eInvoicing in Denmark

Legislation

Denmark is a pioneer in using eInvoicing. Since 2005, suppliers of services and goods are required to send electronic invoices (UBL) to public institutions and public authorities.

Since 18 April 2019, with the implementation of Directive 2014/55/EU, all public entities must be able to receive and process electronic invoices in accordance with the European Standard on einvoicing (EN-16931).

The Order on electronic settlement with public authorities, Order No. 206 of 11.03.2011 includes general provisions, such as information on invoices from public entities to natural or legal persons, invoices for public entities, and use of infrastructure. The legislation stipulated the mandatory standard for eInvoicing in public procurement in Denmark – OIOUBL. OIOUBL is provided and maintained by the Danish Business Authority.

The legislation also stipulated that public entities should use the OIO Reliable Asynchronous Secure Profile (OIORASP), which is a profile of web service standards. It makes it possible to exchange business documents (such as eInvoices) through the Internet with a high degree of security and reliability in the transactions. Later this year Nemhandel eDelivery will also be possible.

On 19 May 2022, the Danish Parliament has adopted the Bill on the Danish Bookkeeping Act, this law impose the usage of the Digital Bookkeeping System (DBS) for al businesses in Denmark. In addition to needing stronger IT security and support for bookkeeping features, these systems must be able to generate, receive, and store electronic invoices. They should also be connected to Peppol and Nemhandel, and be able to handle different types of application responses. 

The Consolidated Law on Public Payments states that all-natural and legal persons must provide a bank account ("Nemkonto") into which the public authorities can make the payment. No other way of payment is foreseen by the Act.

eInvoicing platform and eInvoicing management solutions

The Danish government mandates the use of the NemHandel platform for exchanging eInvoices in B2G public procurement. NemHandel is a publicly developed and operated national infrastructure that enables companies to submit electronic invoices securely over the Internet. eInvoices that adhere to the OIOUBL standard and use the web services as specified in OIORASP are transmitted through NemHandel.

However, this system will not remain the same, as of May 2023 the Danish Business Authority has set a specific timeline for a transition from OIORASP (considered outdated and not conformed with the European standard) to eDelivery. OIORASP will continue as a standalone protocol until 31 October 2023, after which it is required that the recipient is at least registered in the eDelivery network. However, OIORASP can still be used until November 2024.

Economic operators can use any solution connected to NemHandel to submit eInvoices.

There are more than 100 different solutions on the market targeting different user groups and company sizes, commonly used ones are Microsoft Dynamics, Fujitsu and SAP. Also, there are over 30 solution providers, both big and small. Among them are IBM, CSC, Tradeshift, Truelink, Visma and Pagero. 

Approach for receiving and processing eInvoices

Denmark mandates the use of the European standard on eInvoicing (UBL), the transmission of eInvoices through web services (compliant with OIORASP) and the use of the Danish national infrastructure (NemHandel). Only receivers of eInvoices should be registered in the NemHandelRegistry (NHR), in order to register in the registry, enterprise shall insert the correct CVR (Central Business Register) number and GLN (Global Location Number) number if relevant.

Moreover, in accordance with the new bookkeeping system, business enterprises must ensure that all providers can send eInvoices to all types of recipient addresses. This means in CVR number, P number, SE number, and GLN/EAN number. [1] All public entities have at least one eInvoice recipient number that is publicly available on the organisation’s website. In NHR AS4 is also possible. 

Economic operators can submit eInvoices using three main tools:

• fully integrated eInvoice-enabled Enterprise Resource Planning (ERP) solutions (software or web-based);
• ERP solutions in combination with an open-source eDelivery;
• manually created in the web-based invoicing portals (webform).

Overall, the Danish system is similar to Peppol. It is based on the same architectural principles, with a four-corner model, technical infrastructure agreements for the solution providers to sign and almost identical open standards for payload. Danish economic operators using the NemHandel network can reach users on the Peppol network.

In addition, the Danish Business Authority supplies IT vendors with guidelines, validation tools, presentation style sheets and open-source components to ease the implementation of eInvoicing. It is the implementers' (IT vendors’) responsibility to adhere to the standards and develop software solutions for the different users' needs in the market.

No electronic signature is required for eInvoices and the archiving period amounts to 5 years for movable properties and 10 years for immovable properties [2].

eInvoicing implementation in sub-central level contracting authorities 

It is mandatory for public authorities to be registered in the NHR with one or more GLN / EAN numbers (state, regions, and municipalities).

The eInvoicing model in place is based on Peppol and works in the same way for regional and central authorities. OpenPeppol is used also for receiving non-domestic suppliers’ eInvoices. The European standard is partially implemented and co-exists with OIOUBL. 

Denmark uses a CIUS (same as the one used at the national level) communicated via Peppol.

Status on the implementation of the European Standard on eInvoicing (EN)

The Danish Business Authority is in dialogue with the economic operators and eInvoicing solutions providers to make sure that they adhere to the European norms, once they are ready. With the upcoming implementation of the Bookkeeping Act,the European Standard will be adopted by 2026 by all the economic operators and public institutions in the country.  This will be done either by conversion services or by adapting to the European standard on eInvoicing.

Implementation of the Directive 2014/55/EU as well as the implementation of the European standard on eInvoicing, for which a bill was presented in the Danish parliament on October 2018. This plan includes, among other actions, documentation for the Danish Core Invoice Usage Specification (CIUS), syntax mapping and the development of the Danish SMP (Regulation of competition in the telecommunications market). Denmark has also implemented eInvoicing at the level of sub-central entities.

Use of Core Invoicing Usage Specifications (CIUS) at national level

More information on CIUS is available here. 

Digital reporting requirements

On 19 May 2022, the Danish Parliament passed the Accounting Law for digital accounting systems, which will enter into force gradually over the next few years. On 1 February 2023, the requirements for standard digital accounting came into force.

The new legislation has set a timeline for the implementation of the norms, which will depend on the company’s turnover:

• January 2024: All companies obliged to submit annual reports to ERST (class B, C, D) must be compliant with einvoicingeI-invoicing by 1 January 2024. Those using in-house developed bookkeeping software have until 1 July 2024.
• January 2026: Companies not obliged to submit annual reports to the Danish Business Authority but have a turnover of over DKK 300,000 in two consecutive years (class A) must be compliant with einvoicingeI-invoicing by 1 January 2026. However, those using in-house developed bookkeeping software have until 1 July 2026.

[1](Guide on bookkeeping and digital bookkeeping systems, 2023), [2] (Bill on the Danish Bookkeeping Act, 2022)

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Last updated:  Jun 28, 2024 18:10