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Non-compliance with these digital bookkeeping requirements can result in fines and a qualified opinion in the annual report.

If your company is obligated to submit an annual report to the Danish Business Authority, your company must comply with the rules relating to digital bookkeeping. These companies must comply with the rules once they start a new financial year after 1 January 2025.

Further, companies exempt from filing annual reports in Denmark, for example, companies holding solely a Danish VAT registration that generate an annual net turnover of more than DKK 300,000  for two consecutive years, are also required to comply with the regulations relating to digital bookkeeping. These companies must comply with the rules from 1 January 2026.

Transactions should be recorded accurately and as soon as possible in a digital bookkeeping system. It is also mandatory that the bookkeeping system can receive, store and issue electronic invoices (e-invoices). If you use a standard digital bookkeeping system approved by the Danish Business Authority, the provider of the digital bookkeeping system is responsible for ensuring that the system meets the requirements of the Bookkeeping Act.

If your digital bookkeeping system is a so-called customised system and therefore not on the list below (such as SAP), your company is responsible for ensuring that the system meets the requirements of the Bookkeeping Act.

The Danish Business Authority has published the list of approved standard digital bookkeeping systems here: Registered bookkeeping systems

Even when using an approved standardised digital bookkeeping system, you must ensure that, in addition to transactions, various documents are stored in the system. Your company, as the system user, must be able to utilise the functions offered by the standardised digital bookkeeping system.

One of the requirements of the new Bookkeeping Act is that the bookkeeping system must support the international standard file format SAF-T. This aims to facilitate safer and easier exchange of bookkeeping data (e.g., with the Danish Tax Agency) and transition between bookkeeping systems. Although there is currently no requirement for regular submission of SAF-T files to authorities, the bookkeeping system must be able to generate, import, and export a SAF-T file including header information.

Besides generating SAF-T files, companies are required to be able to issue and receive electronic invoices, which must also be stored and archived. While it is not yet mandatory for your company to actively use electronic invoicing, your digital bookkeeping system must be capable of handling such invoices.

The Danish Business Authority has announced its intention to monitor compliance with digital bookkeeping requirements. The Danish Bookkeeping Act includes provisions for penalties, with fines up to DKK 1.5 million for violations of digital bookkeeping requirements. Auditors are also vigilant about compliance and may issue a qualified opinion in the annual report if your bookkeeping system does not meet the requirements.

At ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Acor Tax, we recommend testing whether your bookkeeping system, regardless of its presence on the Danish Business Authority's list of approved systems, can generate electronic invoices (in the format of Danish standard OIOUBL and the EU standard Peppol BIS) and whether it can correctly receive and store such invoices. Additionally, we strongly recommend testing your system's ability to generate SAF-T files. We suggest creating a test file to examine the information it contains, ensuring that the SAF-T file includes the correct and necessary information.

f you need advice and guidance on creating SAF-T files or preparing for e-invoicing, feel free to reach out to us.

We are happy to arrange a meeting.