Denmark Proposes New Requirements for Digital Bookkeeping Systems to Promote E-Invoicing

The Danish Business Authority (Erhvervsstyrelsen) has proposed new requirements for registered standard digital bookkeeping systems (DBS), with the aim of encouraging wider voluntary use of electronic invoicing in Denmark. The proposal is currently under public consultation and does not introduce a general B2B e-invoicing mandate.

Under the proposal, providers of registered standard digital bookkeeping systems would have several new responsibilities:

1. Automatic Nemhandel registration: Businesses using these systems would generally be registered for e-invoicing in the NemHandel Register unless they actively opt out. Nemhandel is Denmark’s national infrastructure for exchanging electronic business documents, especially e-invoices, credit notes and other e-commerce documents. Customers would have four weeks to decline registration and could also deregister later.
2.  E-invoicing as the first option: When issuing an invoice, the bookkeeping system would automatically check whether the recipient is registered in the NemHandel Register. If so, electronic invoicing must be presented as the first sending option. Businesses would still be free to choose another method.
3.  Stronger security and data integrity: Providers would need to introduce additional identity verification, generally using MitID (national digital identification system), protect company master data such as CVR number, name and address from unauthorized changes, improve searchability of bookkeeping records and prevent users from deleting required accounting material.

The proposal focuses on registered standard bookkeeping systems. It does not extend these particular amendments to companies using customized/non-registered bookkeeping systems. The broader objective is to make e-invoicing easier and more secure rather than immediately making its use compulsory. The Danish Business Authority estimates that the measures could bring around 125,000 additional businesses into the electronic invoicing infrastructure.

Most of the new requirements are planned to take effect on January 1, 2027. However, the rules requiring providers to notify new and existing customers about Nemhandel registration are scheduled to apply from November 30, 2026.

The consultation is open until August 17, 2026, and the Danish Business Authority expects the final executive order to be published in early September 2026.