Denmark Introduced New e-Invoicing and Digital Bookkeeping System Requirements for 2027 and 2028

Denmark has introduced new requirements for registered digital bookkeeping systems, effective in March 2027 and January 2028. Software providers must introduce business identity verification, automatic e-Invoicing registration and stronger data controls, affecting retailers and other businesses using these systems

Denmark has adopted new requirements for registered digital bookkeeping systems to increase the use of electronic invoicing and strengthen the security of business records. The Danish Business Authority introduced the changes through Executive Order No. 811 of September 22, 2026, followed by official implementation guidance published on September 25, 2026.

The requirements will be implemented in two phases, beginning on March 1, 2027, and January 1, 2028. They primarily apply to providers of registered digital standard bookkeeping systems, but will also affect retailers, retail chains, e-commerce businesses and other companies using these solutions.

The first phase introduces three main requirements involving business identification, e-Invoicing registration and invoice creation.

1.     Business identity verification through MitID

Providers must verify the identity of their customers and end customers registered in Denmark's Central Business Register (CVR) using MitID, Denmark's national digital identification system.

New customers must complete verification when registering in the bookkeeping system, while existing customers must complete it before accessing the system again. This is a one-time identity verification, not a requirement to use MitID during every login.

Providers must record verification activities, including the time, type and user involved, and make these records available during official inspections. Foreign customers not registered in CVR are currently outside this specific identification requirement.

2.     Automatic registration for e-Invoicing through NemHandel

Following identity verification, providers must register eligible businesses to receive e-Invoices through NemHandel unless they are already registered or actively decline.

Businesses must receive notification of the planned registration and have four weeks to opt out. If they do not respond, the provider has another four weeks to complete registration. Businesses may also withdraw their registration later.

The registration process proceeds as businesses access their bookkeeping systems and verify their identities. Registration does not make e-Invoice issuance mandatory for ordinary domestic B2B transactions.

3.     E-Invoice options during invoice creation

Registered bookkeeping systems must clearly display the option to send an e-Invoice when the recipient is registered in NemHandel.

This requirement applies to manually created invoices. Automated invoicing processes, including batch invoicing or invoices generated through external application programming interfaces (APIs), are excluded from this particular display requirement.

The objective is to make the availability of structured e-Invoicing visible to users without requiring them to search separately for the recipient's preferred invoicing method.

The second phase introduces further controls over company information, accounting records and system security.

Providers must implement MitID verification whenever an individual user adds or changes supplementary company information, including bank account details and certain business identifiers.

Company registration information must be retrieved automatically from CVR and protected against direct editing within the bookkeeping system. Changes to official company details must instead be made through the appropriate public business registration procedures.

Electronic business documents sent through the system, including e-Invoices, must contain the sender's registered company name, address and CVR number.

The systems must also allow accounting records to be identified, searched and extracted separately for each business. The Danish Business Authority describes this as a clarification of existing recordkeeping requirements.

Finally, users must not be able to delete sent or received business documents and supporting accounting records. The protection also extends to documents that have not yet been entered into the accounts, preventing their removal before bookkeeping.

Impact on retailers and software providers

The changes mainly affect bookkeeping, ERP and e-Invoicing functionality rather than the fiscalization of individual retail sales.

For retailers, automatic NemHandel registration may change how supplier invoices are received and processed. Businesses using integrated retail and accounting systems should ensure that incoming e-Invoices can be accessed, reviewed and recorded through their existing workflows.

Retail chains operating multiple locations may also need to review company identifiers and invoice routing arrangements, especially where different stores or business units use separate receiving addresses.

For software providers, the new requirements involve MitID integration, NemHandel registration functionality, recipient identification, company master-data validation and stronger record protection.

What should businesses prepare?

Providers of registered digital bookkeeping systems should prioritise the March 2027 requirements, particularly MitID verification, automatic NemHandel registration and the display of E-Invoice options.

They should also prepare for the January 2028 requirements involving protected company data, user verification, accounting record retrieval and document deletion controls.

Retailers should review their incoming invoice procedures and confirm how their bookkeeping provider will handle NemHandel registration, invoice notifications and document access.

The principal consequence is the growing connection between e-Invoicing and digital bookkeeping compliance. Although these requirements do not directly change retail fiscalization rules, they may affect the systems used to transfer transaction and invoice data between POS, ERP and accounting platforms.

The changes also support Denmark's preparation for the EU VAT in the Digital Age (ViDA) requirements, under which electronic invoicing for covered intra-EU B2B transactions becomes mandatory from July 1, 2030.

The principal legal basis is the Executive Order No. 811 of September 22, 2026, and the Danish Business Authority’s Implementation guidance from September 25, 2026 - Source Source

Ivana Picajkić Medior Legal Consultant Linkedin profile