Understanding Danish E-Invoicing Regulations
Electronic invoicing in Denmark is a well-established practice, with a clear distinction between Business-to-Government (B2G) and Business-to-Business (B2B) transactions. For B2G transactions, e-invoicing has been mandatory since 2005, requiring all suppliers to public authorities to submit their invoices electronically. Public authorities are obligated to accept and process these e-invoices, provided they comply with the European Standard EN 16931, typically exchanged via the national NemHandel platform.
While B2B e-invoicing is not yet universally mandatory for issuance, the 2022 Bookkeeping Act significantly impacts all businesses by requiring them to possess the capability to send and receive structured electronic invoices. This Act mandates the use of digital bookkeeping systems (DBS) that support structured e-invoicing and the generation of Standard Audit Files for Tax (SAF-T).
Compliance deadlines for the Bookkeeping Act are phased:
- July 1, 2024: Applied to companies required to submit annual reports and already using registered bookkeeping systems.
- January 1, 2025: Extended to companies submitting annual reports but using non-registered or custom-built accounting systems.
- January 1, 2026: The requirement will apply to businesses without an annual reporting obligation, such as sole proprietorships, if their annual net turnover has exceeded DKK 300,000 for two consecutive years. For those using in-house accounting systems, the deadline is expected to be July 2026.
Non-compliance with B2G e-invoicing regulations can lead to severe consequences, including automatic rejection of invoices, payment delays, audits, administrative fines, and even potential exclusion from future government contracts.