Denmark’s digital bookkeeping requirements

Denmark has continued the phased implementation of its digital bookkeeping requirements, with further businesses coming within scope from 2026.

The requirements are particularly relevant for international groups operating in Denmark, including businesses using global ERP or accounting systems that are not registered with the Danish Business Authority.

Businesses should therefore consider whether they are now within scope and ensure that their bookkeeping systems and processes meet the applicable Danish requirements.

Who is required to use digital bookkeeping?

Denmark’s digital bookkeeping requirements have been introduced in phases.

The requirements have already been implemented for businesses subject to annual reporting requirements under the Danish Financial Statements Act. For businesses subject to annual reporting that use a non-registered digital bookkeeping system, the requirements apply to accounting periods beginning on or after 1 January 2025.

From 1 January 2026, the requirements have been extended to businesses that are not required to prepare an annual report under the Danish Financial Statements Act, such as certain sole traders, where their net turnover exceeds DKK 300,000 in each of two consecutive income years.

Businesses that previously concluded that they were outside the digital bookkeeping requirements should therefore reassess their position.

What does digital bookkeeping mean for businesses?

Businesses within scope need to use a digital bookkeeping system that meets the applicable requirements of the Danish Bookkeeping Act.

The Danish framework distinguishes between registered digital bookkeeping systems and non-registered digital bookkeeping systems.

Registered digital bookkeeping systems

Digital standard bookkeeping systems are registered with the Danish Business Authority. Systems included on the Authority’s register have been checked against the statutory requirements for digital bookkeeping systems.

Businesses using a registered system can therefore rely on the system meeting the applicable system requirements under the Danish Bookkeeping Act.

As the register can change, businesses should check the Danish Business Authority’s current register of registered bookkeeping systems rather than relying on the status of a particular accounting system at an earlier point in time.

Non-registered digital bookkeeping systems

A business is not necessarily prevented from using a bookkeeping system simply because it does not appear on the Danish Business Authority register.

However, there is an important difference in responsibility. For a registered system, responsibility for ensuring that the system complies with the applicable system requirements rests with the provider. Where a non-registered system is used, responsibility rests with the business itself.

The requirements for non-registered systems address areas including the recording and amendment of transactions, IT security and backup, automation, electronic invoicing, bank reconciliation and the sharing of bookkeeping data.

This is particularly relevant for multinational groups using a global ERP or accounting platform.

Rather than assuming that a group-wide accounting system satisfies Danish requirements, businesses should consider whether the system and associated processes meet the relevant local requirements and maintain appropriate documentation supporting their assessment.

Consider your bookkeeping procedures

Compliance is not solely about the accounting system being used.

Businesses should also consider their wider bookkeeping arrangements and ensure their procedures reflect how transactions are recorded, accounting material is retained and responsibilities are managed across the organisation.

This can be particularly important for international groups where bookkeeping is undertaken centrally outside Denmark or responsibilities are divided between a Danish operation, an overseas finance function and third-party service providers.

Electronic invoicing and NemHandel

Electronic invoicing is becoming an increasingly important part of Denmark’s wider digitalisation programme.

NemHandel is Denmark’s common digital infrastructure for exchanging business documents between businesses and public authorities. It supports common document standards, a recipient register and electronic transmission infrastructure. Use of NemHandel for exchanging electronic invoices with Danish public authorities has been mandatory since 2005.

Further changes are now being introduced for registered digital bookkeeping systems as part of a wider programme to increase the use of electronic invoicing.

In September 2026, the Danish Business Authority published new requirements for registered bookkeeping systems aimed at making the use of electronic invoices more efficient and secure. These measures form part of a series of initiatives being implemented during 2026 and 2027 to expand the voluntary use of electronic invoicing.

The Authority’s current guidance states that providers of registered bookkeeping systems will be required to automatically register their customers for electronic invoicing unless the customer actively opts out. Businesses using registered systems are expected to have the opportunity to send and receive electronic invoices from spring 2027 without having to register themselves.

Businesses should therefore consider electronic invoicing alongside their wider assessment of Danish bookkeeping compliance and continue to monitor developments in this area.

What should businesses do now?

How Crowe UK can help

For multinational organisations, complying with Denmark’s digital bookkeeping requirements can involve more than simply confirming which accounting software is being used.

Where bookkeeping is maintained through a global ERP platform or by a finance function outside Denmark, businesses may need to assess how their existing systems, processes and record-keeping arrangements align with local Danish requirements.

Crowe can support businesses in reviewing their existing bookkeeping arrangements, understanding how the Danish requirements apply to their operations and identifying potential compliance gaps.

Our international network can also support businesses looking to align Danish bookkeeping requirements with their wider accounting and compliance processes.

If you would like to discuss how Denmark’s digital bookkeeping requirements may affect your organisation, please contact our Global Business Solutions team.