SAP challenges for Danish subsidiaries in international corporations

The new bookkeeping regulations entail that Danish subsidiaries and branches using non-approved bookkeeping systems risk significant fines.

Overview of requirements for digital standard bookkeeping systems

New bookkeeping requirements

The new Bookkeeping Act mandates that companies in class B and above, including all public and private limited companies, must use an approved system or one that meets equivalent requirements. These rules take effect for financial years starting on or after January 1, 2025, for companies with their own bookkeeping systems. For Danish branches of foreign companies, the regulations apply from 2026.

Challenges with SAP

Many international corporations use SAP for bookkeeping. Danish subsidiaries in these corporations now face the challenge that SAP has not yet been recognized as an approved bookkeeping system by the Danish Business Authority. However, the system can be used if it meets the requirements for an approved bookkeeping system.

Requirements for bookkeeping systems

To be approved, a bookkeeping system must be able to handle:

Transaction data, voucher numbers, and initials of the person recording the transaction.

• E-invoices: Must be able to send and receive in both OIOUBL and Peppol BIS formats.
• IT security: Must meet recognized standards for IT security.
• Bank reconciliation: Must be able to perform bank reconciliation and difference control, potentially in Excel.
• Digital document archive: Must have a digital archive for B2B invoices with a clear transaction and control trail.
• Backup: Weekly backups must be taken and stored with a third party.
• Data export: Must be able to export data in SAF-T format for sharing with public authorities.
• Bookkeeping procedure: Must have a description of the bookkeeping procedure, and it must be documented that the system complies with the new Bookkeeping Act.

These requirements apply to all companies using non-approved systems, such as C5 and NAV, and not only SAP users.

Consequences of non-compliance

Failure to comply with the rules can result in substantial fines, depending on the company's revenue:

• Revenue of 10-100 million DKK: Minor violations can result in fines between 25,000 DKK and 100,000 DKK.
• Serious violations: Fines can reach up to 1 million DKK for this revenue group.
• Larger companies: Risk even higher fines.

Do you need advice?

If you want to ensure your bookkeeping system meets the new requirements or need help transitioning to a cloud solution, feel free to contact digitalization consultant Rikke Andersen Hviid at +45 32 42 83 06 / Rikke.Hviid@dk.gt.com.