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Denmark delays digital certified invoicing and bookkeeping

Government change delays implementation of digital invoice and record keeping phased launch

The implementation of the Danish Bookkeeping Act has been delayed at the start of December. This was due to the delay in formation of a new government – subsequently completed last week.

Accounting and similar systems to support the digital requirements must register with the Danish Business Authority by 31 October 2023 – based on requirements to be issued in February 2023. Following a verification process, eligible systems will be certified for 1 January 2024.

Denmark was to require digital record keeping for businesses from 1 January 2024. This includes using only certified accounting software and ERS. This is similar to the UK Making Tax Digital plan, seeking to ensure the entire order to reporting path is digitised and manual processes are expunged.

There will be a threshold for the new obligations of turnover above DKK 300,000, approximately €40,300, in the last two calendar years. But all companies will be required to submit the annual the Erhvervsstyrelsen (Danish Business Authority).  The Authority will be providing further technical requirements and a new implementation date in 2023.  Any publisher of accounting, invoicing and similar systems will be expected to register with the Authority in 2023.

Phased implementation 2024 to 2026

There will be a phased implementation of the new reporting requirements. The old schedule was:

  • Jan 2024: taxpayers already with annual Erhvervsstyrelsen reporting obligations
  • Jan 2026: any other businesses with a turnover of more than DKK 300,000; July for in-house developed accounting systems

Denmark imposed e-invoicing on B2G transactions in 2005 using the PEPPOL BIS 3.0  and OIOUBL format via the NemHande portal.

Read our Danish VAT guide here.

EU review of Digital Reporting Requirements

The EU is also reviewing EU e-invoicing options as part of its VAT in the Digital Age reforms, published in December 2022.

Europe e-invoicing and live reporting

Country Date Comments (click for details)
EU e-invoice proposals 2028 Digital reporting and e-invoicing harmonisation
Albania Jan 2021 Authorised e-invoice software and pre-clearance
Belgium Jul 2024 Phased introduction of B2B e-invoices
Bulgaria 2023 Public consultation on pre-clearance model e-invoice
Croatia 2025 B2B mandatory e-invoicing
Denmark 2024 Digital record keeping obligations
Finland Apr 2020 Customer option to require B2B e-invoices
France Jul 2024 E-invoicing and e-reporting for B2B and B2C
Germany Jan 2025 B2B mandatory e-invoicing proposals
Greece Oct 2021 myData summary invoice and ledger reporting
Hungary Jul 2018 RTIR live invoice reporting. No govt pre-clearance required
Italy Jan 2019 Pre-clearance SdI e-invoicing
Ireland TBC Public consultation underway
Latvia Jan 2025 B2B e-invoices based on PEPPOL
Lithuania ? E-invoicing platform being scoped
Netherlands - Unlikely to adopt domestic reforms
Poland Jul 2024 B2B mandated e-invoicing
Portugal Jan 2024 Certified invoicing software for non-residents
Jan 2024 ATCUD digital invoice signature for non-residents
Romania Jul 2022 RO e-invoicing implementation
Russia TBC Extension of Traceability Model to B2B on hold
Serbia Jan 2023 B2B e-invoicing
Slovakia 2025 B2B and B2C e-invoice rollout
Slovenia 2023 ? e-SLOG B2B proposal stalled
Spain 1 Jul 2017 SII live invoice and book reporting
Spain 2 2024 Pre-clearance B2B e-invoices; supplement to SII
Sweden TBC PEPPOL based mandatory e-invoicing
Turkey Jan 2014 e-invoice e-Fatura and e-Arşiv
UK Apr 2022 MTD for VAT extended to 1.1million taxpayers


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