Regulatory updates - Denmark

The announcement follows the cancellation of OIOUBL 3, and is the result of an analysis conducted by the Danish Business Authority during the last year.  

As part of the phase out, a migration timeline from OIOUBL 2.1 to NemHandel BIS 4 was revealed, set to run from 2028 to mid-2029. A release candidate for NemHandel BIS 4 is expected in 2028, with subsequent timelines for final release and the implementation of the new standard alongside the phase out of OIOUBL 2.1.

More detailed timelines are yet to be announced by the Danish Business Authority.

Compared with SAF‑T 1.0, SAF‑T 2.0 expands the required structure and content to enable future exchange and sharing of transaction-level accounting data with the public sector and partners in a standardized format.

The main changes in SAF-T 2.0 include:

• Introduction of the concept of MIFU (Mandatory if used)
• Mandatory Masterfiles
• Mandatory GeneralLedgerEntries
• Mandatory fields with suspension in the Executive Order on requirements for digital standard accounting systems (BEK 97 of 26/01/2023)
• MIFU fields for reporting to the Danish Tax Agency, Statistics Denmark and other data sharing use cases
• The introduction of the XML attribute Nil

Details on the updated SAF-T 2.0 version are available here.

The suspension of the OIOUBL 3 release follows a review of the document strategy which was announced in March 2025, followed by meetings organized by Nemhandel in June and October updating service providers on the progress.

Now, the Authority confirms OIOUBL 3 will no longer be released based on feedback from service providers indicating extensive implementation work and effort would be required. Instead, the Authority will work toward only using one standard rather than the current dual use of the Peppol and OIOUBL standards.

A new Nemhandelsforum providing further details will be held February 24, 2026.