Denmark Moves New E-Invoicing System Requirements to March 2027
Denmark has moved the start date for new requirements on registered digital bookkeeping systems from 1 January to 1 March 2027. The changes are designed to make e-invoicing easier for businesses to adopt, but they do not introduce an e-invoicing mandate.
Under the new rules, providers of registered bookkeeping systems must tell customers that they will be enrolled for e-invoicing through the NemHandel register unless they opt out. Businesses will have four weeks from their first login after 1 March 2027 to decline registration. Providers must also make it clear, when a user creates an invoice manually, whether the recipient is registered to receive an e-invoice.
The change applies to system providers, rather than imposing a new obligation on businesses to send every domestic invoice electronically. Companies enrolled through NemHandel can still agree other invoice methods with their customers and suppliers. However, the Danish Business Authority says a business cannot reject an otherwise correct invoice solely because it arrives as an e-invoice.
Finance and AP teams should ensure their invoice processes are ready for more suppliers to send structured invoices directly into their systems. Businesses using customised, non-registered bookkeeping systems will not be enrolled automatically through this measure, although they remain responsible for meeting the digital bookkeeping requirements that apply to their systems.
The Business Authority is also encouraging wider use of e-invoices, including by businesses that issue recurring invoices. KPMG expects adoption to increase during 2027, but that is an assessment of likely business practice, not a new domestic B2B e-invoicing mandate.
Separately, KPMG reports that Denmark plans to replace its existing OIOUBL and Peppol BIS invoice formats with a single Peppol-based specification. It says the transition is expected to begin in mid-2028, with the existing formats phased out by mid-2029.
This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.
