Understanding Electronic Invoicing Regulations in Denmark
Denmark has long been a frontrunner in digitalizing its invoicing processes, particularly within the public sector. Mandatory electronic invoicing for business-to-government (B2G) transactions was introduced in 2005, making Denmark one of the first European countries to implement such a requirement. This pioneering move aimed to streamline public procurement and enhance efficiency. Suppliers providing goods or services to public authorities must submit invoices electronically, as paper invoices are not accepted.
The legal framework for invoicing public authorities requires adherence to specific structured formats, primarily Peppol BIS Billing 3.0 and OIOUBL 2.1, both of which comply with the European e-invoicing standard (EN 16931). The national digital infrastructure, NemHandel, was established to support this requirement, and it is interconnected with the broader Peppol network, allowing for flexible submission methods.
More recently, the Digital Bookkeeping Act, adopted in 2022, has significantly broadened the scope of digital requirements. While there is currently no mandatory business-to-business (B2B) e-invoicing requirement, the Act mandates that businesses use certified digital bookkeeping systems capable of generating and receiving structured electronic invoices. This legislation is being implemented in phases, with most businesses, including small companies with an annual turnover exceeding DKK 300,000 for two consecutive years, expected to comply by January 2026 (or July 2026 for those using in-house accounting systems). The Danish Business Authority (Erhvervsstyrelsen or ERST) is the responsible body for these policies and the certification of bookkeeping systems. This evolution signifies a shift towards a "readiness-based" e-invoicing jurisdiction, where the emphasis is on system capability rather than a strict transaction-by-transaction mandate for B2B.