Bookkeeping description: Your §6 obligation in 10 steps (with template)
§6 of the Bogforingslov requires every bookkeeping-obligated company to have a written bookkeeping description — a document detailing how receipts, chart of accounts, periodization, and reconciliations are handled. It is neither a chart of accounts nor an e-conomic screenshot. It is a standalone PDF document SKAT can demand on 24 hours' notice. Here are 10 concrete steps to create one that both holds up at audit and can be billed as advisory work.
Steps 1-3: Identity, chart of accounts, periodization
Step 1 — Company identity: CVR, address, fiscal year, accounting class, and accounting standard (§ from the annual accounts act). About one page, but SKAT uses it to frame the rest.
Step 2 — Chart of accounts structure: which chart is used, who owns it, how often it is reviewed. Add a top-account overview and a brief justification for chosen sub-accounts. If the client uses e-conomic, cite the specific dimensions.
Step 3 — Periodization: which entries are periodized monthly, quarterly, or annually. Most common: rent, subscriptions, accountant fees, depreciation, and prepaid insurance.
Steps 4-6: Receipts, approval, retention
Step 4 — Receipt handling: where receipts are received (email, app, physical mail), who enters them, which bookkeeping system is used, and how a receipt is linked to a posting. Also describe the OCR solution if one is used.
Step 5 — Approval flow: who approves purchase invoices, who approves sales invoices, how many amount thresholds exist (typically under DKK 5,000, 5,000-50,000, over 50,000). Describe two-factor approvals where relevant.
Step 6 — Retention: where digital receipts are stored (cloud vendor and location), who has access, how backup is handled, and how recovery is documented at vendor switch. Remember 5-year retention per §13.
Steps 7-9: Reconciliations, VAT, inventory
Step 7 — Reconciliations: which accounts are reconciled monthly (bank, debtor, creditor, VAT), which quarterly, and which only at year-end. Describe the reviewer and where discrepancies are documented.
Step 8 — VAT: filing frequency (monthly / quarterly / semi-annually), who files, which method (invoice / cash), and how EU trade / imports are handled. If the company has partial VAT deduction, write the calculation method explicitly.
Step 9 — Inventory: if relevant, describe counting method (continuous vs periodic), valuation (FIFO / average), and frequency of physical counts.
Step 10: Version control and review cadence
Step 10 — Maintenance: who owns the document (typically CFO or external accountant), how often it is reviewed (annually at minimum or on material change), and how changes are documented. Use a version number and date — e.g. 'v2.3 — 2026-04-15 — receipt flow updated after Dinero-to-e-conomic switch'.
File the document in the same folder as the annual accounts, and password-lock it if it contains sensitive details about staff or two-factor routines.
How to bill the work
A thorough bookkeeping description for an SMB takes 4-6 hours to create and 1-2 hours of annual maintenance. It is a billable advisory engagement — not part of the regular audit fee. Describe the deliverable as '§6 bookkeeping description + annual review' and set a fixed package price (typically DKK 6,000-9,000 for creation, DKK 1,500-2,500 for annual review). Clients understand the value the moment you mention the SKAT fines for missing §6 documentation.
Ofte stillede sporgsmol
Does every bookkeeping-obligated company need a description?
Yes. §6 covers everyone with a bookkeeping obligation under the annual accounts act — regardless of size. Even a small ApS with one employee needs a written document describing the bookkeeping routines.
How detailed should the description be?
Detailed enough that an outsider (an accountant or a SKAT case worker) can understand the entire bookkeeping flow without further explanation. For an SMB, 4-8 pages is typically sufficient; for a larger company with multiple departments, up to 20 pages.
Can a chart of accounts or e-conomic template replace the description?
No. The chart of accounts is an input to the description, not a replacement. The description must explicitly document processes, responsibilities, approval flow, and reconciliation routines — things a chart of accounts cannot express.
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Step-by-step guide to creating a §6 bookkeeping description for Danish SMBs. What SKAT asks for, what to include, and how the accountant bills the work.
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