The law's purpose is to reduce tax fraud and modernize accounting practices. Requirements already apply to all medium and large companies following the deadlines in 2024 and early 2025. Smaller businesses with an annual turnover exceeding DKK 300,000 must comply by July 1, 2026.

‍

The businesses must ensure their systems can:

‍

• Securely maintain and store bookkeeping records for five years
• Send/receive e-invoices (OIOUBL and Peppol BIS)
• Generate SAF-T files on demand

‍

‍

‍

Who must comply and when?

‍

The Act introduces phased implementation dates between 2024 and 2026, based on company type and system usage. Companies submitting an annual report to the Danish Business Authority must comply by July 1, 2024 or January 1, 2025, depending on their system:

‍

• July 1, 2024: Medium and large companies using registered solutions were required to be compliant.
• January 1, 2025: Same applies to those using custom, non-registered systems or with no certified system.
• January 1, 2026: The requirements will extend to most smaller businesses and foreign entities once their turnover from Danish activities exceeds DKK 300,000 (approx. €40,000) for two consecutive years.
• July 1, 2026: Deadline for small companies using custom or in-house systems.

‍

There is a key distinction between 'registered' and 'non-registered' bookkeeping systems. For registered systems, the provider is primarily responsible for ensuring the system meets the Act's technical requirements. For non-registered systems, the user company bears full responsibility for compliance and must be able to document this.

‍

A complete list of registered bookkeeping systems can be found here (Danish only).

‍

The requirements

‍

‍

Businesses must comply in three different areas:

‍

‍

Storage

First, the Act mandates that all business transactions be recorded in a compliant Digital Bookkeeping System (DBS), effectively ending the legal use of spreadsheets or manual ledgers for official accounting.

‍

Second, it introduces the principle of immutability: once a transaction is posted, the system must make it impossible to edit or delete. Any corrections must be made through new, reversing entries, ensuring a transparent and unalterable audit trail.

‍

Furthermore, companies are now required to digitally store all records and their associated vouchers—such as invoices and receipts—for five years. This includes an automated, weekly backup to a secure server with an independent third party located within the EU/EEA.

‍

Finally, businesses must create and maintain a formal, written description of their bookkeeping procedures, making internal controls and responsibilities explicit and auditable.

‍

‍

Electronic invoicing

The system must be able to send and receive structured electronic invoices in both the national OIOUBL format and the pan-European Peppol BIS 3.0 format. While universal B2B e-invoicing is not yet mandatory, the required system capability is a clear signal of the government's direction.

‍

‍

SAF-T(Standard Audit File for Tax)

The system must be able to generate a standardized SAF-T file of all accounting data upon request from the Danish tax authorities (Skattestyrelsen). This SAF-T file must support the international standard, facilitating a safe and smooth exchange of bookkeeping data, both with the authorities and other bookkeeping systems.

‍

‍

Consequences of non-compliance

‍

The Danish Business Authority is overseeing the Act's implementation, providing guidance, managing the register of approved digital bookkeeping systems and conducting risk-based controls to ensure compliance.

‍

Non-compliance carries significant risks:

‍

• Being de-selected by suppliers or customers for non-alignment
• Fines for non-compliance are substantial, scaled according to company revenue, and can reach up to DKK 1.5 million.
• Auditors who find a company non-compliant can issue a qualified opinion on the annual report.
• Compulsory dissolution of the enterprise, in severe cases.

‍

‍

What are my next steps?

‍

If your company is - or will be - impacted by these changes, you should:

‍

• Ensure your storage of bookkeeping data complies with the requirements.'
• Send and recieve test invoices, using both the OIOUBL format and Peppol BIS 3.0 format.
• Produce a SAF-T file and verify compliance with the international standards.

‍

‍

‍

Contact Logiq if you need help staying compliant.

‍