Denmark: New Rules Proposed for E-Invoicing Through Digital Bookkeeping Systems

Denmark is proposing an opt-out the Danish e-Invoicing infrastructure (Nemhandel) registration model for users of registered digital standard bookkeeping systems, alongside default E-Invoice presentation, Danish National Electronic Identification System (MitID) identity checks and stricter master-data controls from late 2026 and January 2027.

The Danish Business Authority (Erhvervsstyrelsen) has proposed amendments to the requirements for registered digital standard bookkeeping systems that would change how E-Invoicing is presented and activated for business users. The public consultation closed on August 17, 2026.

The changes are focusing primarily on providers of digital standard bookkeeping systems that must be registered with the Danish Business Authority. The current regulatory basis is Executive Order No. 97 of January 26, 2023 on requirements for digital standard bookkeeping systems. The proposal does not extend the same requirements to non-registered or custom bookkeeping systems, where the business itself is responsible for meeting the applicable digital-bookkeeping rules. If adopted as drafted, most provisions would apply from January 1, 2027, while two Nemhandel notification provisions would start on November 30, 2026.

Under the current rules, registered bookkeeping systems must support E-Invoicing and allow end customers to choose registration through Nemhandel. The proposal reverses that logic. Providers would have to register end customers unless the customer is already registered or opts out within four weeks. Registered customers could still deregister later.

For existing end customers not already registered, providers would have to send direct information about the planned registration by November 30, 2026. Those customers would then be registered by January 1, 2027 unless they opt out. New end customers created after November 30 would receive the same information during onboarding and have four weeks to refuse registration.

When a user creates an invoice, the system would also have to check automatically whether the recipient is registered in the Nemhandel register. If so, electronic sending must be presented as the first or default option. This does not oblige the sender to issue an E-Invoice: the Danish Business Authority’s implementation guide expressly states that sending remains voluntary.

Providers would also have to verify the identity of end customers, customer businesses and individual system users. For Danish users, verification would generally use Danish National Electronic Identification System (MitID). Existing users would verify their identity at the first login after the rules take effect, while new users would be verified when created. Danish National Electronic Identification System (MitID) would not be required at every login.

Identity verification would also be required whenever a user adds or changes supplementary master data, including payment information and Tax Registration Number, Global Location Number, European Article Number (SE, GLN or EAN numbers). Foreign customers or users unable to use Danish National Electronic Identification System (MitID) would require other appropriate identity-verification measures.

The system would have to obtain locked master data — Central Business Register Number (CVR number), company name and address — directly from the Central Business Register (CVR), and users could not edit those fields inside the bookkeeping system. Outgoing electronic business documents would have to contain the end customer’s locked and applicable supplementary master data.

Bookkeeping material must also be uniquely attributable to the relevant end customer and searchable using master-data identifiers. Notably, the Danish Business Authority describes this searchability rule as a clarification of existing law, rather than a wholly new obligation. The draft would also prevent users from deleting sent or received electronic business documents and vouchers stored in the system, extending protection against deletion to documents before they are booked.

Impact on bookkeeping-system providers and businesses

The main implementation burden falls on providers of registered digital standard bookkeeping systems. Their products may require changes to onboarding, customer notification, Nemhandel registration and lookup, invoice-option presentation, Danish National Electronic Identification System (MitID) validation, Central Business Register (CVR) data handling, search functions and document-retention controls.

For retailers and other businesses using registered systems, the effect is different. The proposal does not create a general obligation to issue every domestic B2B invoice electronically. Instead, the software environment would make Nemhandel registration and E-Invoicing more likely by default. Users may therefore see changes in onboarding, identity checks, master-data maintenance and invoice-sending workflows even though sending an E-Invoice remains voluntary.

What should affected providers and businesses do now?

Providers should compare their current functionality with the consultation draft and prepare for the Nemhandel opt-out process, automatic recipient lookup, MitID verification, CVR-based master-data controls and non-deletion requirements. They should also be ready to communicate with existing end customers before November 30 if the final order confirms that deadline.

Businesses using registered systems should identify whether their solution falls within the registered-system framework, check their current Nemhandel status and review who can change payment or other supplementary master data. They should also ask their provider how the proposed onboarding and identity-verification changes will be implemented. Until the final order is confirmed, both providers and users should monitor the official text rather than treating the consultation draft as an adopted requirement.

From a retail compliance perspective, the most important distinction is between a system requirement and a transaction-level E-Invoicing mandate. The proposal changes system defaults and controls, but it does not itself require every Danish B2B invoice to be sent electronically. This distinction also matters when linking the Danish initiative to VAT in the Digital Age (ViDA): from July 1, 2030, ViDA introduces mandatory E-Invoicing-based digital reporting for cross-border B2B transactions, while domestic mandatory E-Invoicing remains subject to Member State choices and conditions.

The official sources for this are the Danish Consultation on the draft executive order amending executive order on requirements for digital standard accounting systems, and the Executive Order amending the Executive Order on requirements for digital standard accounting systems. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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