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Electronic Sales Registration Systems – Denmark

As of 1 January 2024, §63 of the VAT Ordinance on Digital Sales Registration Systems (“Digitale salgsregistreringssystemer“) will come into force in Denmark. From this date, “digital sales registration systems” (electronic recording systems, cash registers, etc.) must fulfil certain requirements. Among other things, sales transactions must be digitally signed with a Danish OCES certificate. This certificate must be issued to the respective retailer or caterer.

Who is affected?

In the first step, the requirements apply to all companies with an annual turnover of less than 10 million Danish kroner (approx. EUR 1.3 million) that are active in the following sectors:

  • Cafes, pubs, nightclubs etc.
  • Pizzerias, fast food bars, ice cream parlours etc.
  • Grocery stores and 24-hour convenience stores
  • Restaurants

15 Requirements

The Danish Tax Agency has published 15 technical requirements for sales registration systems, which describe, among other things, the keeping of an electronic journal and the provision of data in the form of a signed SAF-T export.

We would like to draw special attention to some of these requirements:

  • As of Jan. 1st 2024, POS systems in Denmark that are used in the above-mentioned sectors and thus fall under §63 of the VAT Ordinance must have a connection to payment terminals (if bank card/debit card or credit card payments are accepted). Non-connected / non implemented payment terminals are therefore no longer permitted.
  • The recording system (electronic sales registration system) must not have a function for subsequently changing or deleting data in the electronic journal.

Types of sales

In addition to traditional cash sales, sales transactions that are settled using electronic means of payment such as payment cards or MobilePay must also be processed via the digital sales registration system.

Online sales

Payments made in the course of online sales, both via the company’s own website and via online portals (e.g. Just Eat, Foodora, etc.), must also be recorded in the sales registration system.

Fines

The tax authorities have announced penalties for non-compliance with the regulations. From Jan. 1st 2024, the tax authorities can carry out so-called compliance checks. The penalties are increased each time the financial authorities visit.

Following an update in the summer of this year, the Danish Tax Agency has now published a new version of the technical requirements for digital sales registration systems at the beginning of November. RetailForce will provide a new version of the Fiskal middleware that implements these changes in good time.

Please contact us if you have any questions about Danish fiscalisation.