Why Denmark Is Doubling-Down on Digital Records
Denmark has long been a frontrunner in electronic invoicing for public procurement, but the new Bookkeeping Act pushes digitalisation much deeper into the private sector. The Danish Business Authority (Erhvervsstyrelsen) now insists that all accounting data live inside a certified, cloud-ready bookkeeping system—one that can create, receive and store structured e-invoices and export SAF-T audit files on demand. The goal? Sharper audit trails, fewer manual errors and easier VAT control in a world that is moving toward near-real-time reporting.
| Entity type | Obligation trigger | First compliance year |
| Companies already filing an annual report under the Danish Financial Statements Act | Using a non-registered bookkeeping system | FY starting 1 Jan 2025 |
| All VAT-registered entities—Danish and foreign | Actual net turnover > DKK 300,000 in two consecutive fiscal years | 1 Jan 2026 |
| Newly VAT-registered entities after 1 Jan 2026 | Exceed the DKK 300,000 threshold for two successive years | Rolling basis |
| Sole proprietorships & associations | Same DKK 300,000 test | 1 Jan 2026 |
| Previously exempt subsidiaries of financial & insurance companies | No special carve-out any more | 1 Jan 2026 |
Practical tip: The DKK 300,000 test is based on actual turnover—budget figures don’t count, and you cannot annualise partial-year numbers to escape the rule.
The Tech Checklist: What “Digital Bookkeeping System” Really Means
- E-invoicing muscle
Your system must support structured invoice formats such as OIOUBL or Peppol BIS 3.0 and handle both inbound and outbound flows.
- SAF-T export
Upon request from the Tax Agency (Skattestyrelsen), you must be able to produce a standard audit file containing ledger, VAT, inventory and fixed-asset data.
- Immutable storage & logs
Every entry must be timestamped, version-controlled and stored in Denmark or another EEA country that guarantees equivalent data-protection standards.
- Integration openness
APIs (often REST or SOAP) need to be available so auditors can fetch data directly, and so Peppol or ERP connectors can talk to your ledger in real time.
- Certification or registration
Suppliers can register their software with the Business Authority. If you build an in-house solution, you carry the burden of proving it meets the same criteria.
Foreign Businesses: No Danish Office? Still Danish Rules.
If you are established in Germany, the UK or the US yet hold a Danish VAT number, the moment your Danish turnover crosses the DKK 300,000 line for two years running, you must move your Danish books onto a compliant platform—or face fines that can reach DKK 1.5 million, plus possible dissolution orders for severe breaches.
Penalties and Audit Hot-Spots
- Administrative fines—scaled to turnover and severity.
- Daily coercive fines until the bookkeeping system is fixed.
- Criminal liability for management in cases of gross negligence or intent.
Expect auditors to focus on VAT boxes 1, 4 and 6, cross-checking e-invoice VAT rates against SAF-T totals and bank statement feeds.
Six Steps to Be Ready Before the Clock Strikes 2026
- Run a turnover health-check—confirm whether you will cross the DKK 300k threshold in 2024/2025.
- Map your current tech stack—ERP, invoicing tool, expense app, POS. Identify gaps.
- Select or certify a bookkeeping platform—ensure Peppol connectivity and SAF-T export.
- Clean your master data—correct VAT numbers, GL codes and customer identifiers now; bad data scales badly.
- Train your team—bookkeepers need to understand e-invoice fields and SAF-T concepts.
- Document procedures—the Bookkeeping Act requires written policies for backup, access control and retention.
Looking Forward: Denmark and Europe’s Bigger Digital Play
Denmark’s rules line up neatly with the EU’s forthcoming “VAT in the Digital Age” (ViDA) package, which foresees standardised digital reporting across Member States. Companies that get their Danish house in order will be in pole position for the next wave of EU-wide e-invoice mandates and real-time reporting obligations.
January 2026 may feel distant, but implementing a compliant digital bookkeeping ecosystem—while cleansing data, revamping processes and training staff—takes time. Treat 2025 as your test year: run dual systems, fix wrinkles early and keep auditors (and cash-flow) happy.
Have questions on selecting a system or aligning your Danish setup with multi-country VAT flows? RTC Suite’s regulatory team is just a message away.
Disclaimer:
This blog post is intended for informational purposes only and does not constitute legal, tax, or compliance advice. While every effort has been made to ensure accuracy at the time of publication, regulatory interpretations and requirements under the Danish Bookkeeping Act may evolve. Businesses operating in Denmark—or those with Danish VAT obligations—should consult with local legal or tax advisors and refer to official guidance issued by the Danish Business Authority and the Danish Tax Agency before taking action.
