Denmark e-Invoicing: NemHandel Auto-Enrolment Moves to March 2027 as Peppol and SAF-T Requirements Expand

Denmark has postponed new NemHandel enrolment requirements to March 1, 2027. The changes promote voluntary B2B e-Invoicing, while registered bookkeeping systems also face SAF-T 2.1 requirements and Denmark prepares to consolidate invoice formats around Peppol by 2029.

Denmark has moved the next stage of its e-Invoicing programme from January 1 to March 1, 2027, giving providers of registered digital bookkeeping systems two additional months to prepare for new NemHandel requirements. The change does not introduce a general domestic B2B e-Invoicing mandate. Instead, Denmark is using its mandatory digital bookkeeping framework to make structured e-Invoicing easier to adopt and increasingly visible as the normal invoicing option.

At the same time, Denmark is preparing a wider technical transition. The current parallel use of OIOUBL and Peppol BIS is expected to be replaced by a common Peppol-based specification, with migration starting around mid-2028 and the existing formats expected to be phased out during 2029. Registered digital bookkeeping systems must also support SAF-T version 2.1 from January 1, 2027.

Together, the changes show how Denmark is linking digital bookkeeping, e-Invoicing, standardized accounting data and European interoperability without yet requiring all domestic B2B invoices to be issued electronically.

The new requirements principally concern providers of registered digital bookkeeping systems.

Users of those systems must be informed that they will be registered in the NemHandelRegister, which identifies businesses able to receive structured electronic invoices through Denmark’s NemHandel infrastructure. Businesses will have four weeks to opt out. If they do not opt out, the bookkeeping-system provider must complete the registration.

The rules also affect how invoicing functions are presented inside bookkeeping software. When a user manually creates an invoice, the system must identify whether the customer is registered in the NemHandelRegister. Where the recipient is registered, sending a structured e-Invoice should be presented as a clear and straightforward option.

This distinction matters. Automatic registration as a potential e-Invoice recipient is not the same as making domestic B2B e-Invoicing mandatory. A business can opt out of the registration process, and Denmark has not introduced a universal rule requiring every domestic B2B invoice to be exchanged through NemHandel.

The Danish Business Authority had already explained during the 2026 consultation that registered bookkeeping-system providers would be required to enrol customers for receiving e-Invoices unless the businesses actively declined. The September update changes the implementation date to March 1, 2027.

The current coexistence of OIOUBL and Peppol BIS is also expected to be temporary.

According to the latest implementation information, Denmark intends to move towards one common E-Invoice specification based on Peppol. The transition is expected to begin around mid-2028, with the existing parallel formats phased out by approximately mid-2029.

For software and ERP providers, this is an important technical transition. Denmark currently has a domestic OIOUBL environment alongside a Peppol-based exchange, and there are differences between the two specifications and the document processes they support. The Danish Business Authority’s existing technical guidance confirms that both environments remain relevant today.

Businesses should therefore not treat the future Peppol-based model as the current mandatory format. The migration will require separate implementation planning as the final specifications and transition milestones are confirmed.

The timing also places Denmark’s transition shortly before the EU VAT in the Digital Age (ViDA) reforms. From July 1, 2030, the amended EU VAT Directive introduces new electronic invoicing and Digital Reporting Requirements for relevant intra-Community transactions.

The Danish Business Authority currently states that registered digital bookkeeping systems must support SAF-T version 2.1 from January 1, 2027. Non-registered digital bookkeeping systems may continue supporting SAF-T version 1.0, which is limited to a header file under the current requirements.

This is worth distinguishing from the Danish Business Authority’s February 2026 announcement, which originally described the expanded standard as SAF-T 2.0. That version introduced transaction-level accounting information, including Masterfiles and GeneralLedgerEntries. The authority’s current SAF-T page now refers to version 2.1 for the January 2027 requirement, so businesses and software providers should work from the latest technical specification rather than the earlier announcement alone.

The expanded SAF-T structure is intended to support standardized exchange of bookkeeping and accounting data and may also support future automation of reporting to public authorities.

Impact on retailers, ERP and software providers

For retailers, the main practical issue is likely to arise where B2B invoices are generated from transactions originating in POS, e-commerce or order-management environments.

As more business customers become visible in the NemHandelRegister, systems need to determine whether a structured E-Invoice can be sent and move the required transaction data correctly from the original sales process into the bookkeeping or invoicing system.

For providers of registered bookkeeping systems, the March 2027 deadline creates more direct obligations: customer notification, handling the four-week opt-out period, registration in NemHandel and clearer E-Invoice functionality must all be supported.

At the same time, providers must prepare for SAF-T 2.1 and, looking further ahead, the migration from today’s OIOUBL/Peppol environment to the future common Peppol-based specification.

What should affected businesses prepare for?

Businesses using registered bookkeeping systems should first determine whether they want to remain registered in NemHandel once notified. Those expecting to receive structured E-Invoices should also verify that their internal invoice-processing and accounting workflows can handle them correctly.

Retailers and larger groups using customised or non-registered ERP systems should separately review their NemHandel connectivity and current support for OIOUBL and Peppol. They should also monitor whether and when future SAF-T requirements will be expanded to non-registered systems.

Software providers should prepare for the March 1, 2027 NemHandel changes, the January 1, 2027 SAF-T 2.1 requirement where applicable, and the planned 2028–2029 Peppol migration.

From a retail compliance perspective, Denmark’s approach is notable because it does not rely on a sudden universal domestic B2B E-Invoicing mandate. Instead, the country is progressively making structured invoices easier to exchange, making potential recipients easier to identify and standardising the underlying bookkeeping data. The practical effect may nevertheless be substantial: as NemHandel registration expands, structured E-Invoicing could become the normal B2B process for many businesses even while the domestic exchange itself remains voluntary.

The principal official source is the Danish Business Authority website regarding Nemhandel-common digital infrastructure. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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