The Danish Business Authority has published a draft executive order amending the requirements for registered digital standard bookkeeping systems. The proposal introduces new obligations aimed at accelerating the voluntary adoption of e-invoicing ahead of the EU’s VAT in the Digital Age (ViDA) deadline of 1 July 2030. The final order expected to be published in early September 2026.
Scope
The proposed requirements apply exclusively to digital standard bookkeeping systems that must be registered with ERST under the Danish Bookkeeping Act. They do not extend to custom or non-registered bookkeeping systems, such as ERP systems used by enterprises that fall under a separate compliance framework.
E-Invoicing Requirements
The draft introduces two key changes to how e-invoicing is handled within registered systems:
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Opt-out registration in Nemhandel: Registered systems in scope must register all end customers for e-invoicing in the Nemhandelsregistret unless the end customer is already registered or actively opts out within a four-week window. This replaces the current opt-in model. Existing end customers must be notified by 30 November 2026 and will be registered by 1 January 2027 unless they opt out. New end customers onboarded after 30 November 2026 are subject to the same four-week opt-out process from the point of onboarding.
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E-invoice as default sending option: Registered systems must automatically check whether an invoice recipient is registered in Nemhandel at the time of invoicing and, if so, present e-invoicing as the first/default sending option. Sending remains voluntary — the requirement is one of system presentation, not transactional obligation.
Additional Security and Data Integrity Requirements
The draft also introduces a set of supplementary requirements designed to strengthen trust in the e-invoicing infrastructure:
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Identity verification: Registered systems must verify the identity of all end customers, customers, and individual users via MitID. This applies both at onboarding and, for existing users, at first login following the order’s entry into force. MitID verification is also required each time supplementary master data — such as payment details or GLN/EAN numbers — is added or amended.
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Master data integrity: Locked master data (CVR number, company name, and address) must be sourced directly from the CVR register and may not be edited within the bookkeeping system. All outgoing electronic business documents must carry the end customer’s locked and supplementary master data.
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Searchability: Bookkeeping material must be uniquely attributable to each end customer and searchable by their master data identifiers.
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Record retention: Users must not be able to delete documents or vouchers stored in the system.
Implementation Timeline
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30 November 2026 – Deadline for providers to notify existing end customers of upcoming Nemhandel registration; new end customers onboarded from this date are subject to the four-week opt-out process.
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1 January 2027 – All remaining new requirements enter into force; existing end customers are registered in Nemhandel unless they have opted out.
What This Means
The proposal does not introduce a general obligation for Danish businesses to issue or receive B2B e-invoices. Instead, it expands the technical and process requirements for registered bookkeeping systems to make e-invoicing more accessible and the default path. ERST estimates that the measures will bring approximately 125,000 additional businesses into Nemhandel, roughly doubling current registrations and realising around 20% of the potential administrative savings from full e-invoicing adoption — estimated at up to DKK 9 billion annually. The changes reflect Denmark’s broader trajectory toward full B2B e-invoicing mandated under ViDA by 2030.
