Danish Bookkeeping Act 2026: Everything You Need to Know
The Danish Bookkeeping Act has been rolling out in phases, and the final major wave hits on 1 January 2026: the requirement for a digital bookkeeping system for sole proprietorships with net revenue exceeding DKK 300,000. Here is everything you need to know about the new requirements.
Trap 1: Receipts without machine-readable format
§10(1) requires the bookkeeping system to export receipt data in a machine-readable format — in practice SAF-T or an equivalent open standard. We still see clients whose system only delivers PDF receipts without the underlying JSON or XML.
The consequence at a SKAT audit: the accountant spends 3-5 extra hours manually reconstructing data from PDFs. The fee rises, the client gets annoyed, and if the deadline is missed, a fine under §137 follows (up to DKK 10,000 first offence, then daily fines).
Verify today: open the client's system and request a SAF-T export for last quarter. If the system can't do it, the client has a real §10 problem — regardless of vendor marketing.
Trap 2: Missing §6 bookkeeping description
§6 requires a written bookkeeping description documenting routines for receipts, chart of accounts, periodization, inventory, and reconciliations. Many clients believe a chart of accounts or an e-conomic template covers it — it doesn't.
SKAT explicitly asks for the §6 document at audits and during routine compliance checks. If it's missing, the company moves into the higher risk category, and next year's audit intensifies.
Verify today: ask the client for the PDF of their bookkeeping description. If it doesn't exist, book the time to create one — it's a billable engagement (typically 4-6 hours for an SMB).
Trap 3: 5-year retention in the client's local system
§13 requires 5-year retention of receipts, bookkeeping material, and the digital bookkeeping system itself. When the client switches accounting vendor, the accountant is asked to ensure continuity.
We regularly see clients who switched from Dinero to e-conomic without an export — the old data sits on an expired account, the client forgot the login, and the vendor purged after 6 months of inactivity. The accountant gets blamed at the next SKAT audit.
Verify today: ask the client to drop a SAF-T or CSV export from every prior system into a shared folder. Mark the export date as the receipt date in the bookkeeping description.
Trap 4: PDF receipts without underlying OCR data
§10(2) specifies that digital receipts must be readable and searchable digitally. A scanned PDF without OCR (optical character recognition) does not formally meet the requirement — even though many clients think it does.
Consequence: when SKAT asks to see 'every invoice above DKK 50,000 from supplier X in Q3', the accountant burns hours on a manual PDF review. With SAF-T filtering, the same query takes 30 seconds.
Verify today: open 5 random receipts in the client's system and try to copy-paste the text. If you get an empty clipboard or a string of garbage characters, the receipts aren't OCR'd and need to be re-exported.
Trap 5: No audit trail for adjustments and corrections
§10(3) requires every change in bookkeeping to be traceable — i.e. timestamp, user identity, before/after values. If the client's system doesn't log this, the accountant has no way to prove that a correction was made in good faith.
We have seen multiple cases where the client backdated a posting to adjust a VAT deduction — without an audit trail. Result: SKAT suspects deliberate manipulation, and the company ends up in a prolonged investigation.
Verify today: ask the vendor to confirm in writing that the system logs every posting with timestamp and user identity. Save that email — it's your documentation toward SKAT if the question ever comes up.
Conclusion: Spend 2-3 hours per client in Q2 on a compliance screening
Bogforingsloven 2026 is not a theoretical exercise — it hits your workday when SKAT visits or the client switches systems. The five traps above are the ones we see most often, but they are also the easiest to close proactively: a 2-3 hour compliance screening per client in Q2 typically saves 8-12 hours of reactive firefighting later in the year.
Bill it as a separate compliance check. Clients understand the value once you explain the fine levels, and you simultaneously have a documented §6 routine that meets the auditor independence standard.
Ofte stillede sporgsmol
Which companies are covered from 2026?
Every ApS, A/S, I/S, K/S, and sole proprietor with revenue above DKK 300,000 in two consecutive years. Foundations and associations are also covered if they have bookkeeping obligations under the annual accounts act.
How big is the fine for §10 non-compliance?
First offence: up to DKK 10,000. Repeat or serious violations can trigger daily fines and move the company into the Danish Business Authority's high-risk category, which means intensified audits the following years. Personal criminal liability for management is possible in cases of deliberate manipulation.
Do e-conomic, Dinero, and Billy count as §10-compliant?
Yes, but only on their newest tiers. Some legacy packages (typically pre-2024 subscriptions) don't support full SAF-T export. Always ask the vendor for written confirmation that the client's specific subscription meets §10(1)-(3).
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Complete guide to the Danish Bookkeeping Act 2026: digital requirements, SAF-T, document handling and 5-year retention for sole proprietorships.
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