Denmark’s Bookkeeping Act establishes a fully digital accounting environment, placing standardized data availability and audit readiness at the core of compliance. Within this framework, SAF-T (Standard Audit File for Tax) plays a central role as the evolving standard for structured accounting data exchange.
Rather than introducing periodic SAF-T submission obligations, Denmark focuses on ensuring that businesses maintain digitally compliant bookkeeping systems capable of generating and exporting accounting data in standardized formats when required.
Denmark SAF-T Regulation Overview
What is the SAF-T obligation in Denmark?
Under the Danish Bookkeeping Act, businesses must use digital bookkeeping systems that allow accounting data to be stored, processed, and exported in a structured and standardized manner. SAF-T has been defined as the key reference standard supporting this requirement.
The obligation does not impose routine SAF-T filing. Instead, it ensures that accounting data:
- is digitally available
- can be exported in a structured format
- is audit ready upon request by authorities
This positions SAF-T as a capability requirement, not a reporting mandate.
Denmark SAF-T Scope of Application
The SAF-T and digital bookkeeping requirements apply to:
- companies subject to the Annual Accounts Act
- businesses using certified or self-developed digital bookkeeping systems
- sole proprietorships exceeding the applicable turnover threshold
- foreign companies operating in Denmark and falling within the act’s scope
The determining factor is not company size, but whether the entity is required to maintain digital bookkeeping records under Danish law.
Current SAF-T Requirements in Denmark
Under the current framework, digital bookkeeping systems must be able to:
- generate, import, and export SAF-T files
- read and process header-level master data
- ensure that accounting data can be securely stored and retrieved
These requirements form the baseline technical compliance level for systems operating under the Bookkeeping Act today.
Denmark SAF-T 2.0 – Upcoming Developments
Denmark is actively advancing its SAF-T framework. The Danish Business Authority, in cooperation with the Danish Tax Agency, has launched a public consultation on SAF-T version 2.0.
SAF-T 2.0 aims to:
- enable export of full transaction-level accounting data
- include all relevant master data in a standardized structure
- support consistent data sharing with auditors, business partners, and public authorities
- strengthen automation and digital auditing capabilities
The consultation period closes on 1 September 2025, after which a finalized version of SAF-T 2.0 is expected to be published.
Denmark SAF-T Timeline and Applicability
The SAF-T obligation follows the phased rollout of the Bookkeeping Act:
- 1 July 2024
Medium and large companies subject to the Annual Accounts Act using certified digital bookkeeping systems - 1 January 2025
Companies using self-developed bookkeeping software - 1 January 2026
Sole proprietorships with annual net turnover exceeding DKK 300,000 for two consecutive years
From these dates onward, businesses must ensure their systems meet the digital bookkeeping and SAF-T capability requirements.
Data Retention and Security
Under the Bookkeeping Act, businesses must:
- retain accounting records and related documentation for five years from the end of the financial year
- implement appropriate technical and organizational security measures
- ensure controlled user access, data integrity, and automatic backups
There is no requirement to reproduce physical signatures where accounting records and reports are maintained digitally.
How can SNI help you about SAF-T in Denmark?
SNI’s solution has customization tables that include information required by the Danish tax authorities. By mapping these customization tables, the solution allows you to process and create e-invoices in the prescribed XML format and collect them in the user-friendly cockpit. SNI solution helps you to stay compliant with the bookkeeping regulations in Denmark.
SNI solution integrates with clients’ systems without the need for updates to existing system versions and is independent of SAP versions. SNI’s SAP solution is compatible with SAP ECC 4.7 and above, as well as SAP Business Technology Platform (BTP), SAP R3 and SAP S/4HANA. In addition, SNI provides ERP-independent solutions designed to integrate with any ERP system clients may use.
Frequently Asked Questions – Denmark SAF-T
Is SAF-T reporting mandatory in Denmark?
No. Denmark does not impose a periodic or automatic SAF-T reporting obligation. Under the Danish Bookkeeping Act, SAF-T is used as a technical capability and audit-readiness standard, not as a routine submission requirement.
Businesses are required to maintain digital bookkeeping systems that can generate and export accounting data in SAF-T format if requested by the authorities. This means SAF-T must be available on demand, typically in the context of audits or inspections, rather than being submitted monthly or annually.
What accounting data must be supported under the current SAF-T requirements?
Under the current framework (SAF-T version 1.0), digital bookkeeping systems must be able to:
- Generate, import, and export SAF-T files
- Process and read header-level master data
- Securely store accounting data in a structured format
The current requirements focus on data structure and availability, rather than full transaction-level detail. This baseline ensures that accounting records can be accessed, reviewed, and extracted in a standardized way when required by auditors or authorities.
What is SAF-T 2.0 and how will it change compliance?
SAF-T 2.0 is an upcoming enhanced version of Denmark’s SAF-T framework that is currently under consultation by the Danish Business Authority in cooperation with the Danish Tax Agency.
SAF-T 2.0 is expected to significantly expand the scope of data by enabling:
- Export of full transaction-level accounting data
- Inclusion of all relevant master data
- Improved consistency for audits and data sharing
This update aims to strengthen digital audits and automation, rather than introduce new reporting frequencies.
When will SAF-T 2.0 become applicable?
The public consultation for SAF-T 2.0 closes on 1 September 2025. Following the consultation, Danish authorities are expected to publish the final technical specifications.
While no mandatory effective date has yet been formally confirmed, businesses are strongly encouraged to prepare early. Systems that only meet the minimum SAF-T 1.0 requirements today may require further development once SAF-T 2.0 becomes the reference standard for digital bookkeeping and audits.
Does the SAF-T obligation apply to small businesses and sole proprietorships?
Yes. The SAF-T and digital bookkeeping requirements apply to sole proprietorships once they exceed an annual net turnover of DKK 300,000 for two consecutive years, effective from 1 January 2026.
For these businesses, compliance does not mean submitting SAF-T files regularly, but ensuring that their bookkeeping systems are digital, secure, and capable of exporting accounting data in SAF-T format if requested. This ensures consistent auditability across businesses of all sizes.
How is Denmark’s SAF-T approach different from other countries?
Denmark’s SAF-T model differs from many jurisdictions by emphasizing capability over submission.
In some countries, SAF-T must be submitted on a recurring basis, such as monthly or annually. In Denmark, SAF-T serves as a technical backbone for digital bookkeeping and audits. Businesses must be able to produce structured accounting data when requested, but they are not required to transmit SAF-T files proactively. This creates flexibility while still enforcing high digital compliance standards.