Danish digital bookkeeping obligation

Danish digital bookkeeping obligation moves forward. Although there are no official dates yet, the Danish authorities have published an estimated timeline for the introduction of this obligation, which is rolling out in phases.

The only certainty in terms of deadlines is that digital bookkeeping obligation will apply from the first accounting or income period that starts after the requirement for digital bookkeeping has come into force.

Service providers are already required to notify their digital bookkeeping solutions to the Danish Virk. If the solution is already on the market, the service provider must notify the authorities before 31 October 2023.

Danish Virk plans to publish a list of registered standard accounting systems meeting the requirements, by January 2024.

Based on the estimated timeline, by July 2024 the first businesses will be subject to the digital bookkeeping obligation. This concerns those companies with an obligation to submit annual accounts and which are already using a standard digital bookkeeping system. For example, companies with a turnover higher than DKK 300,000 in each of the past two years.

Foreign non-established companies’ VAT registered in Denmark may have to comply with this obligation. The fact that you have a Danish VAT number means you have to comply with the bookkeeping law. The obligation for digital bookkeeping arises in the following scenarios, according to Section 6 of the Law:

• If you have the obligation to submit an annual report, or
• If your net turnover exceeds DKK 300,000 in two consecutive years.

This obligation must not be confused with electronic invoicing. Although the standard digital bookkeeping systems must allow the issuance of electronic invoices, the new obligation does not dictate how companies must issue their invoices. Official information can be found here.