In 2019, the Danish VAT Regulation was extended to include requirements for so-called "digital sales registration systems".

These requirements are listed below (with reference to the relevant paragraphs or sections).

Digital sales registration systems

§ 62 a. Digital sales registration systems must meet the following requirements:

1. all actions via sales registration systems must be registered (logged) in the system's electronic journal. Transaction data in the electronic journal must be digitally signed with a Danish OCES certificate issued to the trader so that the integrity of the data in the electronic journal can be verified in connection with the control.

2. the electronic record must contain the information that must also be included on a simplified invoice or receipt to the customer, cf. section 63. for each transaction, the electronic record must also contain:

  a. The time of the start of the purchase and the end / interruption.

  b. A sequential transaction number that must be unique to the merchant (per CVR number).

  c. The payment method used / The means of payment used.

  d. The serial number of the digital sales registration system.

3. The sales registration system must be able to generate a file in SAF-T format directly from the electronic journal. The Tax Administration is preparing a Danish guide on the use of the SAF-T format.

4. The file from the electronic journal must be readable on publicly accessible electronic media or otherwise be able to be transmitted digitally to the authorities upon request.

5. The sales registration system must be able to generate a report with the daily turnover which resets the sales counters etc. after registration in the electronic journal. (Z-report).

6. The sales registration system must be able to generate a report with sales up to formation without resetting sales counters, etc. (X report).

7. Digital means of payment such as payment cards, mobile payment, etc. must be connected to the revenue recognition system in such a way that payment with digital means of payment is automatically recorded in the digital revenue recognition system.

8. The sales registration system must be able to register separate totals for the means of payment used, i.e. totals for cash payment, card payment, mobile payment, etc.

9. There must be a built-in clock and date set in relation to Danish Standard Time. All adjustments to the time indication in the system must be registered in the electronic journal.

10. A printer function must be assigned, e.g. for printing simplified invoices or till receipts, cf. § 63, if the trader cannot send the till receipt digitally to a system that the customer has accepted in advance.

11. On request, it must be possible to print a receipt that clearly distinguishes between positive and negative amounts. The requirement shall also be deemed to be met if the sales registration system can send the receipt digitally to a system that the customer has accepted in advance.

12. Sales registration systems to be used by multiple sellers must be able to record transactions and totals for each seller separately, including the volume of sales and the type of payment method.

13. Training and similar records without turnover must result in cash vouchers clearly marked with e.g. "audit not valid" or "training - not valid" and such vouchers must not be confused with normal vouchers.

14. If a business receives cash, cf. section 81, subsection 1 of the Payments Act, the sales registration system must be equipped with:

  a. A cash drawer for storing cash.

  b. Possibility to store/manage change (stock of coin and banknote types).

Stk. 2. The digital sales registration system shall not contain any functions that allow the addition, editing or deletion of information.

Stk. 3. The digital sales registration system shall not be capable of being connected to or integrated with software or hardware that allows the addition, editing or deletion of information in the electronic journal.

§ 2 

The Implementing Regulation shall enter into force on 1 July 2021.

Important requirements in detail

Recording of all "actions" (point 1.)

In addition to data on sales transactions ("receipts"), all actions of the "sales registration system" (cash register) must be recorded. This means that in Denmark,

1. all document types should be transferred to the RetailForce system if possible and
2. a technical journal must be kept that records defined events. General information on this can be found in the article "Technical event log"; which cash register events must be recorded in Denmark is described in the article "Event code mapping".

Recording of electronic payments (point 7.)

All digital means of payment such as payment cards, MobilePay, etc. must be connected to the sales registration system in such a way that payment with digital means of payment is automatically registered in the digital sales registration system.

Card and payment terminals must be integrated with the cash register (the digital sales registration system). The reference ID of the payment must be transferred from the payment terminal to the cash register.

Online-Sales

Online sales must be registered/recorded in the sales registration system in the same way as sales made through in-store orders. This applies to sales via your own website and sales via online portals such as "Just Eat", "Foodora", "OrderYo-Yo", etc.

Please note:

• If the payment is made directly to the company via online payment (e.g. MobilePay, credit card, ApplePay), the payment must be automatically registered in the digital sales registration system.
• If the payment is made to a third party in connection with the order (e.g. "JustEat", "Foodora", "OrderYoYo", etc.), the payment must be registered in the digital sales registration system in the same way as a cash payment. This can be done, for example, with a key in the sales registration system that indicates that the payment was made via a third party, e.g. "Just Eat", "Foodora", "OrderYoYo", etc.

Retention of data

Data must be available for a period of at least five years from the end of the financial year in question.

There is no specific requirement for storage, except that data must be stored and accessible for at least 5 years.

Sources

• Ordinance amending the Value Added Tax Ordinance: https://www.retsinformation.dk/eli/lta/2020/1507
• FAQ - Frequently asked questions provided on 15/11/2023 by the Danish Tax Agency.