Digital bookkeeping in Denmark is a legal and operational requirement, not simply a choice to use accounting software. First establish whether the duty applies to the Danish business, then confirm that the system, documents, controls and access meet the relevant requirements.
For international companies, the important decision is often whether to use a registered system or retain a foreign group ERP. Both routes can work, but they place different responsibilities on the business. This guide focuses on scope and system readiness; our accounting services cover the recurring bookkeeping and reporting workflow.
1. Establish whether the digital duty applies
An ordinary Danish ApS or A/S required to file an annual report enters through the annual-reporting rules. It does not receive a two-year exemption simply because turnover is low.
For covered businesses that are not required to file an annual report, the turnover route generally applies when actual net turnover exceeded DKK 300,000 in each of two consecutive income years. A forecast is not enough, and the threshold is not a general exemption for every small company.
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| Danish setup | Starting point for the assessment |
|---|---|
| ApS or A/S with an annual-report duty | Check the annual-reporting commencement date and current system compliance |
| Covered business without an annual-report duty | Test actual net turnover in the two relevant preceding income years |
| Foreign company’s Danish branch or commercial activity | Assess the Danish activity and applicable reporting/turnover route |
| Foreign company with a Danish VAT or tax registration only | Do not decide scope from the registration number alone |
The general Bookkeeping Act and the mandatory digital rules have different scope tests. A foreign business can have Danish recordkeeping duties even where its digital-duty position needs a more detailed assessment. Document the facts and conclusion using the Bookkeeping Act guidance.
2. Identify the first year that must comply
The digital requirement was phased in by reporting status and system type. These dates refer to the start of the relevant financial or income year.
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| Business category | System route | Relevant years begin on or after |
|---|---|---|
| Annual-reporting businesses | Registered system | 1 July 2024 |
| Annual-reporting businesses | Non-registered system | 1 January 2025 |
| Covered non-annual-reporting businesses above the turnover threshold | Either route | 1 January 2026 |
The official scope and commencement guide explains the categories. For a calendar-year ApS using a registered system, the first relevant financial year normally began on 1 January 2025.
For the turnover route, use actual net sales after the relevant deductions, including VAT. A short first income year can still count as one of the two years. For example, a business established in March 2024 that exceeded DKK 300,000 in both its first income year and 2025 could enter the requirement in 2026.
A new non-annual-reporting business is not brought into that turnover route by its budget alone. Keep this distinction separate from the annual-reporting route for an ApS.
3. Choose a registered system or validate the group ERP
A system on the Authority’s register places responsibility for the registered system’s statutory technical requirements on the provider. The business still has to record complete transactions, supply documents, reconcile balances and use the system correctly.
A foreign or custom system can also be used. If it is not registered, the business must ensure that its setup meets the requirements for non-registered systems. A headquarters policy saying “all subsidiaries use this ERP” is not evidence of Danish compliance.
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| Operating model | Evidence to obtain |
|---|---|
| Registered bookkeeping system | Current registration, applicable product/module coverage and a working document process |
| Non-registered or foreign group ERP | A documented mapping of Danish requirements to configuration, controls, storage and exports |
| External bookkeeping provider | Clear system responsibility, document handover, access, reconciliation and exit arrangements |
Check the live register of bookkeeping systems. A registration does not amount to approval of the company’s actual bookkeeping.
Map connected apps too. The ledger, invoice archive, expense tool and interfaces form an operating chain. Do not assume a registered core system covers documents stored elsewhere or every external add-on.
4. Test the system with real transaction flows
For a non-registered setup, use the Authority’s system requirements and checklist. Validate the following areas before relying on the system for the Danish operation:
- Transaction information: dates, amounts, descriptions, unique identifiers and relevant currency information are recorded.
- Transaction trail: figures in reports can be traced back to the ledger and individual postings.
- Supporting evidence: each posting can be connected to its voucher or other documentation.
- Corrections: the original record and change history remain visible rather than being silently overwritten.
- Security and backup: access is controlled, backups meet the applicable requirements and restoration works.
- Automation: the required structured invoice, bank-reconciliation and data-export functions are available.
The non-registered-system rules include a full backup at least weekly when new entries have been recorded, held with a non-related party on a server in the EU/EEA. Ask for evidence of the arrangement and test restoration of both ledger data and documents.
Structured electronic invoices are different from PDF invoices sent by email. Test the prescribed formats and channels. System capability and an obligation to use e-invoicing for a particular transaction are separate questions; public-sector, contractual and future requirements can also matter.
The system must support the required data export, currently the Danish SAF-T format. A PDF ledger or ordinary spreadsheet export is not the same file. Run a sample export and confirm that finance can identify and explain the Danish records.
5. Keep documents, procedures and access usable
The digital duty includes recording transactions and storing the covered supporting documents. Identify which purchase and sales vouchers fall within the detailed rules, how they enter the system and who resolves missing or unreadable files.
Bookkeeping records generally must remain safely available for five years from the end of the financial year concerned. Specific exceptions or other legal requirements can apply. A software change, provider change or business closure does not automatically end the retention obligation.
Before changing a system, agree:
- Which ledger, voucher and audit-history data will be exported.
- How opening and closing balances will be reconciled.
- Who retains the old records and for how long.
- Which users can retrieve readable evidence after the old contract ends.
- How an authority request will be handled.
Keep a practical written description of the bookkeeping process where required. Identify the responsible people, transaction recording, reconciliations, storage and retrieval. Update it when the operating setup changes; a generic template that does not match the system is weak evidence.
Data protection remains a separate responsibility. Review access and provider arrangements for records containing employee, customer or other personal information.
6. Use a practical implementation plan
A working setup needs finance, IT, headquarters and the provider to agree the same scope. Use a short implementation plan with evidence at each stage.
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| Stage | Main task | Completion evidence |
|---|---|---|
| Scope | Confirm entity/activity, applicable route and first covered year | Written scope conclusion |
| System decision | Select registered system or validate the non-registered setup | Registration check or requirements mapping |
| Configuration | Define ledger, documents, access, interfaces and controls | Configured workflows and responsibility list |
| Migration and testing | Reconcile balances; test a sale, purchase, correction, backup and export | Test results and resolved exceptions |
| Operation | Start the recurring close and monitor missing items | Approved procedure and first reconciliation |
For example, a foreign-owned ApS keeping its group ERP should test a Danish supplier invoice from receipt through posting, approval, VAT treatment, payment and document retrieval. Repeat with a credit note and a correction. This reveals practical gaps that a vendor feature list may miss.
Tie the process to Danish VAT returns: the figures reported should reconcile to the ledger and source documents. Digital storage alone does not make a return correct.
7. Keep the setup under review
Assign an owner for system changes, new modules, provider notices and regulatory updates. Retest the Danish requirements after a material ERP change rather than assuming the original review covers every later configuration.
If bookkeeping is outsourced, agree who supplies documents, approves transactions, checks reports and retains access. The provider’s responsibilities and the company’s information duties should both be explicit.
Need help assessing the current workflow? Contact NordicEstab with the Danish registration, financial year, accounting system, document archive and provider arrangements. We can discuss the bookkeeping setup and the work needed to support a reliable close.
This guide provides general information. Scope and system requirements depend on the actual operation and configuration. Official guidance checked on 9 October 2026.