Regulatory updates - Denmark

Compared with SAF‑T 1.0, SAF‑T 2.0 expands the required structure and content to enable future exchange and sharing of transaction-level accounting data with the public sector and partners in a standardized format.

The main changes in SAF-T 2.0 include:

• Introduction of the concept of MIFU (Mandatory if used)
• Mandatory Masterfiles
• Mandatory GeneralLedgerEntries
• Mandatory fields with suspension in the Executive Order on requirements for digital standard accounting systems (BEK 97 of 26/01/2023)
• MIFU fields for reporting to the Danish Tax Agency, Statistics Denmark and other data sharing use cases
• The introduction of the XML attribute Nil

Details on the updated SAF-T 2.0 version are available here.

The suspension of the OIOUBL 3 release follows a review of the document strategy which was announced in March 2025, followed by meetings organized by Nemhandel in June and October updating service providers on the progress.

Now, the Authority confirms OIOUBL 3 will no longer be released based on feedback from service providers indicating extensive implementation work and effort would be required. Instead, the Authority will work toward only using one standard rather than the current dual use of the Peppol and OIOUBL standards.

A new Nemhandelsforum providing further details will be held February 24, 2026.

Denmark continues strategic developments in e-invoicing and digital bookkeeping. The Danish Business Authority is advancing several initiatives to enhance standardization, improve data quality, and increase automation across business transactions. These developments align with broader European digital transformation efforts and prepare Danish businesses for upcoming EU requirements.

Document standard strategy

Following the postponement of OIOUBL 3.0, the Danish Business Authority is currently finalizing its analysis after consultation with selected stakeholders, along with legislative objectives and associated cost assessments. The results and strategy, which were expected in October 2025, have been delayed and are anticipated in the first quarter of 2026.

While major updates to the national e-invoicing standard remain under review, the Release Candidate of the latest version of OIOUBL 2.1 was published on October 14, 2025. This update aims to help businesses reduce manual reporting of climate data by including support for climate data (CO2) in e-invoices. The CO2 data fields will remain optional, and the final release is scheduled for the end of October 2025.

SAF-T 2.0 and G2B transactions

The final version of SAF-T 2.0 is being finalized following public consultation and is expected to be published at the end of 2025.

For government-to-business (G2B) transactions, the Danish Regulatory Forum (Regelforum) has recommended that public entities send e-invoices to businesses, mirroring the existing requirement for businesses to send e-invoices for B2G transactions. The Economic Development Agency (Økonomistyrelsen) is currently reviewing this recommendation with assistance from the Danish Business Authority.

Evaluating future requirements for digital bookkeeping systems

In view of ViDA requirements for intra-EU transactions taking effect in July 2030, the Business Authority is considering additional requirements for registered Standard Digital Bookkeeping Systems to advance digitalization, improve data quality, and boost efficiency. The proposals include:

• Targeting 70% e-invoicing adoption by 2027;
• Requiring businesses to be registered in the Nemhandelregister (NHR) with an opt-out option; and
• Requiring API integration with Nemhandel to automate identification of e‑invoice recipients.

The proposed requirements for registered Standard Digital Bookkeeping Systems, are proposed to eventually extend to Specially Developed Systems as well.