Order on Reporting and Publication of Annual Reports etc. in the Danish Business Authority for Companies Subject to Accounting Rules for Financial Undertakings

Order on Reporting and Publication of Annual Reports etc. in the Danish Business Authority for Companies Subject to Accounting Rules for Financial Undertakings etc.1)

Pursuant to Section 195, subsection 4, Section 195a, subsection 4, and Section 373, subsection 4, of the Act on Financial Business, cf. Consolidation Act No. 650 of 9 June 2025, Section 94, subsection 3, and Section 190, subsection 6, of the Act on Investment Funds etc., cf. Consolidation Act No. 1163 of 13 November 2024, Section 70, subsection 3, and Section 117, subsection 9, of the Act on Company Pension Funds, cf. Consolidation Act No. 183 of 26 February 2024, Section 131, subsection 6, and Section 190, subsection 5, of the Act on Managers of Alternative Investment Funds etc., cf. Consolidation Act No. 231 of 1 March 2024, Section 156, subsection 4, Section 156a, subsection 4, and Section 270, subsection 1, of the Act on Fund Brokers and Investment Services and Activities, cf. Consolidation Act No. 232 of 1 March 2024, as amended by Act No. 480 of 22 May 2024, and Section 189, subsection 4, Section 189a, subsection 4, and Section 316, subsection 1, of the Act on Insurance Business, cf. Consolidation Act No. 169 of 16 February 2025, it is hereby prescribed after consultation with the Danish Business Authority:

Scope of Application

Section 1. This Order applies to the following undertakings:

1. Financial undertakings, cf. Section 5, subsection 1, no. 1, of the Act on Financial Business.
2. Financial holding companies, cf. Section 5, subsection 1, no. 9, of the Act on Financial Business and Section 9, subsection 1, no. 9, of the Act on Insurance Business.
3. Insurance companies, cf. Section 9, subsection 1, no. 1, of the Act on Insurance Business.
4. Insurance holding companies, cf. Section 9, subsection 1, no. 10, of the Act on Insurance Business.
5. Fund broker companies, cf. Section 13, subsection 2, of the Act on Fund Brokers and Investment Services and Activities.
6. Fund broker holding companies, cf. Section 10, no. 20, of the Act on Fund Brokers and Investment Services and Activities.
7. Managers of alternative investment funds with registered domicile in Denmark that are not self-managed and have permission to manage alternative investment funds, cf. the Act on Managers of Alternative Investment Funds etc.
8. Danish UCITS covered by the Act on Investment Funds etc.
9. Company pension funds covered by the Act on Company Pension Funds.
10. A ship financing institute covered by the Act on a Ship Financing Institute.
11. The Association of Municipal and Regional Mortgage Credit Institutions in Denmark, cf. the Act on the Association of Municipal and Regional Mortgage Credit Institutions in Denmark.

Subsection 2. Notwithstanding subsection 1, no. 8, this Order does not apply to securities funds.

Section 2. The following accounting documents shall be reported to the Danish Business Authority:

1. The audited annual report as approved by the company’s general meeting or representative body.
2. Half-year reports, if the company is obliged to prepare half-year reports.
3. Sustainability reports for subsidiaries and branches of third-country undertakings that must prepare a sustainability report on behalf of the ultimate parent undertaking or a foreign undertaking not subject to the legislation of an EU/EEA country, and relevant declarations, cf. Sections 177 and 178 of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. or Sections 170 and 171 of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds.
4. Voluntarily prepared consolidated sustainability reporting, where a subsidiary is subject to sustainability reporting requirements but applies the exemption in Section 160, subsections 8-10, of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. or Section 150, subsections 8-10, of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds.

Subsection 2. The following accounting documents may be reported to the Danish Business Authority in accordance with the rules of this Order:

1. Half-year reports that the company voluntarily prepares and publishes.
2. Quarterly reports that the company voluntarily prepares and publishes.

Subsection 3. Voluntarily prepared consolidated sustainability reporting, where a subsidiary is subject to sustainability reporting requirements, cf. subsection 1, no. 4, shall be reported by the subsidiary, provided that the parent undertaking is not subject to this Order.

Subsection 4. The person responsible for reporting the accounting documents mentioned in subsections 1-3 is referred to as the "reporter" in this Order.

Digital Reporting

Section 3. Accounting documents as mentioned in Section 2 shall be reported as a searchable PDF file to the Danish Business Authority via the digital reporting solution "Regnskab Special" (Accounting Special), which must be accessed via the website currently provided by the Danish Business Authority for digital reporting of accounting documents, cf. however subsections 2-8.

Subsection 2. Companies that issue transferable securities admitted to trading on a regulated market in the EU/EEA shall prepare and report the annual report in accordance with subsections 7 and 8. However, tagging of consolidated accounts prepared in accordance with international accounting standards, IFRS, shall only be required. The companies mentioned in the first sentence may voluntarily tag the entire annual report. When tagging the annual report, the company must use both the Danish Financial Supervisory Authority’s taxonomy, cf. subsection 9, and the ESEF taxonomy, published by the European Securities and Markets Authority (ESMA) and accessible via ESMA’s website.

Subsection 3. Companies that prepare sustainability reporting shall prepare and report the company’s annual report in accordance with subsections 7 and 8. When tagging the annual report, the company must use both the Danish Financial Supervisory Authority’s taxonomy, cf. subsection 9, and the currently applicable ESRS taxonomies, published by the European Securities and Markets Authority (ESMA) and accessible via ESMA’s website.

Subsection 4. Subsidiaries and branches of third-country undertakings not subject to the legislation of an EU/EEA country that must report a sustainability report, cf. Section 2, subsection 1, no. 3, shall report an Inline XBRL file, cf. subsections 7 and 8, and use the currently applicable ESRS taxonomy for the European Sustainability Reporting Standards, published by the European Securities and Markets Authority (ESMA) and accessible via ESMA’s website.

Subsection 5. Subsidiaries that are subject to sustainability reporting requirements but apply the exemption in Section 160, subsections 8-10, of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. or Section 150, subsections 8-10, of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds, and are part of a group where the parent undertaking voluntarily prepares consolidated sustainability reports, shall report the parent undertaking’s voluntarily prepared consolidated sustainability reporting as a separate document, cf. Section 2, subsection 1, no. 4, in an Inline XBRL file, and use the currently applicable ESRS taxonomy for the European Sustainability Reporting Standards, published by the European Securities and Markets Authority (ESMA) and accessible via ESMA’s website.

Subsection 6. Companies reporting in accordance with Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council shall prepare and report the annual report in accordance with subsections 7 and 8. When tagging the annual report, the company must use both the Danish Financial Supervisory Authority’s taxonomy, cf. subsection 9, and the Article 8 taxonomy, published by the European Securities and Markets Authority (ESMA) and accessible via ESMA’s website.

Subsection 7. Companies preparing accounting documents as mentioned in subsections 2, 3, 4, 5, or 6 shall prepare and report the annual reports in xHTML format. If tagging is required, this shall be done in XBRL. The annual reports shall be tagged using both the relevant taxonomies mentioned in subsections 2, 3, 4, 5, or 6 and using XBRL format specification 2.1 and Inline XBRL format specification 1.1 in a taxonomy designated by the Danish Financial Supervisory Authority, cf. subsection 9.

Subsection 8. The annual reports shall be reported to the Danish Business Authority via the digital reporting solution "Regnskab Special" (Accounting Special), which must be accessed via the website currently provided by the Danish Business Authority for digital reporting of accounting documents.

Subsection 9. The Danish Financial Supervisory Authority’s taxonomy is designated on the Danish Financial Supervisory Authority’s website www.finanstilsynet.dk/ansoeg-og-indberet/indberetning-til-erhvervsstyrelsen.

Section 4. When an accounting document is received by the Danish Business Authority, the Danish Business Authority automatically sends a digitally generated receipt to the reporter. The receipt is sent to the email address provided by the reporter in connection with the reporting of the relevant accounting document. The Danish Business Authority automatically forwards the receipt to the Danish Financial Supervisory Authority.

Subsection 2. The Danish Business Authority publishes the reported files, cf. Section 3, to provide accounting users with access to the accounting documents via the website currently used by the Danish Business Authority for the publication of accounting documents.

Subsection 3. In the Danish Financial Supervisory Authority’s control of annual reports, both the PDF file and the Inline XBRL file, as well as the contained xHTML and XBRL files and other relevant information, are used, as appropriate.

Subsection 4. If the information mentioned in nos. 1-4 is contained in the reported accounting documents, the Danish Business Authority shall forward the accounting documents to the European Single Access Point (ESAP), established in accordance with the Regulation of the European Parliament and of the Council on the establishment of a European Single Access Point, which provides centralized access to publicly available information relevant to financial services, capital markets, and sustainability. The following information shall be forwarded to the European Single Access Point (ESAP):

1. Information on annual reports and annual management reports for labour market-related pension funds, as referred to in the Company Pension Funds Act.
2. Information on annual reports for each financial year and half-year reports covering the first six months of the financial year for investment management companies, as referred to in the Act on Financial Business, and UCITS, as referred to in the Act on Investment Funds.
3. If the company prepares sustainability reporting, consolidated sustainability reporting, or a sustainability report: a) The management report or the consolidated management report, including for both reports the information required in accordance with Article 8 of the Regulation of the European Parliament and of the Council on establishing a framework to facilitate sustainable investment. b) The annual report, including any consolidated accounts. c) The audit report. d) The sustainability reporting declaration, if the company prepares sustainability reporting. e) Sustainability reports regarding subsidiaries and branches of third-country undertakings that must prepare a sustainability report on behalf of the ultimate parent undertaking or a foreign undertaking not subject to the legislation of an EU/EEA country, and the accompanying sustainability reporting declaration, cf. Section 177, subsection 1, and Section 178, subsection 1, of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. and Section 170, subsection 1, and Section 171, subsection 1, of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds, if the company prepares sustainability reporting. f) Any declarations from subsidiaries and branches of third-country undertakings that must prepare a sustainability report on behalf of the ultimate parent undertaking or a foreign undertaking not subject to the legislation of an EU/EEA country, stating that the foreign undertaking or the ultimate parent undertaking has not complied with a request for necessary information for the preparation of a sustainability report, cf. Section 177, subsection 4, second sentence, and Section 178, subsection 5, second sentence, of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. and Section 170, subsection 3, and Section 171, subsection 3, of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds. g) Any report on payments to authorities or the consolidated report on payments to authorities, cf. Section 153 of the Order on Financial Reports for Credit Institutions and Fund Broker Companies etc. and Section 145 of the Order on Financial Reports for Insurance Companies and Cross-Border Pension Funds.
4. Information on the legal, managerial, and organizational structure of financial conglomerates as part of the annual report, as referred to in the Act on Financial Business and the Act on Insurance Business in cross-border pension funds, life insurance companies, and general insurance companies etc.

Section 5. If it is technically impossible to report digital accounts, the company may apply for an exemption from digital reporting to the Danish Business Authority to the Danish Financial Supervisory Authority, cf. subsection 2.

Subsection 2. The Danish Financial Supervisory Authority may only grant an exemption from digital reporting to the Danish Business Authority in cases of errors in the technical solutions that prevent the company’s digital reporting, where a solution cannot be found before the reporting deadline, or in cases where the digital reporting would significantly degrade the value of the accounting document for accounting users.

Tagging of Annual Reports with the Danish Financial Supervisory Authority’s Taxonomy

Section 6. Companies reporting with the Danish Financial Supervisory Authority’s taxonomy must use the taxonomy’s entry points, which are directed towards the type of company. Entry points and instructions will appear on the Danish Financial Supervisory Authority’s website www.finanstilsynet.dk/ansoeg-og-indberet/indberetning-til-erhvervsstyrelsen.

Subsection 2. Companies as mentioned in subsection 1 must separately tag the information relevant to the company, including:

1. The general information relevant to the company, including the company’s name, CVR number, financial period, comparison period, and date of the general meeting.
2. The independent auditor’s audit report, including conclusions.
3. Other declarations from the auditor or independent reporting assurance provider, if the accounting document contains such.
4. Key figures and ratios.
5. The income statement.
6. The balance sheet.
7. Changes in equity, if the accounting document contains such.
8. Capital classes, if the accounting document contains such.
9. Segment reporting, if the accounting document contains such.
10. The statement of comprehensive income, if the accounting document contains such.

Section 7. When reporting with the Danish Financial Supervisory Authority’s taxonomy, companies may in the structured part of the accounting document choose to include the following information in the accounting document collectively ("block tagging"):

1. Any management statement, cf. subsection 2.
2. Any management report or supplementary report, cf. subsection 3.
3. Note disclosures, including information on applied accounting policies, cf. subsection 4.

Subsection 2. Block tagging of the text sections of the management statement may be performed. The following information must, however, be separately tagged in XBRL, if relevant in the annual report:

1. The signatures of the responsible management members, including the date of signatures.
2. Information on any disagreement.

Subsection 3. Block tagging of the text sections of the management report may be performed, cf. however nos. 1-5:

1. If the management report or supplementary report contains a statement on corporate social responsibility, the statement must be separately tagged in XBRL at a minimum. If the management report contains a reference to a website where such a statement is published, information regarding this must be separately tagged in XBRL with the internet address to be used to access the statement directly or the page where all published statements are available.
2. If the management report or supplementary report contains a statement on corporate governance, the statement must be separately tagged in XBRL at a minimum. If the management report contains a reference to a website where such a statement is published, information regarding this must be separately tagged in XBRL with the internet address to be used to access the statement directly or the page where all published statements are available.
3. If the management report or supplementary report contains a report on payments to authorities, the report must be separately tagged in XBRL at a minimum. If the management report contains a reference to a website where such a report is published, information regarding this must be separately tagged in XBRL with the internet address to be used to access the report directly or the page where all published reports are available.
4. If the management report contains a statement on the company’s diversity policy, the statement must be separately tagged in XBRL at a minimum. If the management report contains a reference to a website where such a statement is published, information regarding this must be separately tagged in XBRL with the internet address to be used to access the statement directly or the page where all published statements are available. If the statement on the company’s diversity policy is given in connection with the statement on targets and policies regarding the underrepresented sex in the company’s management, this must be stated, and this statement must be separately tagged.
5. If the management report contains a statement on the company’s data ethics policy, the statement must be separately tagged in XBRL at a minimum. If the management report contains a reference to a website where such a statement is published, information regarding this must be separately tagged in XBRL with the internet address to be used to access the statement directly or the page where all published statements are available.

Subsection 4. Block tagging of note disclosures must be performed at the note level. However, separate tagging in XBRL must be performed for:

1. Information on which legislation the report is prepared under.
2. Information on changes in applied accounting policies.
3. Information on the average number of employees, if the notes contain such information.

Section 8. Unless otherwise stated in this Order, information in the part of the accounting document that can be opened and presented to a user ("the readable part") must correspond to the information reported in the XBRL-tagged part ("the structured part") of the accounting document, cf. however subsections 2-4.

Subsection 2. In the readable part of the accounting document, the accounting document may, within the framework of the accounting rules in the financial sector, be presented with other more specific designations than in the structured part of the accounting document, and may contain e.g. logos, images, and graphs.

Subsection 3. If the company reports the same information with multiple values ("renderings") in the readable part of the accounting document, e.g. in connection with rounding, the company must, in the structured part of the accounting document, choose which value is valid as the reported value. The values not selected as the reported value must be separately tagged as other values ("other rendering of reported value").

Subsection 4. A company tagging in accordance with guidelines established in EU law or corresponding international standards may, notwithstanding subsection 1, except for information mentioned in Section 6, subsection 2, omit tagging the information in the Danish Financial Supervisory Authority’s taxonomy.

Section 9. If a company’s annual report or consolidated accounts are prepared in accordance with Danish accounting rules established by or in accordance with legislation for financial undertakings, and contain a specific accounting item not found in the Danish Financial Supervisory Authority’s taxonomy, the company must report the accounting item under an accounting item with a broader designation that covers the relevant accounting item, and specify the accounting item in the notes.

Subsection 2. If no accounting item with a broader designation exists in the Danish Financial Supervisory Authority’s taxonomy that covers the relevant accounting item, the field must not be tagged in the structured part of the accounting document.

Subsection 3. Notwithstanding subsection 2, all accounting items must appear in the readable part of the accounting document.

Tagging of Annual Reports for Companies Subject to IFRS

Section 10. Companies that are obliged to prepare consolidated accounts in accordance with international accounting standards (IFRS) and must report accounting documents, cf. Section 3, subsection 2, must use the specific entry point for this in the Danish Financial Supervisory Authority’s taxonomy when reporting the annual report, "IFRS excluding financial statements".

Subsection 2. When using the specific entry point mentioned in subsection 1, the financial parts of the annual report must be tagged with the ESEF taxonomy, cf. Section 3, subsection 2. The Danish Financial Supervisory Authority’s taxonomy must not be used for the tagging, cf. the first sentence.

Subsection 3. The structured part of the annual report must contain tagging with the Danish Financial Supervisory Authority’s taxonomy of the non-financial information relevant to the company, cf. Sections 6 and 7.

Section 11. Companies that prepare consolidated accounts in accordance with IFRS and must report accounting documents, cf. Section 3, subsection 2, and where the parent undertaking prepares accounts in accordance with Danish legislation, are exempt from reporting the parent undertaking’s annual report in the structured part of the annual report. The company must only report the consolidated accounts in the structured part of the annual report.

Subsection 2. Notwithstanding subsection 1, the parent undertaking’s annual report must appear in its entirety in the readable part of the annual report, which must also contain the parent undertaking’s annual report etc. and the consolidated accounts.

Descriptive Information

Section 12. The following information must clearly appear at the beginning of the readable part of an accounting document:

1. The document’s designation, cf. Section 2, subsections 1 and 2.
2. The company’s full name, CVR number, and domicile address.
3. The financial period.

Subsection 2. The date of approval of the annual report and the name of the chairman of the general meeting or the corresponding approval body must be reported to the Danish Business Authority as part of the annual report. If the annual report is reported in Inline XBRL, the information may instead be provided in connection with the reporting of the annual report.

Section 13. It must appear from the accounting document who has prepared, approved, and confirmed the accounting document, with the names and functions of the relevant persons.

1. The Order contains provisions that implement parts of Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU as regards corporate sustainability reporting, OJ 2022, No L 322, page 15, and parts of Directive (EU) 2023/2864 of the European Parliament and of the Council of 13 December 2023 amending certain Directives as regards the establishment of the common European access point and its functioning, OJ L of 20 December 2023.

Official Gazette A 2025 Published on 28 June 2025 27 June 2025. No. 917. Ministry of Industry, Business and Financial Affairs, Danish Financial Supervisory Authority, file no. 24-010632 CQ003272