New Bookkeeping Act: Requirements set for customized bookkeeping systems

The decree on requirements for customized bookkeeping systems took effect on February 29, 2024. These requirements will be effective for fiscal years beginning on or after January 1, 2025. In short, this means that companies can choose to keep their books digitally in either:

• A digital standard bookkeeping system registered with the Danish Business Authority, or
• A customized bookkeeping system tailored specifically to your business 

If a company opts for a digital standard bookkeeping system, it must be one of the registered bookkeeping systems listed on the Danish Business Authority's registry of standard bookkeeping systems. Choosing a listed bookkeeping system ensures compliance with digital bookkeeping standards.

Read more about the registered bookkeeping systems and find the list here: Requirements for digital standard bookkeeping systems.

Requirements for customized bookkeeping systems

If a company chooses a bookkeeping system that is custom-built, such as C5 or NAV (all systems not listed in the registry of bookkeeping systems), it must ensure that the system meets the requirements for digital bookkeeping systems according to the Bookkeeping Act § 15. The requirements for customized bookkeeping systems are detailed in the Decree on Requirements for Companies' Digital Bookkeeping Systems Not Registered Under the Bookkeeping Act (in Danish).

The decree specifies that the specially developed bookkeeping system must include fields for entering the following information:

• Transaction date
• Amount
• Voucher number
• Transaction text
• Transaction day's exchange rate, if the registration is not in DKK

Additionally, the bookkeeping system must assign the following information to each recorded transaction:

• Registration date
• Sequential transaction number or ID
• Initials of the person or program that recorded the transaction

Furthermore, the system must meet the following requirements:

• The company must ensure the system logs all changes and prevents alteration, backdating, or deletion of recorded transactions.
  
  
• The digital bookkeeping system must be able to store documentation for a recorded transaction related to purchases or sales, containing the following information:
  • Issue date
  • Nature of the delivery
  • Amount
  • Sender and receiver; including name, address, and CVR number or SE number
  • The amount of VAT
  • Payment information

Please note that there are exceptions to the above requirements for, e.g., cash register slips. Read more in the decree (in Danish).

• The digital bookkeeping system is required to automatically backup all recorded transactions and vouchers at least once a week.
  
  
• The company must store the backup on a server in an EU or EEA country with a non-affiliated party that is presumed to meet recognized standards for IT security.
  
  
• The company must ensure that the digital bookkeeping system can automatically send and receive electronic invoices and credit notes via Nemhandel in OIOUBL format.
  
  
• The company must ensure that the digital bookkeeping system can automatically send and receive electronic invoices and credit notes in Peppol BIS format.
  
  
• The company must ensure that the digital bookkeeping system supports data sharing by making it possible to generate a SAF-T file.
  
  
• The company must ensure that the digital bookkeeping system supports reconciliation of the company's bookkeeping with the company's bank account and clearly highlights differences if a posting is not reconciled with the company's bank account.

In addition to the decree, the Danish Business Authority has created a short guide on how to comply with a number of the requirements for the customized bookkeeping system: Guide: How to Fulfill 5 Requirements for Your Bookkeeping System.

Advantages and disadvantages of customized bookkeeping systems

The advantage of using a customized  system is that it can be adjusted to exactly the needs for system support prevalent in your business.

The disadvantage or challenge can be that the requirements for the customized bookkeeping systems may affect the company's other systems, which may necessitate changes to internal procedures and systems in areas other than bookkeeping. In addition to the time it may take to adapt the customized bookkeeping systems, companies may also need to spend resources on adjusting related procedures and systems.

The requirements for customized bookkeeping systems will come into effect for fiscal years starting from January 1, 2025.

Want to know more?

Should you require guidance or advice regarding whether to change your bookkeeping system, system selection, or similar matters, feel free to reach out to your auditor.