Achieving Compliance in Denmark: An Overview with mySupply
In Denmark, the infrastructure NemHandel and the document standard OIOUBL are managed by the Danish Business Authority (Erhvervsstyrelsen).
In the autumn of 2023, the NemHandel infrastructure will transition to e-Delivery. During the same period, new document formats will be introduced in OIOUBL 3.0, including invoices, credit notes, application responses (technical), and invoice responses. Additionally, a product master data document will be introduced in early 2024.
Denmark also utilizes the Peppol network to implement the European Standard on eInvoicing (EN 16931), primarily intended for cross-border trade.
The Danish legislation regarding e-invoicing is based on the Act on Public Payments, etc. and the Executive Order on Information in and Transport of OIOUBL Electronic Invoices for Electronic Settlement with Public Authorities.
In Denmark, there is mandatory B2G (Business-to-Government) legislation, meaning that Danish companies acting as suppliers to the public sector are required to send electronic invoices and credit notes. PDF invoices are not accepted within the Danish public sector.
Currently, there is no specific legislation regarding e-invoicing in the B2B (Business-to-Business) sector in Denmark. Instead, a new accounting law will be introduced, imposing requirements on Danish accounting systems.
The New Danish Accounting Law (2024-2026)
The Accounting Law mandates that accounting in Denmark must be conducted digitally in the future. This means that Danish companies that do not already have a digital accounting system will be required to use one within a year.
There are specific relevant dates for the new accounting law:
- January 1, 2024: The Danish Business Authority will publish a list of approved and registered accounting systems.
- July 1, 2024: Companies obligated to submit annual reports under the Annual Financial Statements Act and using a digital standard accounting system must conduct digital accounting.
- January 1, 2025: Companies obligated to submit annual reports under the Annual Financial Statements Act and using a digitally customized accounting system must conduct digital accounting.
- 2026: Personally-owned companies with a business net turnover exceeding DKK 300,000 in each of the two preceding income years (2024 and 2025) must conduct digital accounting.
From an e-invoicing perspective, it is particularly interesting that standard accounting systems are required to have built-in functionality for handling electronic business documents in various document exchange networks. Specifically, this means that standard accounting systems must be able to:
- Send electronic invoices, credit notes, and Application Response (Technical Acknowledgment) in OIOUBL and Peppol formats via eDelivery, NemHandel, and the Peppol network.
- Receive electronic invoices, credit notes, and Application Response (Technical Acknowledgment) in OIOUBL and Peppol formats via eDelivery, NemHandel, and the Peppol network.
- The requirement for e-invoicing in Danish accounting systems will increase the adoption of e-invoicing in Denmark, as it will become a standard method of invoicing for Danish companies. The intriguing question is whether and when mandatory e-invoicing legislation for transactions between Danish companies can be expected.
What Can Be Exchanged?
Electronic invoices and credit notes: For cross-border transactions (from Denmark to foreign countries), Peppol BIS Billing 3.0 is used, which is Peppol’s standard format for invoices and credit notes. Domestic Danish transactions are exchanged via Dansk NemHandel, where the OIOUBL standard predominates. However, the Peppol network can also be used for this purpose.
Other electronic business documents in Dansk NemHandel: OIOUBL Reminders, OIOUBL Utility Specification (handling utility sector documents), OIOUBL Orders, OIOUBL Order Responses (Simple and Advanced), OIOUBL Catalogs.
How Are Electronic Business Documents Exchanged?
In Denmark, electronic business documents are currently exchanged via the NemHandel network. Danish operators (Service Providers) exchange approved electronic business documents using the technical exchange protocol called RASP. The NemHandel network is currently being upgraded to an eDelivery network and will resemble the exchange model used in the Peppol network, which is built on the AS4 protocol, SMP, and SML.
In parallel with the NemHandel network, Denmark also supports the Peppol network. All Danish public organizations are registered to receive e-invoices and credit notes via the Peppol network.
Tax Reporting / Tax Clearance
There is a requirement for reporting using the SAF-T format, which contains data about a company’s accounting and is often generated directly from the financial system.
A CTC (Continuous Transaction Controls) clearance model has not yet been determined in Denmark to meet the requirements of the ViDA directive, which mandates mandatory real-time reporting of VAT to the Danish tax authorities. In Denmark, various models for VAT clearance are being explored and incorporated into the overall e-invoicing architecture, which is based on Peppol and NemHandel.
There is a 5-year electronic archiving requirement for electronic invoices and credit notes in Denmark.