragraph 1(3) of the Bookkeeping Act, which addresses the automation of administrative processes through automatic sending and receiving of e-invoices and the improvement of tax reporting.

Digital standard bookkeeping systems are already required to import and export basic company data in SAF-T format. However, the new version 2.0 expands the scope of data that must be reported.

The requirement to implement the technical specifications in SAF-T 2.0 will apply only to providers of registered digital bookkeeping systems. The new version of the SAF-T is now open, for public consultation involving service providers, the business community, and other stakeholders, until September 1, 2025.

The Danish Business Authority has begun an analysis to shape the future of OIOUBL and Nemhandel. As previously reported by Pagero, the planned OIOUBL 3.0 release was postponed in March 2025 due to the need for further evaluation.

At the June 26 meeting, the Danish Business Authority indicated that OIOUBL 3.0 may not be released. A smaller update is under consideration, depending on the findings of the ongoing review.

The key topics being examined include the following.

Short-term

• Whether to release a minor OIOUBL update or a major OIOUBL 3.0 update.

Long-term

• Whether Denmark should maintain its national e-invoicing format and infrastructure (OIOUBL/Nemhandel) or transition fully to the international Peppol standard;
• How legal obligations, like those under the Danish bookkeeping law, and political goals may influence the choice of standard;
• The specific needs of stakeholders, including sustainability and sector-related requirements;
• The cost, security, and infrastructure implications of supporting one or multiple formats.

Industry feedback and the evolving capabilities of Peppol, which is becoming more compatible with Danish e-invoicing needs, have prompted this review. The Danish Business Authority emphasizes that data and input from all relevant parties will guide its decision.

Timelines and next steps

• September/October 2025: Public consultation and stakeholder engagement, with opportunities to provide feedback;
• October/November 2025: Completion of the analysis, followed by the decision-making process.

Pagero will continue to monitor the situation and inform stakeholders about future developments and their implications for e-invoicing in 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.

Following uncertainty regarding the applicability of the extended scope, the Danish Business Authority furthermore clarified foreign entities will only be in scope if they have a permanent establishment in Denmark and annual revenue exceeding 300,000 DKK.