In March 2025, the Danish Business Authority issued new executive orders that extend the digital bookkeeping obligation to a wider range of entities. At the same time, the final rollout of OIOUBL 3—the country’s upgraded e-Invoicing standard—has been officially postponed to October 2025.
These developments highlight Denmark’s continued commitment to digital transformation in tax and financial reporting. Below is a breakdown of the most important updates and what businesses need to do to prepare.
1. Digital Bookkeeping Mandate Now Covers More Entities
In March 2025, Denmark issued Executive Order no. 297 and Executive Order no. 303. These orders broaden the scope of businesses subject to digital bookkeeping under the Danish Bookkeeping Act. These changes aim to create a more unified, transparent financial reporting landscape across sectors.
Who Is Included Under the New Digital Bookkeeping Mandate?
- Sole Proprietorships: Individuals operating a business with an annual turnover exceeding DKK 300,000 for two consecutive financial years.
- Associations and Foundations Engaged in Commercial Activity: Entities conducting business activities with a revenue of more than DKK 300,000 annually over a period of two years.
- Subsidiaries of Financial Institutions (e.g. banks, pension funds, and insurers): These institutions were previously exempt due to consolidated accounting systems at the group level.
These newly included entities must implement compliant digital bookkeeping systems by January 1, 2026. As a result, the regulation now will be apply to an estimated 118,000 additional businesses.
2. Final Release of OIOUBL 3 Pushed to October 2025
Denmark has also delayed the final publication of OIOUBL 3, the latest version of its national e-Invoicing format. Initially planned for April 10, 2025, the launch has now been rescheduled to October 2025.
2.1. What’s Changing in OIOUBL 3?
The updated format introduces several structural and technical enhancements:
- Required Two-Way Communication: All public sector recipients must be capable of both sending and receiving invoice-related messages through a designated digital endpoint.
- Improved Alignment with EN 16931: The format has been further harmonized with the European e-Invoicing standard EN 16931. This involves refinements to data field structures, tax calculation methods, and the overall formatting of invoice content.
2.2. Why the Delay?
The Danish Business Authority attributed the postponement to stakeholder feedback and the need for further technical clarification to ensure the updated format meets regulatory and operational expectations.
Denmark’s push toward greater financial digitization through extended digital bookkeeping mandates and an updated e-Invoicing format is a clear signal for to be prepared. Although the implementation deadlines are months away, early action is essential to ensure seamless compliance and avoid penalties.
