E-invoicing Denmark: NemHandel enrolment becomes the default from 2027

Copenhagen, 20 August 2026 – The Danish Business Authority (Erhvervsstyrelsen) closed its public consultation on Monday 17 August 2026 on a rule change that moves e-invoicing Denmark from a voluntary option to a default setting. The proposal does not target businesses directly. It targets the providers of registered digital standard bookkeeping systems, who would be required to enrol their business users in the NemHandel register automatically unless a company actively opts out. The intended date of entry into force is 1 January 2027.

What the draft actually proposes

Erhvervsstyrelsen published the draft on 1 July 2026 on the Danish consultation portal Høringsportalen under case number 2025-11688. Formally it amends the bekendtgørelse om krav til digitale standard bogføringssystemer, known in Denmark as the kravbekendtgørelse. That is an executive order under the Bogføringsloven, the Danish Bookkeeping Act of 2022, not an amendment to the act itself. The distinction matters: Denmark is changing the rules for software vendors, not the scope of the bookkeeping obligation on companies.

The draft contains three main elements:

• Reversed enrolment procedure. Providers of digital standard bookkeeping systems would be required to register their business customers in the NemHandel register for the receipt of e-invoices. Companies can actively decline, and those already enrolled can still deregister later.
• E-invoice shown first. When an invoice is created, the system must automatically check whether the recipient is listed in the NemHandel register. If so, the e-invoice must be presented to the user as the first sending option.
• Additional security requirements. These include identity verification, mandatory master data on electronic business documents sent from the system, and restrictions on changing company information held in the bookkeeping system.

Erhvervsstyrelsen positions the package explicitly within the Danish government programme Automatisk Erhvervsrapportering (AER), aimed at automated business reporting.

No B2B mandate, but a different default

One nuance is essential. Denmark is not introducing a general B2B mandate of the kind Belgium and France adopted. There is no statutory obligation to send business invoices electronically. What changes is the default: where a Danish company previously had to register itself to receive e-invoices, enrolment becomes the starting point and opting out the exception.

Trade media that reviewed the consultation file put the figure at roughly 125,000 additional businesses becoming reachable for e-invoicing. Peppol.now was unable to trace that number in the official Danish consultation documents. Treat it as an indication rather than an established fact.

The foundation: Bogføringsloven and NemHandel

Denmark is building on infrastructure that has been in place for two decades. NemHandel has been legally required for exchanging e-invoices with Danish public authorities since 2005. According to Erhvervsstyrelsen it consists of three layers: common document standards for financial data (OIOUBL and Peppol BIS), a common recipient register (the NemHandel register) and a transport layer based on the European eDelivery AS4 standard.

The Bogføringsloven of 2022 added a digital bookkeeping obligation on top of that, phased in over several years. As of 1 January 2026 it is fully phased in and also covers personally owned businesses and associations with commercial activities whose net turnover exceeds DKK 300,000 in two consecutive years. Companies within scope must record all transactions in a digital bookkeeping system that is registered with Erhvervsstyrelsen or meets the act’s functional requirements, store records and documentation digitally for five years, and use a system able to send and receive e-invoices in the common public formats.

A parallel track covers standards. In March 2026 Erhvervsstyrelsen confirmed that OIOUBL 3.0 has been cancelled and that Denmark is moving towards Nemhandel BIS 4, a Danish implementation of Peppol BIS 4.0 following the PINT methodology and aligned with the revised EN 16931. Migration is scheduled between 2028 and mid-2029. Peppol.now covered that shift earlier in Denmark e-invoicing Peppol standard: from dual system to a single standard.

E-invoicing Denmark compared with the Netherlands and Belgium

The comparison with the Netherlands is instructive precisely because neither country currently has a general B2B mandate. The difference lies in the sequence. Denmark first anchored the administrative layer in law, through digital bookkeeping, registered systems and a national recipient register, and is now using that layer to make e-invoicing the default behaviour. The Netherlands is still debating the scope of the mandate itself, weighing a minimal ViDA-A variant against a broader ViDA-B variant that would also cover domestic B2B invoices, with a consultation planned for the fourth quarter of 2026. Our report on the Dutch cabinet decision on the e-invoicing mandate sets out both scenarios.

Belgium chose a third route: a mandatory 4-corner Peppol model for domestic B2B invoices since 1 January 2026, with a 5-corner e-reporting model as the ambition for 2028. Three markets, three sequences, one shared European endpoint. From 1 July 2030 ViDA requires digital reporting and e-invoicing for intra-EU B2B transactions, after which national systems must be harmonised on EN 16931 by 2035. On the enforcement side, our analysis of fines and soft-landing periods across Europe adds useful background.

What it means for Dutch and Belgian businesses

Companies supplying Danish customers will probably notice the effect in practice before they notice it in the rulebook. If a large share of Danish SMEs is listed in the NemHandel register by default from 2027, the likelihood that a Danish customer expects or simply accepts an e-invoice rises even without a legal obligation. Three practical points:

• Check that your Peppol Serviceprovider queries the Danish recipient register and supports both OIOUBL 2.1 and Peppol BIS during the transition.
• Factor in the migration to Nemhandel BIS 4 between 2028 and mid-2029, and ask your provider for a roadmap.
• Do not confuse this with a mandate. Denmark has no penalty regime for failing to send B2B invoices electronically, although the Bogføringsloven does have its own enforcement framework for the bookkeeping obligation.

For Dutch and Belgian businesses, e-invoicing Denmark is above all a preview of what a mature national ecosystem does to adoption. Not coercion, but a well-populated address register and a default button pointing the right way. If your own connectivity is still open, the Peppol Serviceprovider comparison tool compares providers covering the Danish, Belgian and Dutch routes in one solution.

Sources

1. Erhvervsstyrelsen, “Bekendtgørelse med nye krav til digitale standard bogføringssystemer er nu i høring”, 2 July 2026
2. Høringsportalen, “Høring over udkast til bekendtgørelse om ændring af bekendtgørelse om krav til digitale standard bogføringssystemer”, case number 2025-11688, published 1 July 2026
3. Erhvervsstyrelsen, “Nemhandel – fælles digital infrastruktur”
4. VATupdate, “Denmark Proposes Default E-Invoicing Rules to Boost Adoption and Fight Tax Fraud”, 18 August 2026
5. Fiscal Solutions, “Denmark proposes new requirements for digital bookkeeping systems to promote e-invoicing”
6. VATupdate, “Denmark Unveils Nemhandel BIS 4 E-Invoicing Standard, Cancels OIOUBL 3.0, Sets 2029 Migration Timeline”, 23 March 2026
7. Government of the Netherlands, “Aanbiedingsbrief rapport ViDA e-facturatie en digitale rapportage”, 10 March 2026