Regulatory updates - Denmark

The proposal is currently under public consultation until August 17, 2026. The Danish Business Authority expects the final executive order to be issued in early September 2026. Under the draft, most requirements would apply from January 1, 2027, while provisions relating to notifications to new and existing end customers would apply from November 30, 2026. The draft amendments form part of the Danish Business Authority's efforts to increase e-invoicing adoption.

Proposed new requirements apply specifically to registered standard DBS

The current proposal introduces new requirements concerning the functionality of standard digital bookkeeping systems that must be registered with the Danish Business Authority. At this stage, the proposed requirements do not extend to custom digital bookkeeping systems.

Requirements aim to increase voluntary e-invoicing adoption

Proposed requirements for registered standard DBS include:

• Registration in Nemhandelsregistret: The proposal would change the current opt-in process to an opt-out process. Providers of registered standard DBS must register end customers for e-invoicing in Nemhandel unless the end customer is already registered or opts out within a four-week period.
• E-invoicing presented as the first choice: Systems would be required to check whether an invoice recipient is registered in Nemhandel and, where this is the case, present e-invoicing as the first/default sending option. The sending method would remain voluntary.
• Additional security and data-integrity measures: The proposal introduces additional identity-verification, master-data integrity, searchability, and record-retention requirements for registered standard DBS.

The proposal does not introduce a general obligation for Danish businesses to issue or receive B2B (business-to-business) e-invoices. Instead, it expands the requirements for registered standard DBS to make e-invoicing more accessible, prominent, and secure. Businesses would still be free to choose another sending method when issuing invoices.

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.