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Denmark's e-invoicing regulation timeline

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Executive summary

Denmark was the first country in Europe to mandate B2G e-invoicing, effective February 2005, and now sits at the threshold of broader B2B digitalization. The country operates a mature e-invoicing infrastructure through NemHandel and PEPPOL, using OIOUBL 2.1 and PEPPOL BIS Billing 3.0 as accepted formats. The January 2026 cancellation of OIOUBL 3.0 signals a strategic pivot toward PEPPOL as the single unified standard. NemHandel / PEPPOL is mandatory for all invoices to public authorities. It is the longest-standing B2G e-invoicing mandate in Europe, enforced since 2005. Digital Bookkeeping Act requires all businesses to use certified digital bookkeeping systems capable of sending and receiving structured e-invoices in PEPPOL BIS 3.0 and OIOUBL formats, with rollout completing in 2026. There is currently no B2B e-invoicing transmission mandate in Denmark — the Bookkeeping Act creates a capability requirement, not a usage mandate. A domestic e-reporting obligation is expected by approximately 2028. Denmark has a single flat 25% VAT rate (moms) with no reduced rates, and uses a post-audit compliance model with no real-time reporting to tax authorities.

Invoicing in Denmark

Denmark’s e-invoicing framework is straightforward by European standards: a strong, well-established B2G mandate built on NemHandel and PEPPOL, paired with a progressive Bookkeeping Act that requires all businesses to be e-invoicing-capable. There are no regional fiscal variations — the framework applies uniformly across Denmark (excluding Greenland and the Faroe Islands, which have their own independent tax systems).
  • NemHandel / PEPPOL mandatory since February 2005 for all invoices to Danish public authorities.
  • Digital Bookkeeping Act requires certified digital bookkeeping systems capable of e-invoicing, phased in through 2026 for all businesses with turnover above DKK 300,000.
Denmark has no B2B e-invoicing transmission mandate as of 2026. The Bookkeeping Act requires e-invoicing-capable systems but does not mandate that every B2B invoice is sent electronically. A domestic e-reporting obligation is expected by approximately 2028.
Suppliers invoicing Danish public authorities must submit electronic invoices via NemHandel or the PEPPOL network. Paper invoices are rejected outright. Public entities are identified by an EAN/GLN number registered in the NemHandelsregisteret (NHR). Denmark is a PEPPOL member and the NHR is integrated with the PEPPOL SML, so public authorities are reachable via both NemHandel and PEPPOL. Accepted formats are OIOUBL 2.1 and PEPPOL BIS Billing 3.0. NemHandel is managed by the Danish Business Authority (Erhvervsstyrelsen), which also serves as Denmark’s PEPPOL Authority.
ScopeB2G
FormatOIOUBL 2.1, PEPPOL BIS Billing 3.0
Compliancee-invoicing
InfrastructureNemHandel / PEPPOL (four-corner model)
ModelDecentralized (access point network)
Effective dateMandatory since February 2005
AgencyErhvervsstyrelsen (ERST) / Digitaliseringsstyrelsen
Invopop supportPEPPOL App
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The Digital Bookkeeping Act is being phased in through 2026. All businesses with annual turnover exceeding DKK 300,000 must use a compliant digital bookkeeping system from January 1, 2026.
Denmark’s 2022 Bookkeeping Act requires businesses to use certified digital bookkeeping systems capable of sending and receiving structured e-invoices in PEPPOL BIS 3.0 and OIOUBL formats. This is a capability mandate: systems must support e-invoicing, but there is no requirement that every invoice is transmitted electronically. Systems must also support SAF-T exports on demand and perform automated weekly backups to a secure, EU/EEA-hosted server.
ScopeB2B, B2G (capability requirement, not transmission mandate)
FormatPEPPOL BIS Billing 3.0, OIOUBL 2.1
ComplianceDigital bookkeeping and e-invoicing readiness
InfrastructurePEPPOL / NemHandel
ModelPost-audit with SAF-T on demand
Effective datePhased rollout, completing January 1, 2026 for most businesses
AgencyErhvervsstyrelsen (ERST)
Invopop supportPEPPOL App, upcoming SAF-T support.
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E-reporting

There is no real-time reporting to tax authorities — SAF-T exports are provided on demand during SKAT inspections. Formal system certification is not required, though an ISAE 3402 audit declaration based on a SKAT template is recommended for documentation. Non-compliance triggers fines starting at DKK 10,000, escalating for repeated violations.

Regulation

Danish invoice requirements implement EU VAT Directive Article 226 through the Momsloven (Danish VAT Act) and Momsbekendtgørelsen (Ministerial Order on VAT). A full invoice is required for B2B sales of DKK 3,000 or more (incl. VAT) and B2C sales exceeding DKK 5,000.Full Invoice
  • Supplier’s full name and address, and CVR number (8-digit business registration number; formatted as DK + 8 digits for EU VAT purposes).
  • Buyer’s full name and address. For intra-EU B2B transactions, the buyer’s VAT number must also be included.
  • Sequential invoice number — unique and part of an ongoing series.
  • Invoice date (date of issue).
  • Delivery / supply date if different from the invoice date.
  • Clear description of the goods delivered or services provided, including quantity and unit price excluding VAT.
  • Any discounts not already included in the unit price.
  • Taxable base — total price excluding VAT.
  • VAT rate applied (25%).
  • VAT amount in DKK or EUR. If the invoice is in another currency, the total Danish VAT must additionally be stated in DKK or EUR, along with the exchange rate used.
  • Total amount including VAT.
  • For reverse charge transactions: a reference to the applicable provision and the customer’s VAT number.
  • For VAT-exempt or zero-rated supplies: a reference to the applicable VAT Act provision (e.g. “0% VAT — intra-Community supply, Momslovens §34”).
Simplified InvoicePermitted for B2B sales below DKK 3,000 or B2C sales up to DKK 5,000:
  • Supplier’s name, address, and CVR number.
  • Invoice date.
  • Description of goods or services.
  • Total amount including VAT and VAT rate, or the statement “moms inkluderet” (VAT included).
Under the Bogføringsloven (Danish Bookkeeping Act), all accounting records — including invoices, receipts, and supporting documentation — must be retained for 5 years from the end of the financial year to which they relate. Records must be stored in a structured, machine-readable format that cannot be altered, backdated, or deleted. The Act requires automated weekly backups to a secure server hosted within the EU/EEA by an independent third party.Note that certain sectors or EU-funded projects may require longer retention under specific grant terms or sectoral regulations.
Denmark levies a single flat VAT rate with no reduced rates — one of the simplest VAT structures in the EU.
  1. Moms (Merværdiafgift) — Standard rate: 25%
    • Applies to all taxable goods and services. There are no reduced rates.
  2. Zero-rated supplies (0%, with input VAT recovery) under Momslovens §§34–36:
    • Exports of goods outside the EU
    • Intra-Community supplies of goods to VAT-registered buyers in other EU member states
    • International passenger transport
    • Certain seagoing vessels and aircraft
    • Newspapers and periodicals (below a certain threshold of advertising content)
  3. VAT-exempt supplies (no VAT charged, no input VAT deduction) under Momslovens §13:
    • Healthcare and medical services
    • Education
    • Financial and insurance services
    • Domestic passenger transport (taxis, buses, scheduled domestic aviation)
    • Postal services (universal service obligation)
    • Residential letting
    • Cultural activities (theatre, concerts, museums)
    • Gambling and lottery
Denmark does not apply VAT in Greenland or the Faroe Islands. Transactions between Denmark proper and these territories are treated as exports/imports.
OIOUBL (Offentlig Information Online – Universal Business Language) is Denmark’s national e-invoicing standard, based on OASIS UBL 2.0. The current version, OIOUBL 2.1, has been in mandatory use since May 2022 and constitutes Denmark’s Core Invoice Usage Specification (CIUS) under EN 16931. It supports invoices, credit notes, reminders, and additional business documents with Danish-specific fields beyond the base PEPPOL BIS format.Both OIOUBL 2.1 and PEPPOL BIS Billing 3.0 are accepted for B2G transactions. Updated Schematron validation rules (v1.17) become mandatory from May 15, 2026.OIOUBL 3.0, published as a release candidate in November 2024, was formally cancelled on January 14, 2026 by Erhvervsstyrelsen. The decision followed feedback from service providers that maintaining two parallel standards was operationally unsustainable. Denmark is now converging on a single PEPPOL-aligned standard — likely based on PEPPOL PINT or a Danish National CIUS of EN 16931. Further details will be published by Erhvervsstyrelsen once the technical specification is finalized.
Denmark introduced electronic sales registration (ESR) requirements effective January 1, 2024, targeting businesses with annual turnover between DKK 50,000 and DKK 10 million in specific sectors: cafés, pubs, nightclubs, restaurants, fast food establishments, ice cream parlors, grill bars, and grocery stores/kiosks. Approximately 12,500 businesses are affected.POS systems in scope must:
  • Record all transactions in an immutable electronic journal.
  • Store data in SAF-T format.
  • Digitally sign transactions using an OCES certificate.
  • Separate sales totals by payment method.
There is no real-time reporting to tax authorities — SAF-T exports are provided on demand during SKAT inspections. Formal system certification is not required, though an ISAE 3402 audit declaration based on a SKAT template is recommended for documentation. Non-compliance triggers fines starting at DKK 10,000, escalating for repeated violations.
Denmark’s VAT law and e-invoicing regulations apply to Denmark proper only. Both Greenland and the Faroe Islands are autonomous territories within the Kingdom of Denmark with independent tax legislation.Greenland is not part of the EU (it withdrew from the EEC in 1985). It has no VAT or sales tax. Corporate income tax is 31.8%. Supplies from Denmark to Greenland are treated as exports (zero-rated for Danish VAT); supplies from Greenland to Denmark are imports subject to 25% moms. Greenland is not subject to the Danish Bookkeeping Act or NemHandel requirements.The Faroe Islands never joined the EU and operate their own VAT system called MVG (meirvirðisgjald), levied at 25% and administered by the Faroese tax authority TAKS (Skattistovan). Corporate tax is 18%. The Faroe Islands have no mandatory e-invoicing requirements and are not subject to Danish bookkeeping legislation.

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