Denmark has chosen not to impose a general domestic B2B e-invoicing mandate. Instead, it is making e-invoicing the easiest option inside the software businesses already use. A new executive order from the Danish Business Authority (Erhvervsstyrelsen) adds requirements for registered digital bookkeeping systems in two phases. From March 2027, providers must verify their customers with MitID (Denmark’s national digital ID) and enrol them for e-invoice receipt in NemHandel (Denmark’s public e-invoicing infrastructure) unless they opt out. From January 2028, a further set of rules protects company master data and accounting records.
The obligations fall on software providers, but every Danish business using a registered system will notice the change.
| Date | Milestone |
| 22 September 2026 | Executive order amending the requirements for registered bookkeeping systems adopted |
| 25 September 2026 | Implementation guidance for providers published |
| Early 2027 | Information letter sent to businesses via Digital Post (Denmark’s official digital mailbox) |
| 1 March 2027 | Phase 1: MitID verification, default NemHandel enrolment, e-invoice option shown when invoicing |
| 1 January 2028 | Phase 2: master data protection, record retrieval, deletion ban |
| 1 July 2030 | EU ViDA rules make e-invoicing mandatory for intra-EU B2B transactions |
Why Denmark Is Taking This Route
Denmark already has the infrastructure for e-invoicing. What it lacks is reach: many businesses are not registered to receive e-invoices, so their suppliers keep sending PDFs. The new rules target that gap directly. If businesses are enrolled by default and senders can see at a glance who can receive an e-invoice, structured invoicing can spread without a legal mandate.
There is also a deadline in the background. Under the EU’s VAT in the Digital Age (ViDA) package, e-invoicing will be mandatory for trade with businesses in other EU countries from 1 July 2030. The Danish Business Authority presents the new requirements as a way to prepare businesses for that date while letting them capture cost savings now.
Who Is Affected
The requirements apply to providers of registered digital standard bookkeeping systems. The executive order introduces a few terms that define who the provider must deal with:
- End customers: the businesses whose bookkeeping takes place in the system.
- Customers: anyone with a direct contract with the provider, including end customers and accounting firms that keep books on their behalf.
- Users: the individual people with rights to post entries in the system.
- Locked master data: the end customer’s registration details as they appear in CVR (Denmark’s central business register), meaning its CVR number, any P-numbers (production unit numbers), name, secondary names and address.
- Supplementary master data: the end customer’s bank details and any SE number (a Danish tax registration number) or GLN number (Global Location Number).
The distinction between companies and individual users matters, because some checks apply to the business once and others apply to every person who makes a change.
Phase 1: From 1 March 2027
One-time MitID verification of every business
Providers must confirm the identity of all end customers and customers registered in CVR through MitID. New customers verify when they are created in the system. Existing customers must verify before they can access the system again. During verification, the business also confirms its registered company details.
This is a one-time check, not a MitID login at every session. The provider must log each verification, including time, type and the user who performed it, and be able to hand the log over during an inspection. To use MitID, the provider needs an agreement with an approved MitID broker. Foreign businesses are outside this requirement for now, as the authority is waiting for a common EU business identification solution.
Default enrolment in NemHandel with a four-week opt-out
Once a business has been verified, the provider must enrol it as an e-invoice recipient in NemHandel unless it is already registered there or actively declines. The process runs in three steps:
- Notice. After verification, the business is told that it will be enrolled unless it opts out within four weeks. The provider can keep this message short and refer to the authority’s information letter for details.
- Enrolment. For every business that has not opted out, the provider completes registration within the following four weeks, even if it sent a similar notice under the old rules.
- Confirmation. As soon as NemHandel confirms the registration, the provider informs the business and explains where incoming e-invoices will appear. Speed matters here, since an unaware business may miss invoices sent to its new address.
The guidance also covers practical choices:
- Endpoint: the CVR number should be the default endpoint (receiving address). P-numbers, SE numbers or GLN numbers can be used where the business needs invoices routed by unit or managed in more detail.
- Ownership: businesses should own their endpoint identifiers, rather than use numbers owned by the provider, so they can move to another system later.
- Existing registrations: a business already registered through another system does not have to be moved.
- Tracking: the provider must keep track of who opted out, and both opt-out and later opt-in must remain possible at any time.
Showing the e-invoice option when invoicing
When a user creates an invoice manually, the system must clearly show that the recipient can receive an e-invoice if it is registered in NemHandel. Sending an e-invoice remains voluntary. The requirement does not apply to automated invoicing, such as batch runs or invoices triggered through an API from another system. Where a recipient has many registered endpoints, the system does not have to choose the right one. That is for the sender and recipient to agree.
The guidance lists this requirement in the March 2027 phase, although a note later in the same document refers to January 2028. Providers should plan for the earlier date.
Phase 2: From 1 January 2028
MitID for every change to bank and identifier data
Any addition or change to an end customer’s supplementary master data, such as bank account details, requires MitID verification of the specific user making the change. Verifying the business is not enough. The aim is to make sure that a change to payment details can always be traced to a person.
Locked company data from CVR
The system must look up the end customer’s details in CVR automatically and must not allow users to edit them. If the details are wrong, the business corrects them through Virk (the Danish public business portal), and the change flows back into the system, usually within minutes. This prevents a business from presenting itself as another company.
CVR data on every outgoing document
Electronic business documents sent from the system, including invoices, must carry the sender’s locked CVR data: name, address and CVR number. Where a business has several production units, the user can choose which unit’s details appear on the document.
Records that can be found and exported per business
The provider must make sure that every booked transaction and voucher can be linked to the business it belongs to and searched by its master data. The business must be able to extract all of its records, for example when switching systems. When data is handed to an authority, the extract must clearly separate one business’s records from others’, and every search and export must be traceable. The authority describes this as a clarification of existing law.
No deletion of documents
Users must not be able to delete sent or received documents and vouchers. The protection now also applies before a document has been booked, closing a gap where invoices could disappear before entering the accounts.
What Providers Should Do Now
Phase 1 leaves little time, and most of the work sits with providers:
- Sign a MitID broker agreement and build the one-time verification and logging flow.
- Prepare the opt-out notice, the enrolment run and the confirmation message, and decide whether to use the NemHandel registration API or a service provider.
- Integrate the NemHandel lookup service into the manual invoicing flow.
- Plan the CVR integration, user-level MitID checks and deletion controls for 2028.
For businesses, the practical change is simple: unless they opt out, they will start receiving e-invoices in their bookkeeping system during 2027. Setting up internal processes to handle these invoices now will make the transition smoother, and it is also good preparation for the cross-border e-invoicing obligations that ViDA brings in 2030.
As a certified Peppol Access Point, RTC supports businesses and software providers preparing for structured e-invoice exchange in Denmark and across Europe.
