Regulatory updates - Denmark

Denmark continues strategic developments in e-invoicing and digital bookkeeping. The Danish Business Authority is advancing several initiatives to enhance standardization, improve data quality, and increase automation across business transactions. These developments align with broader European digital transformation efforts and prepare Danish businesses for upcoming EU requirements.

Document standard strategy

Following the postponement of OIOUBL 3.0, the Danish Business Authority is currently finalizing its analysis after consultation with selected stakeholders, along with legislative objectives and associated cost assessments. The results and strategy, which were expected in October 2025, have been delayed and are anticipated in the first quarter of 2026.

While major updates to the national e-invoicing standard remain under review, the Release Candidate of the latest version of OIOUBL 2.1 was published on October 14, 2025. This update aims to help businesses reduce manual reporting of climate data by including support for climate data (CO2) in e-invoices. The CO2 data fields will remain optional, and the final release is scheduled for the end of October 2025.

SAF-T 2.0 and G2B transactions

The final version of SAF-T 2.0 is being finalized following public consultation and is expected to be published at the end of 2025.

For government-to-business (G2B) transactions, the Danish Regulatory Forum (Regelforum) has recommended that public entities send e-invoices to businesses, mirroring the existing requirement for businesses to send e-invoices for B2G transactions. The Economic Development Agency (Økonomistyrelsen) is currently reviewing this recommendation with assistance from the Danish Business Authority.

Evaluating future requirements for digital bookkeeping systems

In view of ViDA requirements for intra-EU transactions taking effect in July 2030, the Business Authority is considering additional requirements for registered Standard Digital Bookkeeping Systems to advance digitalization, improve data quality, and boost efficiency. The proposals include:

• Targeting 70% e-invoicing adoption by 2027;
• Requiring businesses to be registered in the Nemhandelregister (NHR) with an opt-out option; and
• Requiring API integration with Nemhandel to automate identification of e‑invoice recipients.

The proposed requirements for registered Standard Digital Bookkeeping Systems, are proposed to eventually extend to Specially Developed Systems as well.

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.