Denmark

Bookkeeping Act update Last month, we said progress around on the Bookkeeping Act, which aims to digitise accounting records in Denmark, had stalled somewhat due to the introduction of a new government. The Danish Authorities have since issued a new update in respect of the Bookkeeping Act.   From 1 February 2023, a new schedule for the digital bookkeeping standard came into effect.  All digital standard systems that need to be registered will need to do so by 1 January 2024.   We are awaiting more detailed requirements from the Danish government, as well as exact timeframes as to when companies are expected to comply with the Bookkeeping requirements.  

Delay to bookkeeping act On 13 December, Denmark delayed the implementation of the Bookkeeping Act. Please refer to Tungsten’s previous post summarising details of the Act.   The delay is most likely due to the takeover of the new government. Once the new government is fully functional, new timeframes for implementation will be announced.  

B2G e-invoicing with digital labelling Fiscal policies are intrinsically linked with the advancement of social agendas and programmes. This has been seen prominently with the introduction of multiple plastic and carbon taxes, amongst others, and we expect these agendas to further expand in 2023.  Denmark is one such currently which is using its fiscal policies to showcase a distinctly more ‘green’ agenda.  The Danish Business Authority, the Erhvervsstyrelsen has published the following: 

• OIOUBL version 2.1 and associated OIOUBL Schematrons 1.12 

This introduces the functionality to utilise digital sustainability labels, reducing the need for paper, much like e-invoicing, which also serves to further a significant environmental agenda in the country. 

Mandatory e-invoicing via Bookkeeping Act Despite momentum around e-invoicing being relatively quiet in Denmark in comparison to other countries, this month there have been some very significant developments concerning e-invoicing in the country. The Bookkeeping Act is expected to come into force on 1^st July 2022, which envisages the digitisation of bookkeeping in Denmark. This means all transactions will need to be recorded in a digital system. All documents relating to these transactions must also be preserved in a digital format. The requirements will apply to all enterprises subject to the obligation to present financial statements in accordance with the Danish Financial Statements Act. Implementation of the requirements is expected to follow a phased approach- in line with the following:

• 1 July 2022: The Act is expected to come into force
• 1 January 2023: The Danish Business Authority lays down rules and requirements for bookkeeping systems
• 1 July 2023: Existing suppliers of digital bookkeeping systems must meet the new requirements for digital bookkeeping systems and be registered with the Danish Business Authority
• 1 January 2024: Enterprises covered by the Danish Financial Statements Act’s reporting classes B, C and D must meet the new requirements for digital bookkeeping systems for financial years commencing on or after 1 January 2024
• 1 July 2024: Enterprises covered by the Danish Financial Statements Act’s reporting classes B, C and D and which use their own bookkeeping system that has not been registered with the Danish Business Authority must meet the digital bookkeeping system requirements
• 1 January 2026: Enterprises covered by the Danish Financial Statements Act’s reporting class A and whose revenue exceeds DKK 300,000 must meet the new requirements for digital bookkeeping systems for financial years commencing on or after 1 January 2026
• 1 July 2026: Enterprises covered by the Danish Financial Statements Act’s reporting class A and whose annual revenue exceeds DKK 300,000 for two consecutive years, and which use their own bookkeeping system, must meet the digital bookkeeping system requirements.

This is a significant development in Denmark. Tungsten Network is analysing the requirements and monitoring further e-invoicing developments in the country and what this means for our service offering in the country.

Plans for CO2 tax The Danish government has outlined an ambitious aim of reducing greenhouse gas emissions by 70% by 2030. To this effect, on 20 April 2022, the Danish government announced some green tax reform measures, including the introduction of a new CO2 tax. This will include a fixed minimum amount per tonne of C02. The Danish government will implement this across companies in a phased approach, between 2025 and 2030.

E-orders and e-catalogs by 1 January 2023

As from 2023 new legal e-ordering requirements for public authorities and institutions will become applicable.

As a consequence suppliers will be required to be able to receive e-orders and have e-catalogs (which will comply with the new Peppol standard) on the covered purchasing categories. A report regarding these requirements is scheduled to be sent out for consultation before the Summer holidays.

Denmark implements EU VAT Directive 55

The European Union (EU) VAT Directive 55 obliges all EU public authorities to receive invoices electronically, or at least to have a defined for how they will do so, by 27 November 2018.