Denmark Plans For E-invoicing by Default Approach
Tuesday 15th September, 2026
The Danish Business Authority, Erhvervsstyrelsen has completed a consultation on proposed amendments to the regulation governing registered digital standard bookkeeping systems.
Rather than immediately introducing a general B2B e-invoicing mandate, Denmark proposes to make electronic invoicing the default option within the software used by businesses.
Automatic registration in the Nemhandel Register: Under the first element of the proposal, providers of registered digital standard bookkeeping systems would be required to enrol business customers using their systems in the Nemhandel Register for e-invoicing.
The Danish Business Authority has consulted on amendments requiring providers of registered digital bookkeeping systems to enrol business customers automatically in the Nemhandel Register, unless the customer actively opts out. The proposed rules would apply from 1 January 2027
Registration in the Nemhandel Register makes a business electronically discoverable and allows trading partners to determine whether it can receive structured electronic business documents. Nemhandel is Denmark’s common infrastructure for exchanging electronic documents between businesses and public authorities.
E-invoice to become the first delivery option: The second element concerns how an invoice is sent from a digital standard bookkeeping system. When a user creates an invoice, the system would be required to check automatically whether the recipient is registered in the Nemhandel Register.
The proposal also contains supplementary security measures intended to increase confidence in electronic invoicing.
Part of Denmark’s broader e-invoicing transition: The opt-out proposal should also be viewed alongside Denmark’s planned migration towards a unified e-invoicing specification based on Peppol BIS 4.
The transition is expected to take place between 2028 and 2029, with the existing OIOUBL 2.1 format ultimately being phased out. The objective is to align Denmark more closely with international Peppol standards and prepare its invoicing environment for the structured data and interoperability requirements associated with ViDA.
