Managing Electronic Documents in Denmark
As a customer in Denmark, you can send electronic documents either by email (as attached files) or through the PEPPOL eDelivery Network, or the NemHandel Network for organizations based in Denmark.
Denmark has been using e-invoicing since 2005, especially in the public sector, where it is mandatory for public administrations and their suppliers. Although electronic invoicing for business-to-business (B2B) transactions is not currently mandated by legislation, all bookkeeping systems will soon be required to handle both sending and receiving electronic documents.
In May 2022, the Danish parliament passed a set of reforms regarding the Danish Accounting Act (DBA), which requires companies to keep and archive their accounts in digital format. The implementation of this new rule will be gradual. The implementation timeline of the new Bookkeeping law depends on company turnover (and reporting obligation.)
Important
As per the Danish Bookkeeping Act (DBA) (Act No.700 of 24 May 2022), all Danish organizations are required to register with NemHandel. They should be capable of sending and receiving electronic documents through Nemhandel by January 1, 2025. Additionally, electronic invoices and credit memos must be sent and received in either OIOUBL or Peppol BIS 3.0 formats.
Continia is closely monitoring the progress of the NemHandel network, which is being restructured to resemble the exchange model used in the Peppol network.
The table below outlines the current regulatory states and future outlooks for B2G, B2B, and B2C (business-to-consumer) sectors.
| Transaction Type | Current Regulatory State | Regulatory Outlook |
|---|---|---|
| B2G | It’s mandatory to use the Danish NemHandel or the Peppol network.  Supported by Document Capture. Supported by Document Output. | No changes are expected. |
| B2B | Using the Danish NemHandel or the Peppol network with the OIOUBL/Peppol BIS 3.0 format is optional. Supported by Document Capture. Supported by Document Output. | The OIOUBL 3.0 format is expected to become mandatory for NemHandel by May 2025, with older editions being phased out by November 2025. For registered digital bookkeeping systems: Starting from the first fiscal year beginning after July 1, 2024, the registered digital standard bookkeeping system is required to have the capability to both send and receive electronic documents. For unregistered digital bookkeeping systems: Starting from the first fiscal year beginning after January 1, 2025, the bookkeeping system must be able to send and receive electronic documents. Supported by Document Capture. |
| B2C | No legislation is in place. | No changes are expected. |
Update on NemHandel
The transition from the old NemHandel to the future eDelivery Nemhandel architecture has moved into a new phase. On May 28, 2024, the OSIRASP transaction protocol was deactivated, meaning that the old free-of-charge component NemHandel Referenceklient is no longer available for use. This component could be used for sending documents through NemHandel without a registration. This will not affect anyone using Continia's solutions, as these are integrated directly into NemHandel.
The current status of the transition is that the old platform has officially been shut down, and all transmissions are now going through the new platform.
In the next phase, the new OIOUBL3.0 format will be implemented. The specifications are expected to be finalized in November 2024 with the last adjustments completed in May 2025. From May 2025 use of the new OIOUBL3.0 format will be on a voluntary basis until November 2025, where use of the new format will become mandatory. Along with the new formats, there will be new registration profiles on the NemHandel network, but it still remains unclear if this can be handled without user involvement.
The expectation is that OIOUBL 2.1 will be phased out in mid May 2026 after which any files generated by solutions that don't support the new OIOUBL3.0 format will be rejected by the network.
Danish Bookkeeping Act
As per the Danish Bookkeeping Act (DBA) (Act No.700 of 24 May 2022), all Danish organizations are required to register with NemHandel. Furthermore, electronic invoices and credit memos must be sent and received in either OIOUBL or Peppol BIS 3.0 formats:
- OIOUBL - the primary format specified by the Danish authorities, transmitted through a domestic network known as NemHandel. Only Danish companies registered with the Danish Business Authority (Erhvervsstyrelsen) and possessing a CVR identifier can be registered in NemHandel.
- Peppol BIS 3.0 - this format is utilized through the international Peppol eDelivery Network.
The implementation of the DBA will take place in stages between 2024 and 2026. The first phase will focus on privately owned companies with an annual turnover exceeding DKK 300,000. These companies will be obligated to use a registered digital bookkeeping system. Entities with a turnover below this threshold are exempt from this obligation. However, they still need to comply with all other legal requirements.
For more information, refer to the How to Comply to the Danish Bookkeeping Act article.