Denmark sets the requirements for non-registered digital bookkeeping systems, including Nemhandel and Peppol e-invoicing, from 1 January 2025 (BEK nr. 205/2024)
This page records one dated change. For the rules in Denmark as they stand today, see the Denmark guide →
- Jurisdiction
- Denmark
- Tax
- VAT
- Change type
- E-invoicing
- Status
- In force
- Impact
- FYI
- Announced
- 2 March 2024
- Effective
- 1 January 2025
- Authority
- Erhvervsstyrelsen (Danish Business Authority)
- Verified
- Fetched from official source · high confidence
Danish businesses subject to the digital bookkeeping duty that use a non-registered system, such as one developed for the business itself, rather than a registered standard system.
No action — historical reference. Danish businesses using non-registered digital bookkeeping systems must have complied since 1 January 2025, including e-invoice send/receive capability via Nemhandel.
BEK nr. 205 af 29. februar 2024 (Bekendtgorelse om krav til virksomheders digitale bogforingssystemer der ikke er registreret efter bogforingsloven), issued under lov nr. 700 of 24 May 2022, sets technical requirements for companies using non-registered digital bookkeeping systems, effective 1 January 2025 (§ 7). Under § 5, the system must be able to send and receive e-invoices via Nemhandel in OIOUBL format and Peppol BIS format, and issue application-response and invoice-response messages.
What changed in detail
Executive order BEK nr. 205 of 29 February 2024, issued by Erhvervsstyrelsen under sections 15(2) and 33(3) of the Bookkeeping Act (lov nr. 700 of 24 May 2022), was published in Lovtidende A on 2 March 2024. Under § 7 it enters into force on 1 January 2025.
It applies to businesses covered by section 16(1) of the Act that use a non-registered digital bookkeeping system. The business itself, not a software provider, must make sure the system:
- records for each transaction its date, amount, voucher number, text and exchange rate, and assigns a registration date, a sequential number and the initials of whoever posted it (§ 3);
- prevents users from changing, backdating or deleting posted transactions, and stores vouchers showing issue date, nature of supply, amount, sender and recipient with CVR or SE number, VAT amount and payment details (§ 3);
- takes a full backup at least weekly, held by an unrelated party on a server in the EU or EEA (§ 4);
- can automatically send and receive e-invoices and credit notes via Nemhandel in OIOUBL format and in Peppol BIS format, with the matching response messages; can generate a SAF-T file; and supports bank reconciliation (§ 5).
Breaches of §§ 3 to 5 are punishable by a fine (§ 6).
What it means
The order has applied since 1 January 2025 and is still in force. BEK nr. 303 of 20 March 2025 amended the backup rule from 1 January 2026: the exemption from third-party storage now covers financial, insurance and ATP businesses, and their subsidiaries whose backups follow the parent’s rules on a group-linked system.
Annual-report companies on a non-registered system have been in scope since their first financial year starting on or after 1 January 2025, under BEK nr. 1342/2023. The e-invoicing duty in § 5 is a capability requirement: the system must be able to send and receive Nemhandel and Peppol invoices, even where trading partners still use other channels.
Proof
§ 7. Bekendtgørelsen træder i kraft den 1. januar 2025.§ 7. This executive order takes effect on 1 January 2025.
Source snapshot of the official page. Open full size ↗Archived from the official distribution · BEK nr. 205 af 29. februar 2024 (Lovtidende A, udgivet 2. marts 2024) · retsinformation.dk