Denmark Postpones New Digital Bookkeeping System Requirements to March 2027 and January 2028

Denmark has revised its digital bookkeeping requirements, postponing new e-Invoicing registration and identity verification measures to March 1, 2027. Additional requirements concerning business master data, electronic documents and system security will apply from January 1, 2028.

Denmark has adopted amendments to its digital bookkeeping regulations, introducing new requirements for registered standard digital bookkeeping systems while postponing several implementation deadlines.

The Danish Business Authority issued Executive Order No. 811/2026, amending the existing requirements for digital standard bookkeeping systems. The Authority published accompanying implementation guidance on September 25 and a further announcement on September 28, 2026.

Under the revised timetable, several requirements originally planned for January 1, 2027, will instead become mandatory on March 1, 2027, while additional measures will apply from January 1, 2028.

The amendments focus on making electronic invoicing more accessible, strengthening business identity verification and improving the accuracy and security of accounting records.

Importantly, the new requirements primarily concern providers of registered standard digital bookkeeping systems, rather than introducing new obligations for all POS systems or mandating E-Invoicing for every domestic B2B transaction.

The first implementation stage introduces new requirements concerning business identification, registration for e-Invoicing and invoice delivery options.

Under the amended rules, providers must verify the identity of new and existing customers and end customers registered in Denmark's Central Business Register (CVR) using MitID, the Danish digital identification solution.

For this purpose, end customers are businesses whose bookkeeping is maintained in the system, while customers are businesses directly contracting with the system provider, including accounting firms acting for other businesses.

Existing users must complete identity verification, while new users must be verified during registration. According to the Danish Business Authority, this is a one-time identity confirmation rather than a requirement to use MitID for every subsequent login.

Another requirement concerns registration in Nemhandelsregisteret, Denmark's electronic invoicing recipient register.

From March 1, 2027, providers must inform end customers who are not already registered for E-Invoicing that they will be enrolled unless they actively decline.

Businesses will have four weeks to opt out. Once this period expires, providers have another four weeks to register businesses that have not declined.

The registration process will take place progressively as customers access their bookkeeping systems and complete identity verification.

Businesses retain the right to decline registration or deregister later.

Registered bookkeeping systems must also check whether a recipient is registered in Nemhandelsregisteret when a user manually prepares an invoice.

Where the recipient can receive structured e-Invoices, the system must clearly display that option during invoice creation or selection of the delivery method.

However, the rules do not require the business to send an e-Invoice simply because the recipient is registered. Domestic B2B e-Invoicing remains voluntary under these provisions.

The requirement also does not apply in the same way to automated invoice transmission, including batch processing and invoices initiated through external API integrations.

The second implementation stage introduces further controls concerning business identification, master data and electronic records.

One requirement concerns MitID verification when users add or modify supplementary business master data.

This includes information such as bank account details and relevant SE (business tax registration number) or GLN (global location number) identification numbers.

The system must verify the identity of the individual making the change before allowing the modification.

Another requirement concerns the use of official company information from the CVR register.

Registered bookkeeping systems must automatically retrieve and maintain relevant business master data, including company names, addresses and registration numbers.

These details must be protected against direct modification by users. Corrections to official registered information must instead be made through the appropriate business registration procedures.

From January 2028, electronic business documents sent through these systems must contain the applicable registered business information, retrieved automatically from CVR.

Impact on retailers and software providers

The revised requirements primarily affect providers of registered digital bookkeeping systems, including ERP and accounting software providers whose solutions fall within the Danish registration framework.

For retailers, the practical impact depends on the type of software used and how B2B invoicing is managed.

Retail businesses using registered bookkeeping systems may encounter new MitID verification procedures, automatic E-Invoicing registration notifications and changes to invoice delivery options.

Where a retailer generates B2B invoices through an integrated ERP or accounting system, these changes may affect its invoicing workflow and business master-data management.

However, the amendment does not introduce new Fiscal Receipt requirements or automatically require changes to POS systems used exclusively for retail sales.

Businesses using customized bookkeeping solutions that are not registered with the Danish Business Authority are not directly subject to these particular requirements for registered standard systems. Their existing obligations under the Danish Bookkeeping Act remain applicable.

What should businesses prepare?

Providers of registered standard digital bookkeeping systems should review their implementation plans against the revised March 1, 2027, and January 1, 2028 deadlines.

Preparation should include MitID integration, customer verification, Nemhandelsregisteret registration procedures, opt-out functionality and electronic invoice recipient checks.

For the 2028 requirements, providers should review controls over supplementary business information, CVR data integration, electronic document content and protection of accounting records.

Retailers and other businesses using registered bookkeeping systems should confirm with their providers how identity verification, E-Invoicing registration and updated invoice workflows will be implemented.

The postponement provides additional preparation time, but it does not suspend Denmark's existing digital bookkeeping obligations.

The main distinction concerns the difference between E-Invoicing functionality and mandatory E-Invoicing usage.

Denmark is requiring registered bookkeeping systems to make electronic invoicing easier to access and use, but these provisions do not establish a general obligation to exchange structured E-Invoices for every domestic B2B sale.

The legal basis for this article is the Executive Order No. 811 of September 22, 2026, amending the requirements for digital standard bookkeeping systems. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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