Denmark E-Invoicing Requirements

Enis Gencer
November 16, 2022

New bookkeeping law – Lov om bogføring

On 19 May 2022, the Danish Parliament passed a new bookkeeping law – Lov om bogføring – introducing requirements for companies to use a digital bookkeeping system.

Section 16 of the Law requires many Danish companies to use a digital bookkeeping system and make their bookings electronically. The final deadline is yet to be announced but is expected to be July 2024, with the Danish Business Authority announcing they will give businesses enough time to comply with the e-bookkeeping requirements.

Scope of Denmark’s bookkeeping law

The subjective scope of the digital bookkeeping requirements covers all companies in Denmark that are liable for accounting according to section 3(1) of the Financial Statements Act. Moreover, other companies whose net turnover exceeds DKK 300,000 in two consecutive income years are subject to digital bookkeeping requirements. Finally, the rules cover bookkeepers and others who carry out bookkeeping for other companies.

These companies will be required to record company transactions and store records in a digital bookkeeping system. Companies can use a digital bookkeeping system registered with the Danish Business Authority, Erhvervsstyrelsen, or any other bookkeeping system. However, companies who choose the latter option must ensure their systems meet the requirements according to Law for digital bookkeeping systems.

Potential e-invoicing mandate and PEPPOL

While the new bookkeeping law doesn’t introduce any mandatory e-invoicing or continuous transaction controls (CTC) obligations for businesses, it is envisaged that the digital bookkeeping systems must support continuous registration of the company’s transactions and the automation of administrative processes. This includes automatic transmission and receipt of e-invoices.

This requirement was further detailed in the draft executive order on requirements for standard digital bookkeeping systems, which outlines that the taxpayers:

  • send electronic invoices in OIOUBL and Peppol BIS format,
  • receive electronic invoices in OIOUBL and Peppol BIS format,
  • send electronic credit notes in OIOUBL and Peppol BIS format,
  • receive electronic credit notes in OIOUBL and Peppol BIS format,
  • send an application response on receipt of an electronic invoice
  • send a message-level response when receiving an electronic invoice, and
  • send an invoice response on receipt of an electronic invoice.

Moreover, the new bookkeeping law authorised the Minister for Industry, Business, and Financial Affairs to introduce rules:

(a) that require companies to record their transactions regarding purchases and sales with e-invoices as documentation of the transactions,

(b) on transmission of records by digital bookkeeping systems to a public receiving point through the shared public digital infrastructure for the exchange of e-documents and the storage of such records.

What’s next for Denmark?

Although Denmark’s e-invoicing journey is still in the early phases, it seems that the new bookkeeping law and requirements for digital bookkeeping systems lay the foundation for a future e-invoicing mandate to be duly introduced by the Minister for Industry, Business, and Financial Affairs.

It will be interesting to see how and when Denmark’s plans for e-invoicing will take shape and be affected by the upcoming results from the EU Commission on the VAT in the Digital Age project.

Need help for E-invoicing in Denmark?

If you have any question about Denmark’s new bookkeeping law or e-invoicing requirements in Denmark, please reach out to us: Speak to our tax experts.

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Author

Enis Gencer

Enis Gencer is Regulatory Counsel at Sovos and is based in Istanbul, Turkey. With experience in compliance and legal consultancy he currently undertakes the legal monitoring and analysis of the regulations regarding electronic documents. Enis graduated from Istanbul University Faculty of Law.
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