New requirements for electronic sales registration systems for certain sectors in 2024
From 1 January 2024, businesses within specific sectors (see below) with annual turnover of less than DKK 10 million are required to use an electronic sales registration system. The system must comply with certain new statutory requirements, as stated in the Danish VAT Order.
The new electronic sales registration requirements may mean that your business must either update its electronic sales registration system with new software or acquire a completely new electronic sales registration system.
Who needs to meet the new requirements?
The rules apply to anyone who runs a business in one of the following four sectors with annual turnover of less than DKK 10 million:
- Cafes, pubs, nightclubs etc.
- Pizzerias, fast food bars, ice cream parlours etc.
- Grocery stores and 24-hour convenience stores
- Restaurants
The new statutory requirements for electronic sales registration systems are intended to ensure a sufficiently documented data basis for businesses’ sales registration.
We see that some suppliers state on their website that their sales registration systems are approved by the Tax Agency. This is not correct.
We don't offer to test suppliers’ electronic sales registration systems, and therefore don't approve the individual suppliers’ electronic sales registration systems.
We therefore can't help you to find out which electronic sales registration systems meet the new requirements.
But we expect that by the end of 2023 it will be possible for suppliers of electronic sales registration systems to document that they comply with the requirements of the VAT Order by having an ISAE 3402 audit declaration prepared on the basis of a template from the Tax Agency.
Do I need to replace or update my current sales registration system?
If you, as a business operator, are in doubt as to whether your current electronic sales registration system meets the new requirements or will meet them after a software update, you should contact the supplier of your electronic sales registration system to find out. The same applies if you find out that you need to get a new electronic sales registration system.
It is your own responsibility to ensure that by 1 January 2024 you have an electronic sales registration system that meets the new requirements.
You should therefore remember to ask your current or new supplier about the system’s technical specifications to ensure that you do not keep or invest in a solution that doesn't meet the statutory requirements.
Below, we have compiled a list of the 15 technical requirements that your electronic sales registration system must meet in order to comply with the new statutory requirements that apply as from 1 January 2024.
If you can answer yes to all 15 of the following questions about your electronic sales system, you can be certain that your electronic sales registration system meets the new statutory requirements.
- Can the sales registration system log all actions in an electronic journal?
All actions via sales registration systems must be logged in the system’s electronic journal. Transaction data in the electronic journal must be signed electronically with an OCES certificate identifying the business operator or the provider of the electronic sales registration system, so that the integrity of the data in the electronic journal can be verified in connection with auditing.
- Does the electronic journal contain the same information as stated on the till receipt?
The electronic journal must hold the information that is also to be included on a simplified invoice or a till receipt to the customer.
For each transaction the electronic journal must also include:
a) Details of the business operator’s CVR number.
b) A consecutive transaction number that must be unique to the business operator (by CVR number).
c) Date and time of the commencement and completion/discontinuation of the purchase.
d) The means of payment used.
e) The serial number of the electronic sales registration system as the unique identifier of the sales registration system.
- Does the sales registration system have SAF-T as the default file format?
The sales registration system must be able to generate a file directly from the electronic journal in SAF-T format. The Danish Customs and Tax Administration has decided to use the OECD standard SAF-T (Standard Audit File – Tax) as the standard file format for reporting sales registration data to the Customs and Tax Administration.
- Can the file be transferred electronically or read out on commonly available electronic media?
The file from the electronic journal must be readable on generally available electronic media or otherwise available for electronic transfer to the authorities on request.
- Can the sales registration system generate a Z report?
The sales registration system must be able to generate a report with the day’s turnover that, after registration in the electronic journal, resets the sales counters etc. This is called a Z report.
- Can the sales registration system generate an X report?
The sales registration system must be able to generate a statement of turnover from the last time a Z report was generated. This statement is called an X report.
- Can the sales registration system automatically register payment using an electronic means of payment?
Electronic means of payment such as payment cards, mobile payment etc. must be connected to the sales registration system in such a way that payment using electronic means of payment is automatically recorded in the electronic sales registration system as part of the electronic journal.
- Can the sales registration system record sales by means of payment used?
The sales registration system must be able to record separate sales totals for each of the means of payment used, i.e. sales totals for cash payment, payment by card and mobile payment etc.
- Does the sales registration system have a built-in calendar and clock?
There must be a built-in clock and calendar adjusted to Danish standard time. All adjustments of time indications in the system must be recorded in the electronic journal.
- Does the sales registration system have an associated printer function?
There must be an associated printer function, including for printing simplified invoices or till receipts, if the business operator cannot send the till receipt electronically to a system accepted in advance by the customer.
- Can the sales registration system print a till receipt that distinguishes between positive and negative amounts?
It must be possible to print a till receipt on demand, on which positive and negative amounts are clearly distinguished from each other. The requirement will also be deemed to be fulfilled if the sales registration system can send the till receipt electronically to a system that the customer has agreed to in advance.
- Can the sales registration system record sales separately for each seller?
Sales registration systems intended for multiple sellers must be able to record transactions and totals separately for each seller, including the size of the sale and the type of payment.
- Can the sales registration system clearly mark on the till receipt whether it is a ‘test receipt’?
Training of new employees in the use of the sales registration system and similar registrations whereby no actual sale takes place must be able to generate till receipts that are clearly labelled, e.g. ‘Test not valid’ or ‘Training– not valid’, so that they cannot be mistaken for ordinary till receipts in any way.
- Does the sales registration system have a cash till for storing cash?
When a business receives cash, see section 81(1) of the Danish Payments Act, the sales registration system must be equipped with:
- A cash till.
- Option of a change register (list of coin and banknote types).
- Does the sales registration system have features that allow information to be added, edited or deleted in the electronic journal?
The electronic sales registration system may not have features that allow information to be added, edited or deleted. The electronic sales registration system may not be interconnected or integrated with software or hardware that makes it possible for information to be added, edited or deleted from the electronic journal.
Please note: If the electronic journal is held by a third party, the requirements set out in items 2-15 above must also be met.
Sales with electronic means of payment
All electronic means of payment such as payment cards, MobilePay etc. must be connected to the sales registration system in such a way that electronic means of payment is automatically recorded in the system.
Sales with cash payment
It is a statutory requirement that business operators also accept cash as a means of payment, and therefore cash payments will also have to be recorded in the electronic sales registration system.
Online sales via own website and online portals
Just like sales that take place directly on the business’ premises, online sales must be recorded in the sales registration system. This applies to sales via the business’ own website and sales via online portals such as Just Eat, Foodora etc. If the payment to the business is made using an electronic means of payment, this must be recorded automatically in the electronic sales registration system. If payment is made directly to the online portal, this must be recorded in the sales registration system as the means of payment used, in the same way as registration of cash payment.
As a business operator, you are required to obtain an OCES certificate (Public Certificate for Electronic Services). It must be used to generate an XML file from your electronic sales registration system on request, whereby the file must be signed electronically with an OCES certificate issued to you as a business operator. If data is stored by the supplier/third party, which submits the electronic file on your behalf, the supplier will sign the transaction data with their own OCES certificate.
It is your responsibility as a business operator to acquire an electronic sales registration system that meets the statutory requirements of the VAT Order. You may be fined if, during a compliance check at your premises after 1 January 2024, we find that the order to use an electronic sales registration system that meets the new requirements in the VAT Order is not complied with.
For each time that we perform a compliance check showing that a business does not fulfil the requirements of the electronic sales registration system, the amount of the fine will increase by DKK 10,000.
Fines
- First visit: DKK 10,000
- Second visit: DKK 20,000
- Third visit: DKK 30,000
The business may also be liable for daily fines that run until the requirements for the electronic sales registration system are met. Daily fines are a minimum of DKK 1,000 per day.
For further legal information in Danish see our legal guide .