While Denmark has been a pioneer in the implementation of B2G e-invoicing, leading the way since 2005, the introduction of B2B e-invoicing is going slower than expected.
Directive 2014/55/EU, fully transposed into Danish law, requires central, regional, and local authorities to receive and process electronic invoices. Economic operators and suppliers to public bodies are also required to submit electronic invoices.
The use of e-invoicing in Denmark
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Denmark
Author: Kristina Dosen
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Fiscal subject related
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Content accuracy validation date:
27.06.2024
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Denmark has implemented the European standard on e-invoicing (EN-16931) using the Universal Business Language (UBL) 2.1. The national standard, known as OIOUBL, is based on UBL 2.0. The country also utilizes the Peppol BIS Billing 3.0 format and the NemHandel platform for e-invoicing. This comprehensive system ensures seamless electronic transactions and adherence to European standards.
Furthermore, Denmark's e-invoicing system incorporates the OIO Reliable Asynchronous Secure Profile (OIORASP) for secure and reliable electronic communications between public entities and their suppliers. This infrastructure supports efficient and secure invoicing processes, promotes transparency, and reduces administrative burdens.
Currently, e-invoicing in Denmark is well-developed but not yet mandatory for B2B transactions. Businesses can issue invoices in several ways, including:
- Paper-based invoices
- PDF invoices with an e-signature or a complete audit trail
- Electronic Data Interchange (EDI)
However, this will change soon due to the adoption of the "Bookkeeping Act" in 2022, which mandates digital bookkeeping. Under this new law, accounting, including invoicing, must be conducted digitally using either:
- Digital bookkeeping software is certified by the Danish Business Authority (Erhvervsstyrelsen, or ERST).
- An individual digital bookkeeping solution was developed in compliance with the law.
This law covers all accounting processes, and as a result, B2B e-invoicing will become mandatory, similar to the existing requirements for B2G transactions. E-invoices will need to be transmitted through either the public NemHandel platform or the Peppol network, using formats such as Peppol BIS 3.0 (EN16931-compliant) or the local OIOUBL format, which will also be updated to be EN16931-compliant.
The implementation of the Bookkeeping Act will follow a staged roll-out based on company size and the type of digital bookkeeping solution adopted. The timeline for compliance is as follows:
- January 1, 2024: Publication of all certified digital bookkeeping systems.
- July 1, 2024: Medium and large companies using certified accounting software.
- January 1, 2025: Medium and large companies using custom software.
- January 1, 2026: Financial companies of any size and personally-owned companies with an annual turnover exceeding 300,000 DKK (~40,000 €) in 2024 and 2025.
"Medium and large companies" refer to those already required to submit an annual report under the Annual Accounts Act. Invoices must generally be archived for five years.
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