Denmark Proposes New Requirements for Digital Bookkeeping Systems
Friday 7th August, 2026
The Danish Business Authority is proposing amendments to the requirements of standard digital bookkeeping systems (DBS), as part of efforts to increase voluntary adoption of e-invoicing.
Most new requirements are proposed to become mandatory from 1 January, 2027. Although, requirements are not proposed for custom digital bookkeeping systems as this stage.
Under the draft, most requirements would apply from 1 January, 2027, while provisions relating to notifications to new and existing end customers would apply from 30 November, 2026.
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 present e-invoicing as the 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 e-invoices. Instead, it expands the requirements for registered standard DBS to make e-invoicing more accessible, prominent, and secure.
The proposal is currently under public consultation until 17 August, 2026. The Danish Business Authority expects the final executive order to be issued in early September 2026.
