E-Invoicing in Denmark: Automatic Nemhandel Sign-Up From 2027

For more than two decades, e-invoicing in Denmark has been optional for transactions between private businesses. That is now changing in a quiet but meaningful way. On 25 September 2026, KPMG reported that the Danish Business Authority (Erhvervsstyrelsen) has moved the start of its campaign to increase e-invoicing to 1 March 2027, two months later than the 1 January 2027 date set out in the original proposal. The direction has not changed: from that date, registered bookkeeping systems will have to sign their users up to receive e-invoices by default.

What Happened

On 1 July 2026, Erhvervsstyrelsen sent a draft amendment to the executive order on digital standard bookkeeping systems out for public consultation, with a deadline for responses of 17 August 2026. The draft sets out three main changes. First, system providers must register their users for e-invoicing in Nemhandel, the Danish public infrastructure for exchanging electronic invoices, unless the user opts out. Second, systems should check whether a recipient is registered and present e-invoicing as the primary option. Third, the draft adds security measures, including identity verification and tighter controls on who can change company information.

According to KPMG Denmark’s update of 25 September 2026, the deferred requirements work like this from 1 March 2027. Users of registered bookkeeping systems will be told that they are being registered in the Nemhandel Register, and they will have four weeks to opt out. When an invoice is created manually, the system must show clearly whether the recipient is registered in Nemhandel. KPMG also notes that Denmark plans to replace its two current e-invoice formats, OIOUBL and Peppol BIS, with a single Peppol-based specification, with the transition starting in mid-2028 and the existing formats phased out by mid-2029.

The gap Erhvervsstyrelsen is trying to close is large. KPMG cites figures showing that 85% of Danish companies use a registered digital bookkeeping system, but only 17% of those are registered in the Nemhandel Register. Most invoices between Danish businesses are still sent as PDFs by email, even though the systems in use can often handle structured e-invoices.

Why E-Invoicing in Denmark Matters for Small Businesses

For a small company, the most direct effect is that the decision will, in practice, be made for you unless you act. If your bookkeeping system is on Erhvervsstyrelsen’s list of registered systems, you can expect a notice in 2027 and, if you do nothing, your business will become reachable as an e-invoice recipient. Suppliers who check the register will then be able to send you structured invoices instead of PDFs. That is generally positive, because structured invoices can be read straight into the bookkeeping system, which reduces manual typing and errors. It does require that someone in the business knows where those invoices arrive and how they are approved and posted.

The change also builds on the digital bookkeeping rules that are already in force. Companies covered by the Danish Financial Statements Act have been phased in since 2024, and personally owned businesses with net turnover above DKK 300,000 in two consecutive financial years must keep digital books for financial years starting on or after 1 January 2026, as Beierholm summarises. Many sole traders who moved to a registered system this year will therefore meet the Nemhandel change soon after.

There is a European dimension too. The EU’s VAT in the Digital Age package (ViDA) was adopted on 11 March 2025 and entered into force on 14 April 2025. According to the European Commission, digital reporting requirements will apply to cross-border B2B transactions from 1 July 2030, and member states can already introduce mandatory domestic e-invoicing under specific conditions. Denmark has not announced a domestic mandate, and the 2027 change is presented as an opt-out, not an obligation to send e-invoices. Even so, businesses that trade with customers in other EU countries will benefit from getting used to structured invoicing well before 2030.

Practical Next Steps

A sensible first step is to find out where you stand today. Check whether your bookkeeping system is a registered standard system, and whether your company is already registered in Nemhandel. Your system provider should be able to answer both questions, and many systems show this in their settings.

Next, decide whether you want to be registered or to opt out when the notice arrives. For most businesses, receiving e-invoices will save time. However, a company with an unusual invoice approval process, several legal entities or an external bookkeeper may need to plan the set-up first, so that invoices land in the right place and the right people are notified. Agree internally who will read and respond to the notice from your provider, because the opt-out window is only four weeks.

Then look at the sending side. If you invoice other businesses, it is worth testing whether your system can send e-invoices to customers who are registered, and whether your customer master data, such as CVR numbers and contact details, is accurate. Clean master data is also useful for future reporting, as KPMG points out that the SAF-T file requirement in Denmark currently covers only header information and may expand over time.

Finally, keep an eye on the final version of the executive order. The consultation draft included new identity and security requirements for system users, and the exact wording and dates in the final rules may differ from the draft. Because the rules interact with your own bookkeeping, VAT and approval procedures, it is wise to get advice that fits your own situation before you change your set-up.

Brenvard's perspective

This change affects Brenvard directly too. As a Danish ApS covered by the digital bookkeeping rules, we are in the same position as many of our readers: if our bookkeeping system is registered, a notice will arrive in 2027, and we will need to decide whether to stay registered in Nemhandel, who receives incoming e-invoices and how they are approved. For our internal routines, structured invoices should mean less manual entry and fewer errors, but only if supplier data and approval steps are tidy. On the advisory side, the change creates practical demand for help with set-up and opt-out decisions, while it also removes some routine bookkeeping work as more invoices flow straight into systems. We see that as a reasonable trade: less typing, and more time for reviewing the numbers and the reporting behind them.

A Gradual Shift With Long Lead Times

The deferral to 1 March 2027 gives businesses a few extra months, and the move to a single Peppol format and the EU’s 2030 reporting rules are further away still. That long timeline is an advantage for small companies that use it well. Making e-invoicing part of an ordinary finance routine now is usually simpler than adapting under deadline pressure later. Brenvard helps startups and smaller businesses review bookkeeping systems, invoice flows and reporting set-ups through its finance and accounting services, including the practical choices to make before the notice from your provider arrives.

Sources

KPMG – Denmark: Deferred launch of voluntary e-invoicing to March 1, 2027 (25 September 2026)
KPMG Denmark – Recent update on e-invoicing in Denmark (25 September 2026)
Høringsportalen – Høring over udkast til bekendtgørelse om ændring af bekendtgørelse om krav til digitale standard bogføringssystemer (1 July 2026)
European Commission – VAT in the Digital Age (ViDA) (accessed 1 October 2026)
Erhvervsstyrelsen – Krav til digital bogføring træder i kraft (2 January 2024)
Beierholm – Digital bogføring 2026: krav til personlige firmaer m.fl. (22 April 2025)