Regulatory updates - Denmark

The strategy underlines that the planned transition to Nemhandel BIS 4 depends on the development of Peppol BIS 4, which is expected to support Danish national extensions while preserving international interoperability through incorporation of the PINT architecture.

Timelines

Subject to timely completion of underlying standards, the strategy indicates the following migration path:

• Release candidate (expected to run from November 2027 to May 2028): A proposed version of Nemhandel BIS 4 is released for comments and input.
• Final release (May 2028): Provided the release candidate does not require significant revision, a final release follows, during which support for Nemhandel BIS 4 remains voluntary, while support for OIOUBL 2.1 remains mandatory.
• Phase-in period (May to November 2028): An implementation period precedes the transition of roles. After this period, support for Nemhandel BIS 4 becomes mandatory, while support for OIOUBL 2.1 becomes voluntary.
• Phase-out of OIOUBL (November 2028 to May 2029): OIOUBL 2.1 will no longer be supported.

OIOUBL 2.1 will be maintained until the transition to Nemhandel BIS 4 is completed.

Document types in scope

The initial scope of the transition is limited to invoice-related documents:

• Invoice
• Credit note
• Invoice response/application message

Other document types, such as e-orders and e-receipts, are suggested to remain in both OIOUBL and Peppol for the time being. The Authority states that migration of the remaining OIOUBL document types will require further analysis and depends on Peppol upgrading those document types to the PINT architecture.

Legal effect

The strategy does not entail any immediate changes, and current compliance obligations remain unchanged. Once the transition to Nemhandel BIS 4 is complete, however, the Authority proposes amending the current Bookkeeping Act requirement for digital bookkeeping systems to support both OIOUBL and Peppol BIS, so that only Nemhandel BIS support is required.

Feedback on the strategy may be submitted to info@nemhandel.dk no later than March 27, 2026.

The announcement follows the cancellation of OIOUBL 3, and is the result of an analysis conducted by the Danish Business Authority during the last year.  

As part of the expected phase out, a migration timeline from OIOUBL 2.1 to Nemhandel BIS 4 was revealed, proposed to run from 2028 to mid-2029. A release candidate for Nemhandel BIS 4 is expected in 2028, with subsequent timelines for final release and the implementation of the new standard alongside the phase out of OIOUBL 2.1.

More details are yet to be announced by the Danish Business Authority.

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.