The Danish Business Authority has published the executive order setting out the next wave of requirements for registered standard digital bookkeeping systems. The final text departs from the earlier consultation draft in one significant respect: the main body of requirements, originally slated to take effect on 1 January 2027, will now apply from 1 March 2027. A second set of obligations follows from 1 January 2028.
Executive Order no. 811, read together with the implementation guidelines issued by the Authority, confirms the revised sequencing. Beyond the timeline change, several requirements consulted on earlier have been amended, and a number of new obligations now appear in the final text.
What Applies from 1 March 2027
From the first application date, standard digital bookkeeping systems will need to support the following:
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Default Nemhandel registration with an opt-out window. Where an end-customer is not already registered for e-invoicing, the system must inform them — as part of the MitID validation step — that registration will proceed automatically unless they opt out within four weeks.
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Visibility of recipient e-invoicing status at the point of issuance. When a user creates an invoice manually, the system must make clear whether the recipient appears in the Nemhandelsregister.
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Identity verification via MitID. Customers and end-customers registered in the CVR — both new and existing — must confirm their identity using MitID.
What Applies from 1 January 2028
A second tranche of requirements takes effect ten months later:
MitID authentication for supplementary master data changes. Any user adding or amending supplementary master data for a CVR-registered customer or end-customer must authenticate through MitID.
CVR master data on electronic business documents. Where the customer is registered in the CVR, the system must populate electronic business documents with that registered master data by pulling the information directly from the CVR, and must prevent users from editing it. Systems must also be capable of carrying relevant supplementary master data.
Next Steps
Providers of registered standard systems should align their development roadmaps to the two application dates and consult Executive Order no. 811 and the implementation guidelines for the full technical detail.
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