Denmark Regulation Recap

Denmark is progressing steadily in its digital compliance journey through the phased implementation of the Bookkeeping Act, the development of SAF-T 2.0, and the strengthening of its structured invoicing ecosystem. Although there is still no formal mandate for B2B e-invoicing, Denmark requires businesses to operate systems capable of exchanging compliant electronic documents and preparing for future EU-level interoperability needs under ViDA. The expected release of SAF-T 2.0 later this year will further standardize accounting data reporting and enhance the transparency of digital bookkeeping processes.

Timeline Overview

  • 2023–2025: Phased implementation of the Bookkeeping Act, focusing on digital bookkeeping requirements and system capabilities.

  • 2025: No legal go-live date for mandatory B2B e-invoicing; obligations concern system readiness only.

  • 2025 (ongoing): Active Nemhandel (OIOUBL) specifications and Schematron rules remain fully applicable.

  • End of 2025: SAF-T 2.0 expected to be finalized and published.

  • Future outlook: A 5-corner DCTC model may later be introduced for ViDA reporting, but no timeline exists.

Scope & Technical Requirements

Denmark currently has no confirmed go-live date or legal obligation for mandatory B2B e-invoicing. The regulatory focus remains on ensuring that bookkeeping systems are technically capable of exchanging structured e-invoices rather than obligating businesses to use a specific transmission network.

System Capabilities Required

Bookkeeping and ERP systems must support both Nemhandel (OIOUBL) and Peppol BIS 3.0 formats, as interoperability across both networks is considered a core compliance requirement. Relying solely on Peppol does not meet the current rules, since Nemhandel remains fully operational with binding specifications and Schematron validation rules. Until the final OIOUBL 3.0 specifications are released, systems are expected to maintain compatibility with both formats.

The Nemhandel infrastructure functions under a 4-corner model, mirroring the structure used by Peppol, where transactions flow directly between service providers without involvement from the Danish Business Authority. Although a 5-corner DCTC model may eventually emerge to accommodate future ViDA reporting requirements, no such mechanism has been implemented or scheduled.

SAF-T 2.0

Denmark is preparing to finalize SAF-T version 2.0 by the end of 2025, which will provide a unified standard for extracting and reporting accounting data. The update is expected to support increased transparency, more consistent auditability, and greater alignment with evolving EU digital reporting practices.

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