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E-Invoicing in Denmark: Proposed 2027 Changes

E-invoicing in Denmark may become the default receiving setup for many businesses using registered digital bookkeeping systems from 2027, unless they actively opt out.

Last updated: August 2026

A supplier invoice can reach a Danish business in several ways. It may arrive as a PDF by e-mail, through a supplier portal, through an expense-management tool, or as a structured e-invoice that a bookkeeping system can process electronically.

E-invoicing in Denmark could become much more common under a proposal that Erhvervsstyrelsen has sent into public consultation. Public consultation closes on 17 August 2026. Under the proposal, providers of registered digital standard bookkeeping systems would register end customers for e-invoice receipt through Nemhandel unless the business actively opts out. Erhvervsstyrelsen proposes 1 January 2027 as the main effective date.

The proposal is still under consultation. Businesses do not have a new legal action deadline today, and the final rules may change before adoption.

What counts as e-invoicing in Denmark?

An e-invoice is a structured electronic invoice or credit note that an accounting or bookkeeping system can process automatically and electronically.

A PDF sent by e-mail does not meet that definition. PDFs, image files and similar formats still need an extra reading or data-capture step before the system can treat the information as structured accounting data.

Denmark’s Nemhandel infrastructure supports structured business documents through standards such as OIOUBL and Peppol BIS. Nemhandel combines common document standards, a recipient register and a transport layer for exchanging business documents between systems.

This distinction matters because the proposal concerns structured e-invoicing and Nemhandel registration. It does not simply change how companies send PDF invoices.

What are the current rules?

Registered digital standard bookkeeping systems already have to support e-invoicing. Under the current setup described by Erhvervsstyrelsen, the system provider tells end customers that they can register for e-invoicing in Nemhandel. The provider completes the registration when the customer chooses that option.

The technical capability therefore already exists in registered systems. Today, the process depends on an active choice from the business.

The proposal would reverse that default.

What would change for e-invoicing in Denmark?

The proposed rules would require the provider of a registered digital standard bookkeeping system to register its end customers for e-invoice receipt unless the individual business opts out.

For existing end customers who are not already registered, the provider would have to send direct information about the upcoming registration by 30 November 2026. Businesses would then have four weeks to opt out. The provider would register existing end customers who do not opt out by 1 January 2027.

New end customers created after the notification phase would receive similar information and a four-week period to decline registration.

Registration would remain reversible. A business could later ask the system provider to deregister it, while a company that previously opted out could choose to register later.

The proposal therefore changes the default process around registration without making registration irreversible.

Sending e-invoices could become the first option in your system

A second proposed change concerns outgoing invoices.

When a business creates an invoice, the bookkeeping system would have to check automatically whether the recipient appears in the Nemhandelsregistret. If the recipient is registered, the system would present e-invoicing as the first sending option.

The proposal does not require the sender to choose e-invoicing in every such case. Erhvervsstyrelsen’s reading guide explicitly says that the end customer could still choose another sending method.

That still represents a meaningful change in user behaviour. A company that currently sends most invoices as PDFs may start seeing e-invoicing as the default option whenever the customer can receive it.

Who is actually affected?

For e-invoicing in Denmark, the proposed amendments target providers of registered digital standard bookkeeping systems and the end customers whose bookkeeping takes place in those systems.

The draft also recognises outsourced bookkeeping arrangements. The bookkeeping-liable business remains the end customer, while the system provider’s direct customer may be a bookkeeping firm that works on behalf of several end customers. Individual users can include employees of the business itself or people at an external bookkeeping provider.

This distinction matters for companies that outsource accounting. Your accountant may work in the system, while your company remains the end customer whose invoice-routing setup matters.

Businesses using bespoke or non-registered bookkeeping systems operate under a different regulatory framework. This proposal specifically targets registered digital standard bookkeeping systems.

Before registration, understand what Nemhandel receipt means

Under the proposed rules, the system provider would have to explain several consequences before registering an end customer.

A recipient in the common digital infrastructure could not refuse an e-invoice solely because it arrives in electronic format. The recipient also could not disadvantage a sender solely because the sender used that format. The end customer would retain the right to request deregistration later.

For management, registration therefore becomes more than a technical system setting. Once the company appears in Nemhandel, suppliers can identify that the business accepts structured e-invoices through the relevant endpoint.

That makes invoice ownership and routing worth reviewing before volumes increase.

Practical issue 1: who monitors incoming e-invoices?

Many companies use a simple informal control today. Supplier invoices arrive in a shared mailbox, an employee recognises the supplier, someone approves the invoice, and the document reaches bookkeeping.

As e-invoicing in Denmark becomes more common, structured invoices can remove parts of that manual path. This usually improves efficiency, but it can also create a visibility gap if the business assumes that every supplier invoice will continue to appear in the same e-mail inbox.

A practical process should answer a few basic questions:

  • Who checks newly received e-invoices?
  • Where does the accounting system place them before bookkeeping?
  • Who follows up on rejected, disputed or incomplete invoices?
  • Does management receive an approval request before the invoice can move further?
  • Who covers the process during holidays or employee absence?

The proposed regulation does not prescribe your internal approval workflow. These questions are internal controls that become more important as invoice receipt becomes increasingly system-based.

Practical issue 2: prevent PDF and e-invoice duplicates

A transition period can create parallel invoice channels.

A supplier may send an e-invoice after finding your company in Nemhandel and still send the usual PDF by e-mail. Another supplier may switch formats without telling the person who normally approves invoices.

If both documents enter the bookkeeping process independently, the same supplier invoice can appear twice.

A strong duplicate control should therefore use more than the arrival channel. Supplier identity, invoice number, invoice date and amount give useful matching points. Payment controls should also prevent a second payment if two representations of the same invoice reach different parts of the workflow.

This is an operational recommendation rather than a new requirement in the proposed regulation. It remains one of the most important practical questions for businesses that use several invoice-intake channels.

Practical issue 3: check where your Nemhandel registration points

A business can register in Nemhandel through different endpoint identifiers.

Erhvervsstyrelsen’s reading guide says the CVR number should generally be the starting point when a business wants to receive e-invoices in one system. A P-number can support routing by production unit. GLN/EAN numbers can provide more active control over invoice receipt, while other endpoint types can apply in specific cases.

Existing registrations deserve particular attention. If an end customer already receives e-invoices through another system, the new system provider would not have to move that registration automatically. Instead, the provider may tell the customer that it can redirect e-invoices to the new system.

A company that has changed bookkeeping systems, used a separate invoice platform or worked with several accounting providers should therefore ask a practical question: where are e-invoices actually being delivered today?

The public Nemhandelsregistret allows lookups of registered recipients and supported profiles. Businesses with more complex setups should check this before assuming that a new bookkeeping-system registration will automatically replace an old route.

Practical issue 4: company groups need deliberate routing

Routing becomes especially important when a group has several legal entities, production units or invoice destinations.

An invoice should reach the correct company. A supplier that selects the wrong CVR number can create a bookkeeping and approval problem even when the technical delivery succeeds.

The same issue can arise when a recipient has several GLN/EAN endpoints. Erhvervsstyrelsen’s implementation guidance says the bookkeeping system does not need to identify the correct endpoint automatically when many are available. The sender may still need to agree the correct endpoint with the recipient.

Growing companies should therefore document which entity and endpoint suppliers should use. A short internal routing table can prevent invoices from landing in the wrong company or department.

Practical issue 5: approval and payment authority still matter

Structured invoice data can make bookkeeping faster because the system receives information in a machine-readable format.

That efficiency should preserve the commercial approval step. The company still needs to confirm that it ordered the goods or services, the amount is correct, the supplier is legitimate, the invoice belongs to the correct legal entity, and payment should be released.

For many SMEs, a sensible workflow separates invoice receipt, bookkeeping review, business approval and payment authorisation. The exact model depends on company size and risk, but the responsibilities should be clear.

E-invoicing changes how information enters the system. Management still needs to design a sensible internal process around that information.

For a broader look at why regular controls matter, see our guide to bookkeeping in Denmark and avoiding year-end cleanup.

The proposal also contains new security measures

The consultation package goes beyond e-invoicing.

Erhvervsstyrelsen also proposes stronger identity verification for customers, end customers and individual users of registered bookkeeping systems. The provider would generally use MitID for Danish users and suitable alternative identity measures for foreign users.

Alongside e-invoicing in Denmark, the proposal would strengthen control over company master data. Bookkeeping systems would retrieve core information such as company name, address and CVR number from CVR and lock those fields. A user who changes supplementary master data, including payment information and GLN/EAN data, would have to verify their identity again.

These measures aim to strengthen traceability and reduce the risk of unauthorised changes. They may also change who can create users or update sensitive company information inside the bookkeeping system.

A practical preparation checklist

  • Check whether your company already appears in the Nemhandelsregistret and identify the current endpoint.
  • Map every channel through which supplier invoices arrive, including e-mail, portals, expense tools and e-invoicing.
  • Decide who owns the incoming-invoice queue and who acts as backup during absence.
  • Define how the business detects duplicate invoices across PDF and structured e-invoice channels.
  • Verify that suppliers use the correct CVR, P-number or GLN/EAN endpoint when your setup needs specific routing.
  • Review user access and identify who can change payment information or other sensitive master data.
  • Document the approval path from invoice receipt to bookkeeping and payment.
  • Ask your bookkeeping-system provider how it plans to implement the final requirements for e-invoicing in Denmark once the consultation is complete.
  • Avoid changing a working process solely because of the draft rules. Use the consultation period to understand the current setup and identify weaknesses.

Do businesses need to act now?

There is no immediate new legal action required from businesses based solely on this consultation.

The consultation remains open until 17 August 2026, and the final wording can change. The current draft points to implementation from 1 January 2027, with earlier notification provisions for system providers.

A useful step today is process review. Companies can check existing Nemhandel registrations, invoice channels, approval responsibilities and routing without making irreversible changes.

That work has value even if the final regulation changes. E-invoicing in Denmark already exists, registered bookkeeping systems already have to support it, and better invoice routing and duplicate controls improve bookkeeping regardless of the final consultation outcome.

You can also review our overview of common bookkeeping mistakes in Denmark for other control points that often create avoidable corrections.

Frequently asked questions

Is a PDF invoice an e-invoice in Denmark?

No. Erhvervsstyrelsen defines an e-invoice as a structured electronic invoice or credit note that a system can process automatically and electronically. A PDF or image file does not qualify simply because someone sends it digitally.

Will all Danish B2B invoices become mandatory e-invoices in 2027?

No general mandate appears in the current proposal. Instead, the proposal would make Nemhandel registration the default for end customers using registered digital standard bookkeeping systems unless they opt out. When the recipient is registered, the bookkeeping system would present e-invoicing as the first sending option, while the sender could still choose another method.

Can a business opt out of automatic registration?

Yes, under the proposal. New and existing end customers would receive information and a four-week period to decline registration. A registered business could also request deregistration later.

What if the company is already registered in Nemhandel through another system?

Erhvervsstyrelsen’s reading guide says the new provider would not have to re-register the company into its own setup. The company should check where its current endpoint routes invoices and decide whether it wants to keep or change that routing.

Does automatic e-invoice receipt mean invoices can be paid automatically?

No. E-invoicing concerns the structured exchange and processing of invoice data. Approval and payment controls remain part of the company’s internal financial process.

Want to review how invoices enter your bookkeeping?

Andreas Regnskab helps Danish businesses and international founders review invoice intake, routing, duplicate risks and approval responsibilities so the bookkeeping process stays clear as e-invoicing in Denmark develops.

Book a consultation

Sources and further reading

This article is based on draft rules published for public consultation and reflects the proposal available at the time of research. The final regulation may change. This article provides general information and does not constitute legal advice for a specific company setup.