Regulatory updates - Denmark

Executive Order no. 811  and the implementation guidelines confirm the revised implementation timeline. Additionally, compared with the consultation draft, certain previously proposed requirements have been revised, while additional requirements have been introduced.

Key requirements on standard digital bookkeeping systems applying from March 1, 2027 include:

• Nemhandel opt-out: In connection with the MitID validation, end-customers not already registered for e-invoicing must be notified that they will be registered for e-invoicing unless they actively opt out within four weeks
• Availability of e-invoicing during issuance: For manual user-initiated invoicing, the system must clearly indicate when the recipient is registered in the Nemhandelsregister
• MitID verification: New and existing customers and end customers registered in the CVR must verify their identity using MitID

In addition, certain requirements will apply from January 1, 2028, including:

• MitID verification when changing supplementary master data: Users adding or changing supplementary master data for customers or end customers registered in the CVR must authenticate using MitID
• Masterdata on electronic business documents: Electronic business documents must contain the end customers registered master data when the customer is registered in the CVR by automatically retrieving the CVR information and prevent alteration by users. The system must also support inclusion of relevant supplementary master data

Providers of standard digital bookkeeping systems must implement the above functionality in accordance with the revised implementation timelines, with further details available in Executive Order no. 811  and the implementation guidelines.

The requirements do not currently apply to custom digital bookkeeping systems, which are not subject to registration with the Danish Business Authority.

The proposal is currently under public consultation until August 17, 2026. The Danish Business Authority expects the final executive order to be issued in early September 2026. Under the draft, most requirements would apply from January 1, 2027, while provisions relating to notifications to new and existing end customers would apply from November 30, 2026. The draft amendments form part of the Danish Business Authority's efforts to increase e-invoicing adoption.

Proposed new requirements apply specifically to registered standard DBS

The current proposal introduces new requirements concerning the functionality of standard digital bookkeeping systems that must be registered with the Danish Business Authority. At this stage, the proposed requirements do not extend to custom digital bookkeeping systems.

Requirements aim to increase voluntary e-invoicing adoption

Proposed requirements for registered standard DBS include:

• Registration in Nemhandelsregistret: The proposal would change the current opt-in process to an opt-out process. Providers of registered standard DBS must register end customers for e-invoicing in Nemhandel unless the end customer is already registered or opts out within a four-week period.
• E-invoicing presented as the first choice: Systems would be required to check whether an invoice recipient is registered in Nemhandel and, where this is the case, present e-invoicing as the first/default sending option. The sending method would remain voluntary.
• Additional security and data-integrity measures: The proposal introduces additional identity-verification, master-data integrity, searchability, and record-retention requirements for registered standard DBS.

The proposal does not introduce a general obligation for Danish businesses to issue or receive B2B (business-to-business) e-invoices. Instead, it expands the requirements for registered standard DBS to make e-invoicing more accessible, prominent, and secure. Businesses would still be free to choose another sending method when issuing invoices.

On March 19, 2026, the Danish Business Authority released version 1.16.0 of the Danish CIUS package and version 1.2.13 of the Danish Peppol BIS 3- Other package.

The following change is introduced in version 1.16.0 of the Danish CIUS package:

• Peppol schematrons, which have been mandatory since February 23, 2026, have been updated to version 3.0.20

The following change is introduced in version 1.2.13 of the Danish CIUS package:

• Peppol schematrons, which have been mandatory since February 23, 2026, have been updated to version 3.0.16

The release packages including schematrons and example files, are available here.

To support the new schematrons and the new Peppol certificates (G3), the reference implementation was in addition updated to version 2.3.0 on March 26, 2026.

The reference implementation is available here, and will be deployed to the DEMO environment.