Page History

Legislation

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.

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 e-invoicing (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. 

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.

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), and, therefore, have an eInvoice recipient number (GLN/EAN number). All public entities have at least one eInvoice recipient number that is publicly available on the organisation’s website. In NHR AS4 and AS2 is also possible. 

Economic operators can submit eInvoices

using three main tools:

• Fully fully integrated eInvoice-enabled Enterprise Resource Planning (ERP) solutions (software or web-based);
• ERP solutions in combination with an open-source software provided by the Danish Business Authority, the the NemHandel message  message handler client;
• Manually manually created in the web-based invoicing portals (webform),.

Public entities can either establish their own access point and eInvoicing solution connecting to common public service-oriented infrastructure (OIORASP) or have an agreement with a Value Added Network Services (VANS) network provider. VANS are communication networks for exchanging electronic documents such as eInvoices. A VANS network must have an agreement on the exchange of data based on eInvoice recipient number with other network providers.

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 10 years [1].

eInvoicing implementation in sub-central level contracting authorities 

The eInvoicing model in place is based on Peppol, and OpenPeppol for receiving non-domestic suppliers suppliers’ eInvoices. The European standard is partially implemented and co-exist 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. They can do so 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.

Monitoring eInvoicing implementation 

There is no systemic monitoring system in place. The actual analytics are done using Peppol. 

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

More information on CIUS is available available here. 

Additional information

The Danish Business Authority

works on extending the implementation and support for Peppol in Denmark. The NemHandelRegistry (NHR)

was extended with Peppol eDelivery support (Service Metadata Service SMP) integrated with the European Service Metadata Locater (SML) register. This initiative

makes it easier for the growing number of Peppol enabled eInvoicing service providers and end-users to adopt Peppol services in Denmark. 

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. From 2024, businesses with annual Erhvervsstyrelsen (Danish tax authority) reporting obligations will be required to submit electronic invoices to the tax authority. It is also estimated that businesses with a turnover of more than DKK 300,000 will required to exchange and archive invoices electronically and submit electronic invoices to the tax authority as from January 2025[2].

Under the Accounting Law for digital accounting systems, the Danish tax administration is given the right to introduce the CTC/e-reporting requirement atop the mandatory eInvoicing schema. What is still to be defined is whether this obligation will require Denmark to apply for a derogation (from the VAT Directive)[3].

The new law requires to issue, exchange, receive, process and archive invoices electronically.  While the law does not introduce any mandatory eInvoicing obligations for businesses, it is foreseen that the digital bookkeeping systems will support automatic transmission and receipt of eInvoices among businesses[3].

[1] (Characteristics of the electronic invoice in Denmark, 2023), [2] (E-invoicing in Denmark, 2023), [3] (Compliance updates – Denmark, 2023)

Last updated: