NemHandel 1 March 2027: Denmark finalises the requirements for bookkeeping software, SAF-T 2.1 stays on 1 January 2027

Copenhagen, 12 October 2026. For providers of bookkeeping, ERP or invoicing software with Danish users, the date is now fixed: NemHandel 1 March 2027. With BEK no. 811 of 22 September 2026 and guidance of 5 October 2026, the Danish Business Authority (Erhvervsstyrelsen) finalises the new requirements for registered digital bookkeeping systems, two months later than the 1 January 2027 in the July 2026 draft. The SAF-T 2.1 requirement does not move and applies from 1 January 2027.

NemHandel 1 March 2027: what the final rules require

The draft that the Danish Business Authority put out for consultation in July 2026 named 1 January 2027 as the start date (see our report of 20 August 2026). The final amendment to the requirements order, BEK no. 811 of 22 September 2026, and the guidance the authority published on 5 October 2026 set the e-invoicing requirements at 1 March 2027. From that date, registered bookkeeping systems must, among other things:

• have customers confirm their CVR number with MitID; the CVR number, name, address and any P-numbers are locked and updated automatically from the CVR register;
• inform all new and existing customers who are not yet in the NemHandel register that they will be registered automatically unless they opt out within four weeks;
• register, within four weeks after that period ends, all customers who did not opt out; a customer can still deregister at any later time;
• clearly show, when an invoice is created manually, that the recipient is registered in NemHandel, so that e-invoicing becomes an easy choice. Automated batch or API invoicing is exempt;
• check key company details on outgoing e-documents against the CVR register.

Sending e-invoices remains voluntary. Denmark is not introducing a general B2B mandate; only the default setting changes. A second step follows on 1 January 2028: every change to supplementary master data, such as payment details, SE numbers and GLN numbers, must be validated with MitID. Note: the separate guidance on the e-invoicing requirements of 25 September 2026 names 1 January 2028 for part of the requirements. Check the date for each requirement in BEK no. 811.

SAF-T 2.1 stays on 1 January 2027

The deferral does not apply to SAF-T. According to the guidance of 5 October 2026, registered systems must support SAF-T version 2.1 from 1 January 2027. The file is extended with transaction-level data, more detailed master data on debtors and creditors, and VAT information per transaction.

Background: the move from OIOUBL to Nemhandel BIS 4

The format direction is not new: it has been set since the document strategy of 9 March 2026, and we reported on it on 30 June 2026 (Nemhandel BIS 4 and the phase-out of OIOUBL). Registered systems currently have to process e-invoices automatically in both OIOUBL and Peppol BIS. The Danish Business Authority phases out OIOUBL in favour of Nemhandel BIS 4: Peppol BIS 4 with mandatory Danish extensions. Peppol BIS 3 is skipped, as it lacks data needed for payment automation, among other things. The strategy covers invoice, credit note and invoice response.

The expected timeline: Peppol BIS 4 targeted for end-2026, Nemhandel BIS 4 in 2027, a release candidate comment period from November 2027 to May 2028, phase-in from May to November 2028 and phase-out from November 2028 to May 2029. After mid-2029, bookkeeping legislation will only require support for the Nemhandel BIS format. That is more than a year before ViDA requires EN 16931 e-invoices for cross-border B2B transactions from 1 July 2030.

Context

NemHandel has been mandatory for e-invoices to Danish public authorities since 2005. On 12 October 2026 the NemHandel register listed 67,633 recipients, while according to NemHandel around 350,000 companies use a registered bookkeeping system. Automatic registration makes a large share of them reachable as e-invoice recipients. For how e-invoicing and reporting come together in one integration, see our analysis of Peppol and e-reporting.

What it means and what to do now

For software vendors with Danish users, the work runs on two tracks: the NemHandel requirements first, the format migration after that. This is what you need in place by each date:

1. 1 January 2027: SAF-T 2.1 export with transaction data, extended debtor and creditor master data and VAT per transaction.
2. 1 March 2027: MitID validation, locked CVR master data, the registration notice with a four-week opt-out, registration within four weeks after that, and a recipient check in manual invoicing.
3. 1 January 2028: MitID validation for every change to payment details, SE numbers and GLN numbers.
4. Mid-2028: generate and process Nemhandel BIS 4; the phase-in runs from May to November 2028. Use the release candidate comment period (November 2027 to May 2028) to test your mapping.
5. Mid-2029: OIOUBL is phased out (May 2029); only the Nemhandel BIS format still needs to be supported.
6. 1 July 2030: ViDA requirements for cross-border B2B e-invoicing under EN 16931.

What this means for your integration. Build registration logic and the recipient check as configurable components you can switch on per requirement. Keep your invoice model format-independent, so OIOUBL and Peppol BIS work side by side during the transition and Nemhandel BIS 4 can be added as an extra output. Subscribe to the guidance’s change notifications and plan releases around NemHandel’s deployment windows (15 May and 15 November).

For businesses

A Dutch, Belgian, Luxembourg, German or French supplier with Danish customers will see more Danish companies registered as e-invoice recipients from 1 March 2027. Check whether your invoicing software or Peppol Service Provider reaches Danish recipients. For your Danish customers, e-invoicing remains voluntary; from 1 July 2030 the ViDA requirements apply to cross-border B2B trade.

For Peppol Service Providers

The transition requires support for Peppol BIS 4 with Danish extensions, and a period from May 2028 to May 2029 in which OIOUBL and Nemhandel BIS 4 run side by side. Add the comment period starting in November 2027 to your roadmap.

Sources

1. Retsinformation: BEK no. 811 of 22/09/2026, executive order amending the order on requirements for digital standard bookkeeping systems
2. Danish Business Authority: guidance for providers of digital standard bookkeeping systems (5 October 2026, in Danish)
3. Danish Business Authority: guidance on new requirements for registered bookkeeping systems, effective and secure e-invoicing (25 September 2026, in Danish)
4. Danish Business Authority: E-fakturering (in Danish)
5. Danish Business Authority: strategy for the document standard for e-invoices in Denmark, version 1.0 (9 March 2026, in Danish)
6. NemHandel: e-invoicing becomes the new common way to invoice (28 September 2026, in Danish)
7. NemHandel: new combined guidance for providers of digital standard bookkeeping systems (8 October 2026, in Danish)
8. Danish Business Authority: Nemhandel, shared digital infrastructure (in Danish)
9. NemHandel: number of registered recipients (accessed 12 October 2026)
10. KPMG TaxNewsFlash: Denmark deferred launch of voluntary e-invoicing to March 1, 2027 (secondary source)

Preparing your software for NemHandel 1 March 2027 and the later move from OIOUBL to Peppol, and looking for a Peppol Service Provider or integration partner with experience in Denmark? In the Peppol.now comparison tool you can filter providers by region, features and network.