1. Introduction to Denmark’s Bookkeeping and SAF-T Requirements
Denmark introduced the Standard Audit File for Tax (SAF-T) reporting under its Bookkeeping Act in July 2022. The requirement mandates businesses to digitally report their tax and financial data to Denmark’s tax authority, SKAT, in a standardized electronic format, enhancing transparency and compliance.
1.1 Purpose and Scope of SAF-T in Denmark
The Danish Business Authority (Erhvervsstyrelsen) oversees SAF-T, aligning with the OECD SAF-T version 2 model. Denmark joins 12 other countries in adopting this international format to streamline financial audits, facilitate data exchanges, and reduce tax evasion.
2. Entities Under the Scope of SAF-T Legislation
All businesses that are legally obliged to maintain bookkeeping systems are subject to SAF-T requirements. Importantly, Denmark employs a demand-based approach, meaning that companies are only required to submit SAF-T files upon explicit request from the tax authorities.
3. Implementation Timeline for Digital Bookkeeping
Denmark is implementing digital bookkeeping in several phases:
3.1 Initial Phases of Compliance
- 1 February 2023: Digital standard accounting system requirements became mandatory.
- 31 October 2023: Registration deadline for providers of standard bookkeeping systems.
- 1 January 2024: A public list of approved digital accounting systems is published by the Danish Business Authority.
3.2 Mandatory Digital Bookkeeping for Companies
- 1 July 2024: Companies submitting annual reports under the Danish Financial Statements Act must adopt digital accounting, based on their financial year start date (e.g., 1 July 2024, 1 January 2025, or 1 April 2025).
- 1 January 2025: Companies using customized bookkeeping solutions, such as public limited companies, limited partnerships, private limited companies, commercial foundations, and similar entities, must digitize their bookkeeping.
- January 2026: Sole proprietorships, partnerships, and financial companies with turnover exceeding DKK 300,000 in the two preceding income years (2024 and 2025) must adopt digital bookkeeping.
4. Submission Methods and Frequency for SAF-T
4.1 SAF-T Submission Channels
When requested, businesses must submit SAF-T files through official channels such as TastSelv Erhverv, SKAT’s official self-service portal. Alternative methods include integration via web services (REST APIs) or secure FTP gateways, which facilitate direct electronic submissions. Additionally, SKAT offers a validation service, allowing businesses to test files in a sandbox environment prior to actual submission.
4.2 Accessing the Submission Portal
Businesses can log into TastSelv Erhverv using:
- MitID
- Personal MitID for businesses
- E-tax password (self-key)
4.3 Frequency of SAF-T Submission
Submission frequency is demand-driven. Businesses must submit files as instructed by tax authorities, with deadlines provided in each specific request.
5. Technical Specifications and SAF-T Structure
5.1 Structure of Danish SAF-T Schema
SAF-T files in Denmark include:
- Header (mandatory)
- Master File (optional, expected mandatory)
- General Ledger accounts (optional, expected mandatory)
- Source Documents (optional, expected mandatory)
The Danish Tax Agency highlights a discrepancy in the current technical description, emphasizing that future updates will mandate comprehensive data, including master data and general ledger accounts, to facilitate data transfers between systems effectively.
5.2 SAF-T Format and Validation
- Denmark’s SAF-T files follow the OECD SAF-T V.2 XML format.
- Currently, no file-splitting rules are defined.
- Authorities may request additional documents for comprehensive audits, suggesting current files alone are not sufficient.
6. Key Authentication and Procedural Points for SAF-T Submission
- Official Portals: SAF-T files must be submitted via authorized portals such as TastSelv Erhverv (skat.dk) or Virk.dk. Submissions via email are not accepted.
- Authentication Requirements: Login via MitID/NemID or equivalent verified business credentials.
- Automated Submission: Systems integrating via API or SFTP require authentication using trusted certificates or tokens provided by SKAT.
- XML Format and Encoding: Compliance requires using the official XML schema (Danish SAF-T Financial Data, version 1.0) and the recommended standard chart of accounts (Standardkontoplan) mappings for accuracy.
7. Implications and Recommended Actions for Businesses
Businesses operating in Denmark must proactively prepare by:
- Reviewing and updating existing accounting systems to comply with upcoming mandatory components.
- Monitoring regulatory updates from the Danish Business Authority and SKAT.
- Utilizing available validation services to minimize submission errors.
Early compliance ensures efficient management of digital tax reporting obligations and reduces operational disruptions, positioning businesses for smoother audits and improved regulatory alignment.
