Denmark Proposes Auto-Enrolling 125,000 Businesses into NemHandel E-Invoicing
Denmark's Business Authority proposed new rules on registered digital bookkeeping systems that would auto-register users in NemHandel e-invoicing unless they opt out. The consultation closed 17 August 2026, with most rules due to take effect 1 January 2027 — not a general B2B mandate, but a major nudge toward voluntary adoption.
Denmark does not have a general B2B e-invoicing mandate — unlike Germany, France, Italy, or Poland, structured e-invoicing between private businesses remains voluntary. But a proposal from the Danish Business Authority (Erhvervsstyrelsen), out for public consultation until 17 August 2026, would push adoption sharply upward without formally mandating it.
What's Being Proposed
The rules apply specifically to registered standard digital bookkeeping systems — the category of accounting software that has been required to formally register with the Business Authority under Denmark's Bookkeeping Act (Bogføringsloven). For businesses using one of these registered systems, the proposal would:
- Auto-register them in NemHandel (Denmark's e-invoicing infrastructure) for e-invoicing, unless they actively opt out
- Make e-invoicing the default/first invoicing option shown in the software, where feasible
- Require providers to implement stronger security and data-integrity controls: identity verification, protection of company master data, better record searchability, and technical safeguards blocking deletion of required accounting material
Customized or non-registered bookkeeping systems are out of scope — this is targeted specifically at the standard, registered-system segment of the market.
Timeline
| Date | Milestone |
| 17 August 2026 | Public consultation closes |
| Early September 2026 (expected) | Final executive order issued |
| 30 November 2026 | Customer-notification requirements begin |
| 1 January 2027 | Most rules take effect, including SAF-T 2.0 generation capability |
Scale
The Danish Business Authority estimates the change could bring roughly 125,000 additional businesses into e-invoicing infrastructure that were previously invoicing on paper or by unstructured PDF, simply by changing the default rather than requiring active sign-up.
What This Means for Businesses Trading with Denmark
If your business regularly invoices Danish counterparties, expect a growing share of them to be reachable via NemHandel from early 2027 — even though Denmark still has no B2B mandate forcing it. This mirrors how default/opt-out registration (rather than compulsion) has driven adoption curves elsewhere on the Peppol network.
Source
VATupdate, Denmark Proposes New Digital Bookkeeping Rules to Promote E-Invoicing.
