Denmark Proposes Opt-Out Peppol Model
Denmark is proposing a significant change to its digital bookkeeping framework that could make structured e-invoicing the default option for thousands of businesses.
On 1st July, the Danish Business Authority (Erhvervsstyrelsen) launched a public consultation on draft amendments to the Executive Order governing digital standard bookkeeping systems. The proposal would require providers of compliant bookkeeping software to register business customers to receive e-invoices via NemHandel, Denmark's Peppol-based infrastructure, unless they actively choose to opt out. It would also require e-invoicing to be presented as the default option when issuing invoices, instead of PDF or paper alternatives.
Denmark has a long history of digital invoicing and public procurement:
- Mandatory B2G e-invoicing was introduced in 2005
- NemHandel was launched in 2007
- NemHandel connected to the international Peppol network in 2017
- More than 31.8 million electronic business documents are exchanged annually through NemHandel
- Over 67,000 organisations are registered on the network
- Around 99% of invoices sent to the Danish public sector are already electronic
Unlike many recent B2B mandates, which focus on requiring businesses to exchange structured invoices using a four-corner interoperability model, Denmark's proposal targets the software itself.
By making Peppol the default option within digital bookkeeping systems, the government is seeking to encourage adoption through everyday user behaviour rather than through a direct legal obligation to use a particular exchange method.
The consultation remains open until 17th August 2026. If adopted, the amended Executive Order is expected to enter into force on 1st January 2027.
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