Loan Reporting to Skat: Arrears, Guarantors and the 2026 Udlån File

On 30 September 2026 Skattestyrelsen published the Indberetningsvejledning om Udlån årsultimo 2026 (S nr. 113), the guide that governs loan reporting to Skat for calendar year 2026. Section 13 of the Danish Tax Reporting Act (skatteindberetningsloven) requires businesses within the Act’s territorial scope that grant or intermediate loans in the course of their business to report each year on every loan: the interest credited or due, the debt at 31 December, every borrower or qualifying guarantor, and markers for interest arrears and debt forgiveness. The statutory deadline for the 2026 year-end file is 20 January 2027.

The data goes straight onto citizens’ tax pages. Skattestyrelsen uses it for the tax information shown on skat.dk/tastselv, for the annual statements (årsopgørelser) it pre-fills, and for other authorities that calculate public benefits (guide section 0). Two fields carry outsized weight for the borrower: an arrears flag or a debt-forgiveness code stops the interest from being pre-printed on the annual statement, so a wrong flag leaves deductible interest for the borrower to enter manually.

Related reading: Deposit Reporting to Skat: The Indlån File Due 20 January 2027

Loan reporting to Skat: the 2026 calendar

• 30 September 2026: version 1.0 of the 2026 Udlån guide published.
• 5 October 2026 (Monday): reporting, test and validation for year-end 2026 open; the 2026 XML namespace is dated 01/01/2026 (guide section 0.1).
• 31 December 2026: reference date for the outstanding debt and for each borrower’s resident or non-resident status (guide sections 4.5.2 and 1.4.2).
• 31 December 2026: last day to report digitally for calendar year 2021; years 2020 and earlier can no longer be reported digitally (guide sections 0.1 and 2).
• 1 January 2027: from this date, customer-due-diligence updates under the Danish AML Act also trigger a TIN request for loans created before 1 July 2016 (guide section 1.4.1).
• 20 January 2027 (Wednesday): deadline for the year-end Udlån report and for a nil report (section 54(1) of the Act; guide sections 1.2.1 and 2).
• 14 days after Skattestyrelsen’s response: resubmission of rejected records, the deadline Skattestyrelsen sets under section 54(6) (guide sections 1.5 and 2).
• 1 March 2027: data reported after this date cannot with certainty reach the citizen’s annual statement automatically (guide section 2).
• Within 10 days of cessation: the report for the year a business stops (executive order section 5; guide section 2).

For a single report (enkeltindberetning) filed with errors, the 14 days run from the day it was filed (guide section 7.1).

Section 13 and the rest of the legal basis

The obligation sits in section 13 of skatteindberetningsloven, consolidated as lovbekendtgørelse nr. 1059 of 21 August 2025. Section 13(1) covers anyone who, as part of their business, grants or intermediates loans, and extends the same duty to late-payment interest fixed under the fees act (gebyrloven).

Section 13(2) asks for identification of each borrower or any guarantor, and its operative data items are the loan type, currency and grant date (with the end date for a closed loan), the interest credited or due, an arrears marker, a marker for debt forgiveness under section 5(9) of the Tax Assessment Act (ligningsloven), running commissions, and the debt at 31 December. The remaining items cover mortgage-credit features such as reserve-fund contributions.

Section 13(3) exempts bills of exchange and loans whose interest is not deductible under section 17 A of the Tax Assessment Act. Section 13(4) switches the duty off where a mortgage-deed custodian reporting under section 14 manages the payments on the loan. Section 47 places the duty on persons resident in Denmark or operating from a permanent establishment here.

The executive order on tax reporting, bekendtgørelse nr. 1016 of 22 June 2023, as amended, adds the detail. Its section 29 requires the loan currency as an ISO code, and section 4(4) requires amounts in Danish kroner. Where the guide departs from the legislation or Den juridiske vejledning, those prevail (guide section 0).

Section 54(1) gives the same 20 January deadline to a long list of returns under the Act, including deposits under section 12 and the cooperative return covered in our article on cooperative capital distributions to Skat under section 30.

Who files: lenders well beyond the banking sector

Section 1.1.1 of the guide applies the duty to all Danish financial institutions and other businesses that grant or intermediate loans as part of their activities. Three groups change the filing answer in practice.

The first is financial lenders: banks, savings banks, cooperative banks (andelskasser), finance companies and card issuers, the last including credit on petrol, store and membership cards (guide section 4.1). The second is commercial sellers that finance their own sales, with car, white goods and electronics dealers named as examples. The third is the public sector.

Municipalities report the loans they grant or intermediate and late-payment interest fixed under section 3 of the fees act, cited in the guide as lov nr. 468 of 17 May 2024, and regions report that interest; loans specifically exempted, such as loans for paying land tax (grundskyld), stay out. Energistyrelsen reports loans it grants, for instance to freeze energy bills.

Late-payment interest is where the public-sector perimeter gets narrow. Interest on unpaid utility invoices for water, gas or electricity charged under the Interest Act (renteloven) is outside the duty; the interest is deductible, but the citizen enters it on the annual statement. The same kind of interest charged by Energistyrelsen under section 3 of the fees act and collected by the debt-collection authorities is inside it (guide section 1.1.1).

Loan-based crowdfunding platforms approved by Finanstilsynet sit on both sides. The lender’s position is reported annually as a deposit under section 12, and the borrower’s position goes to Udlån, quarterly and annually, under sections 13 and 15 (guide section 1.1.1).

Registration, nil reports and deregistration

Section 1(1) of the executive order requires registration within eight days after the obligation begins, and the guide dates that start to the first loan agreement with a customer (guide section 1.3). Registration runs through form 03.047 on virk.dk, where the business also picks the gross or net interest principle for section 13; net interest is open only to banks (guide section 1.3.1). A business whose obligation pauses can stay registered and file a nil report instead (guide section 1.2.1). Deregistration is due within eight days after the obligation ends (guide section 1.3.3).

What counts as a loan, and what stays out of Udlån

The guide reads loan broadly. A loan granted as part of the lender’s business counts, and so does one intermediated in the course of business, credit granting, and the acquisition of credit rights in a loan (guide section 1.1.2). A loan relationship has to exist. Interest does not have to: a loan carrying negative interest, which is income for the borrower, remains a loan.

The guide’s non-examples show where the boundary runs. An unpaid invoice does not become a loan, even when the creditor grants a payment arrangement or a deferral. A debtor’s acknowledgement of an invoice debt, or a voluntary settlement, does not create a reportable loan either (guide section 1.1.2). On that reading, invoice receivables on instalment arrangements stay outside Udlån unless a loan relationship has been established.

Inside the perimeter, the guide’s starting point is every loan active during the calendar year (guide section 4.1). A loan redeemed, sold, time-barred or ended through debt restructuring during 2026 is still reported, with a debt of 0, the end date and the year’s interest. For banks the scope includes credit lines with variable drawing rights and the bank’s own holding of mortgage deeds. On an account that can be in credit or in debit, the 31 December balance decides between Udlån and Indlån.

Syndicated loans and mortgage deeds

Syndication splits the duty by who is the lender (guide section 4.1). In a true syndicate each bank lends directly to the borrower, so each reports its own share. In a participation syndicate the lead bank signs the loan and passes parts on to other banks, so the lead bank reports the whole loan; where that lead bank is foreign, no one has a duty to report the loan.

Mortgage deeds (pantebreve) move between sections 13 and 14. A business that lends against real property as part of its activities and manages the deeds itself reports under section 13 in Udlån, and professional buyers of deeds who manage their own purchases are treated the same way, since acquiring credit rights equals lending. Once a deed is deposited with a custodian for management, the obligation passes to the custodian under section 14 and goes into the separate Pantebreve report type (guide section 4.1).

Exempt borrowers and the documentation test

Section 51(1) of the Act excludes loans to tax-exempt institutions under section 3 of the Corporation Tax Act (selskabsskatteloven), state-recognised unemployment funds, banks, pension funds, mortgage credit institutions and insurers (guide section 4.1.1). The guide asks for documentation that a customer’s loans are exempt, and the financial firms must be under Finanstilsynet’s supervision, or their home supervisor’s if foreign (guide section 4.2.1).

For section 3 customers the 2026 guide makes documentation the test: with the customer’s registration certificate, or a Skattestyrelsen confirmation where the certificate is silent, the customer’s loans are not reported; without it, they are, whenever the loan was created. The evidence is collected at onboarding, and where it is missing because the guide gave no instruction to collect it before 2024, at the next customer contact (guide section 4.2.1).

The tax perimeter stands apart from supervisory loan data. Finanstilsynet’s KGFS return on new home loans to borrowers with a high debt factor (gældsfaktor) works from its own definitions, such as a loan-to-value test of more than 60 per cent and amounts in units of DKK 1,000, covered in our KGFS reporting guide; none of them decides whether a loan belongs in Udlån.

Borrowers, guarantors and the residence test

The guide asks for every borrower on the loan, because Skattestyrelsen divides interest, debt and customer-programme amounts equally between the borrowers reported (guide sections 4.2, 4.5 and 8). The executive order says the same in section 6(3), as rewritten by bekendtgørelse nr. 885 of 26 June 2024 with effect from calendar year 2025.

When the guarantor replaces the borrower

The Act lets the report name a guarantor (kautionist), and the guide explains why: the rule keeps reporting in line with the deduction rules, so where the guarantor carries the borrower’s obligations and is a person, the interest is pre-printed on the guarantor’s annual statement. Until Skattestyrelsen instructs otherwise, the guide limits that switch to three situations (guide section 4.2):

• one guarantor covers the borrower’s obligations on the loan in full;
• two or more guarantors cover them in full, jointly and severally;
• the borrowers are no longer liable, for example after public debt restructuring where the whole debt lapses, after the borrower’s death once the estate is closed, or after a corporate borrower ceases through bankruptcy.

Outside these three cases the borrower stays on the record. The 2026 text adds a clarification for guarantees that cover only the instalments: where the guarantors are not liable for the debt on the loan at 31 December, only for the payment under the guarantee agreement, the debt at 31 December goes in as zero, and the system accepts a zero debt without an end date (guide sections 0.1 and 4.2).

Resident or non-resident

The borrower’s status follows residence at 31 December 2026: resident in Denmark means indlænding, anything else valutaudlænding, and for a relationship that ended during the year the status at its end decides (guide section 1.4.2). Estates and bankruptcies administered in Denmark count as resident, and borrowers in Greenland are non-resident. Tax liability plays no part, and the guide notes that CRS and FATCA follow other rules, described for CRS in our CRS reporting guide.

A borrower with a CPR number whose country of residence is not known with certainty is reported as non-resident, with KontohaverIdentifikationMulig set to false and the CPR number filled in. A borrower without a fixed address, such as a homeless person, is reported as resident (guide section 1.4.2). Country code DK on a non-resident is allowed only for an emigrant whose new address is unknown, and otherwise fails with error 8 (guide section 4.7.2).

Identification, TIN and the companies-in-formation trap

Section 52(2), no. 6, of the Act bars establishing or taking over a loan under sections 13 or 15 until the borrower has given identification data. On my reading, “taken over” brings purchased loans within the bar alongside new lending. The data is name, address and CPR number, with fallbacks to CVR number, SE number and date of birth; borrowers abroad add a residence-country TIN or, without one, birth details (executive order section 3; guide section 1.4.1).

Both TIN sections are flagged as significant changes in the 2026 guide. When a customer moves abroad, the institution makes reasonable efforts to obtain the new country’s TIN. The guide also states that no transitional rules apply: from 1 January 2027, a customer-due-diligence update under the AML Act also triggers a TIN request for loans created before 1 July 2016 (guide section 1.4.1). On the reporting side, a TIN issued by the country of tax residence is accepted where the borrower has not given one under the residence country’s rules (guide section 1.4.2).

The guide lists companies in formation among its special error situations. A company receives a CVR number while in formation, but its effective date at the Danish Business Authority comes later, up to 12 months after the founding document is signed (guide section 1.4.1). Until then the founders are the borrowers. A loan granted before the effective date needs two account periods, founders first and the company’s CVR number from the effective date; a CVR number reported before its effective date fails with error 4 or error 54 (guide section 0.3).

One record per loan: identifiers, dates and account periods

The data structure is RenteIndberetningUdlånStruktur, delivered as XML, one report per loan, and the guide confirms there are no new fields this year (guide section 4.3). Three fields cannot be corrected once filed: the income year, VirksomhedSENummer and KontoID. VirksomhedSENummer is the CVR number of the reporting entity, and the guide defines the reporting entity as the owner of the claim (guide section 4.3.1). Quarterly and annual Udlån reports travel in separate files, and a year-end file carries none of the quarterly fields (guide section 4).

KontoID, account number and dates

KontoID is the audit trail. It follows the loan for its whole life, through a move into a collection system or a change of data provider, and changes only when the creditor changes (guide section 4.3.2). It holds at most 30 characters with no spaces or listed special characters, and loans created after 1 October 2021 must not carry a CPR number in it. Running sequence numbers are allowed in one case only: a jointly and severally liable loan in default where the borrowers’ legal obligations have come apart.

UdlånKontoNummer is the number the borrower sees in their tax information. The guide advises against using a CPR number there because of the GDPR risk, and asks that it not change for a KontoID during the year; a needed change should wait for the turn of the year, so the new number is first used in the first quarterly report (guide section 4.4).

KontoStartDato is the date the loan was created, and a buyer of a loan reports that original date, falling back to the takeover date if the original cannot be found; an unknown date goes in as 1900-01-01. KontoOphørDato is the end date, and for a sold loan it is the day the loan passes to the new creditor. Transactions booked after closure do not reopen the reporting (guide section 4.4).

Account periods and account types

Every report carries at least one account period, with a borrower list per period. A new period starts when the ownership circle changes, with borrowers joining or leaving, or when the account type changes within Udlån, such as a move from type 53 to type 56 (guide sections 4.6, 4.6.1 and 4.6.2). The interest across all periods has to add up to the loan’s interest for the year or the report is rejected.

The 2026 guide clarifies a change of ownership on 31 December: the loan then needs periods in both years, the outgoing borrower’s ending 31.12 in year one and the incoming borrower’s starting 01.01 in year two, both with the original start date (guide section 0.2).

The codes and effects come from guide sections 4.5.2 and 4.6.

Interest and debt: what the amount fields hold

RenteBeløb carries the total interest credited or due in the year, including running commissions or premiums for the loan or for securing the claim, and premiums for a guarantee of the customer’s debt (guide section 4.5.1). Default interest and interest triggered by an extraordinary repayment or redemption are reported, with default interest on late instalments reported in the year it is charged. Negative interest, which is income for the borrower, takes a minus sign. A loan with no interest is reported with 0, and a closed loan carries interest up to its end.

LånRestgældBeløb is the debt at 31 December, and future interest stays out of it (guide section 4.5.2). The guide’s example is annual interest falling due on 30 June: the interest accruing from 30 June to 31 December is left out of the year’s debt. Collection costs and court fees are separate claims outside the lender’s duty, although reminder fees charged before the claim goes to collection can be included. An accounting write-down on a distressed loan changes nothing in the file: the full debt is reported as long as the whole amount is claimed.

Amounts go in kroner, with øre only when above zero, and the guide’s own example writes DKK 1,125.50 as 1125,50 and accepts 1125 for DKK 1,125.00 (guide section 4.5). A loan in foreign currency converts at the daily rate when the right arose, and at the 31 December rate for the year-end value (executive order section 4(4)).

Overpayments, customer programmes and the gross or net split

The 2026 guide states that a credit balance arising because the debtor overpaid is not reported to Udlån, even if it is booked on the original loan account; the loan goes in with a debt of 0 and an end date in the year it was redeemed (guide sections 0.1 and 0.2).

Customer and member programme payments fall under section 19 a of the Act; in Udlån they go in KundeordningBeløb when taxable as capital income and not set off in the interest charge (guide section 4.5.3). A set-off amount is folded into RenteBeløb instead. The field carries the gross payment and appears only when there is an amount, since a 0 in an initial report fails with error 74; the amount is pre-printed in box 33 of the annual statement.

Banks also live with their registration choice between gross and net interest (guide section 4.5.1.1). In the guide’s third example, a salary account overdrawn during the year earns DKK 1,000 of credit interest, costs DKK 500 of debit interest and ends the year DKK 20,000 in credit. The gross principle produces two records, Indlån with 1,000 of interest and a 20,000 balance, and Udlån with 500 of interest and a debt of 0. Net reporting splits into two records only where interest and balance land on different account types; the deposit side is covered in our Indlån deposit reporting guide.

The arrears flag that keeps interest off the annual statement

Section 13(2), no. 3, requires a marker on loans with unpaid due interest relating to calendar years before the reporting year. In the file it is LånForholdRestanceMarkering, set true or false per account period (guide section 4.6). True means the interest is not pre-printed on the borrower’s annual statement, and the borrower’s tax information shows the loan as in arrears.

The guide’s six-year example shows the flag tracking arrears from earlier years only:

Year 1 is false even though nothing was paid, because no earlier year is in arrears. Year 5 stays true with no interest charged at all. That year in Appendix 1 is a temporary interest freeze, and the guide states the rule in section 4.6: the unpaid due interest is the loan’s accumulated interest, so a distressed loan whose interest accrual has been set to zero stays flagged, including when accrual resumes.

Payment allocation follows the parties’ agreement. Without one, the guide records the normal practice that payments on account first cover unpaid due interest. A loan with a debt-forgiveness code is still flagged if earlier years’ interest is unpaid (guide section 4.7).

When a loan is sold, the buyer takes over the reporting and the responsibility for correct arrears marking, including for the year of the takeover, so the guide asks the seller to pass on customer data, principal and interest history (guide section 4.6). The guide also recommends a check before filing: the processing report from validation counts the records flagged true, a figure to reconcile against the loans that meet the arrears condition (guide section 0.2).

Debt forgiveness codes 4 to 7

Section 13(2), no. 4, requires a marker where debt forgiveness under section 5(9) of the Tax Assessment Act has taken place in the reporting year or earlier. The field is LånForholdGældEftergivelseKode on the borrower list, and when a code is reported the interest is not pre-printed (guide section 4.7).

Full forgiveness takes no code. Where the whole debt lapses, for instance under a debt-restructuring order, the field stays empty; if all the year’s interest is inside the forgiven debt, the interest goes in as 0, and interest actually paid is reported as the year’s interest.

Partial forgiveness takes a code, and the 2026 guide makes the trigger explicit: the code is reported only where unpaid interest is part of the debt being reduced. Waiving fees alone does not count as debt forgiveness, so the loan carries no code (guide sections 0.1 and 4.7). A lower interest rate, an interest stop, or a write-down that only removes time-barred interest or fees does not trigger code 5.

• Code 4, partial public debt forgiveness: a debt-restructuring order published in Statstidende or a decision by Gældsstyrelsen, reported only in the year it is made.
• Code 5, partial private debt forgiveness: compositions, write-downs on the sale of claims, forgiveness conditional on a payment plan, or a creditor’s own decision to forgive. It stays on the loan for the rest of its life unless code 4, 6 or 7 applies.
• Code 6, a new private forgiveness agreement entered in the year, reported only in that year, after which the loan returns to code 5.
• Code 7, a forgiveness agreement cancelled, for example for breach or false information, reported only in the year of cancellation.

How much debt to report under a forgiveness agreement

The debt field follows different logic for public and private forgiveness (guide section 4.5.2). Under partial public forgiveness, the debt is the agreed reduced amount less instalments paid during the year. Under partial private forgiveness, the debt is based on the amount owed on the date of the agreement, and the reduced amount payable under the plan plays no part. The guide’s example starts from DKK 100,000 owed on 1 March of year 1, including DKK 30,000 of unpaid interest, with DKK 10,000 a year payable for five years and DKK 50,000 forgiven if the plan holds. The reported debt then runs 90,000, 80,000, 70,000 and 60,000, and drops to 0 in year 5; the guide’s table marks the arrears flag in years 1 to 4 and shows it in parentheses for year 5.

Where only one of several borrowers on a loan receives public forgiveness, the loan is split into separate reports with the same KontoID and different sequence numbers, and full forgiveness for one borrower takes that borrower out of the loan, with a separate account period for each ownership circle (guide section 4.5.2).

Collection, sales and mergers: when the loan changes hands

Handing a distressed loan to a collection agency while staying the creditor is no sale, because the creditor does not change (guide section 0.2). The agency uses the same KontoID, no end date is set at handover, and the transition year is reported once, typically by the agency for the whole year. A sale is the opposite case: the seller sets the end date to the transfer date, the buyer reports the original start date, and the borrower’s CPR number has to be handed over with the claim (guide sections 4.4 and 4.7.1).

Loans may not be merged on a transfer to collection or a sale; each loan relationship is reported separately with its own start date. Where loans were wrongly merged under a new KontoID, the repair is to invalidate the merged KontoID for every affected year and then report each loan with its own KontoID, reusing the old ones where they are known (guide section 0.3).

Mergers, demergers and conversions

For a merger the guide recommends splitting by quarter: the ceasing institution reports the quarters up to the merger date and then files nil reports for the following quarters and the year-end, while the continuing institution reports from the merger quarter and for the whole year-end, which means it needs the whole year’s interest (guide section 0.2). It also takes over the ceasing institution’s earlier reports (guide section 2).

A demerger produces two account periods in its year: the existing company up to the day before the demerger, and the new companies from the demerger date. A tax-free conversion of a business with retroactive effect to 1 January is reported on the new CVR number for the whole year, with the account period starting 01.01 to avoid error 54 and the original KontoStartDato kept (guide section 0.2).

When a property is sold and residual debt moves from the Prioritetslån report type to Udlån without a new loan document, the Udlån record keeps the original start date, the KontoID and any arrears flag, and the Prioritetslån record closes on the sale date with a debt of 0 (guide section 0.2).

Validation, statuses and corrections

The file goes through the REST API, the FTPs gateway or TastSelv Erhverv (guide section 3.2), and the TFE test environment is open all year, and production data can also be validated in the production environment (guide section 5).

Section 0.3 lists the errors worth testing for. Error 78 rejects XML that does not match the schema, and for 2026 the namespace is http://skat.dk/ekapital/2026/01/01, so a 2025 file cannot be reused. Error 68 rejects a year-end file containing IndkomstPeriodeTil, a quarterly-only field. Error 139 catches KontohaverUkendt used outside its three permitted cases. Counts and amounts are reconciled against the accounts, checking for duplicates and for amounts entered in øre instead of kroner.

Error 58, raised when a CVR or SE number ceased more than a year before the income year, gets a 2026 clarification. For a ceased sole proprietorship all founders are reported, and for a ceased company at least one, marked as chairman. Where the founders’ details cannot be obtained despite reasonable efforts, the record stays on error 58 until they are known or the loan ends (guide section 0.3).

Valid status and what reaches the borrower

FejlFormat and FejlIndberetning reports are not valid (guide section 7), and where no valid report exists on the loan the institution files a new initial report. FejlKonto, FejlKontohaver, GodkendtKontoAdvis and GodkendtKonto reports are valid and are changed through the correction principle, with RettelseID pointing at the valid IndberetningID, yet a valid status only means the XML is valid. GodkendtKonto and GodkendtKontoAdvis reports appear in the borrower’s tax information, and FejlKonto, FejlIndberetning and FejlFormat reports do not; a FejlKontohaver report is hidden for the account holder that failed and still appears for the account holders that did not (guide section 8).

To change an amount on an approved loan, the guide encourages a correction over an invalidation followed by a new report (guide section 7.1.1). The guide’s reason is timing: an invalidation and a new report may land in different runs and generate two proposals for a new annual statement, while a correction reverses and reposts in one run. The guide recommends isolating a change of UdlånKontoNummer in a correction report of its own, and it requires any other corrections to the account to go in a separate correction report filed before the account-number change, so that, in the guide’s example, a wrongly reported arrears flag that is being corrected does not linger on the old account number.

Errors found in an approved report are corrected immediately, which the 2026 guide spells out as without undue delay (guide section 2). For 2021 and earlier years the institution contacts eKapital to agree how to correct, and from 2022 it uses each year’s own XML structure (guide section 7.4). Before a larger batch of corrections, especially after the first annual statements at the end of March, the guide encourages institutions to tell Skattestyrelsen first (guide section 7.3).

Quarterly Udlån reporting under section 15 runs alongside

Lenders under section 13(1), first sentence, also report quarterly under section 15: the borrower’s identity, the interest and contributions for the quarter, and grant and end dates (section 15(1)). Section 31(2) of the executive order sets the amount per loan as the total credited or charged from the start of the calendar year to the end of the quarter reported. The quarterly report is due by the last business day of the month after the quarter ends (section 15(2)), so the first 2027 report falls at the end of April 2027. There is no quarterly report for the year’s last quarter, and the year-end file covers the full year: the guide states that the quarterly reports do not replace the year-end report (guide section 1.2).

Section 15(3) narrows the quarterly perimeter to borrowers who are natural persons with a CPR number, and exempts loans with three or more borrowers resident in Denmark and loans under section 13(3). Section 15 b, as amended by lov nr. 1784 of 29 December 2025 with effect from 1 July 2026, lets lenders and registered credit intermediaries, with the registered person’s consent and under an agreement with Skattestyrelsen, access the quarterly data where it is needed in a specific credit decision. The guide also lists banks’ credit assessment among the uses of reported data (guide section 8), and I read the two provisions together as the reason quarterly accuracy matters beyond the tax return.

Penalties, retention and reconciliation

Section 59 of the Act fines intentional or grossly negligent failures to report by the section 15(2) or 54(1) deadlines, to resubmit by the section 54(6) deadline, or to keep or hand over material under section 56. Section 58 covers intentionally false, misleading or incomplete information leading to too low a tax assessment, with a fine or up to one year and six months’ imprisonment unless section 289 of the Criminal Code carries a higher penalty. Section 57 lets Skattestyrelsen order a late reporter to report by a set deadline, with daily coercive fines from that deadline until it complies, and the guide states that current practice sets them at a minimum of DKK 1,000 a day (guide section 1.7).

The guide’s fine scale runs by the total number of records: DKK 5,000 for 1 to 1,000, DKK 10,000 above 1,000 up to 10,000, DKK 20,000 above 10,000 up to 100,000, DKK 40,000 above 100,000 up to 1,000,000, and DKK 80,000 above 1,000,000, adjustable for aggravating or mitigating circumstances (guide section 1.7). Responsibility stays with the reporting entity when employees or a bought-in service do the filing.

Section 56(1) requires the basis for the reported data, including the data used to decide whether something is reportable, to be kept under the Bookkeeping Act’s rules for accounting material, and the guide puts the period at five years (guide section 1.6). A bookkeeping entity whose reported data sits in its accounts has to keep the two reconcilable. The guide adds that larger businesses, banks included, show a reconciliation between the interest in their accounts and the interest reported under sections 12 to 14, while smaller ones do so on request (guide section 1.7).

Frequently Asked Questions

A loan was taken out in a customer’s name through identity theft. Does it go into Udlån?

No. Loans taken out by misusing another person’s identity are not reported, and a report already filed is invalidated. The later claim against the convicted person is an invoice claim with no loan agreement behind it, so it is not reported either (guide section 0.2).

A customer deposits a promissory note from a private sale with the bank. Does the bank report it?

Not under Udlån. The guide bars reporting promissory notes in custody where the creditor does not lend as a business, and the borrower claims the deduction by giving the lender’s identity under section 41(1) (guide section 1.1.2). A mortgage deed over real property placed with a custodian for management goes to the custodian’s section 14 Pantebreve report instead (guide section 4.1).

The bank charges a guarantee commission when a customer remortgages. Is that reportable interest?

No. The guarantee is no loan, so there is no reporting duty for the commission, and the citizen enters it in box 44 of the annual statement (guide section 1.1.2).

Under a conditional settlement on a defaulted loan, the bank calculates shadow interest. What goes in RenteBeløb?

Only the interest credited or due. Calculated or shadow interest is reported only if it falls due for payment, and then in the year it falls due (guide section 4.5.1).

The borrower died more than two years ago and the estate is still on the loan. What happens?

The record receives advis 32. The guide asks institutions to register the person who takes over the loan once the estate is wound up; while the estate stays on the record, a surviving spouse who took over the whole loan does not automatically get the full interest deduction (guide section 0.3).

A loan was reported to Udlån when it belonged in Indlån. Can it be corrected?

Through invalidation. The wrong report type or the wrong period is one of the cases where the guide uses invalidation; for a valid report the invalidation carries RettelseID pointing to the existing IndberetningID, and the loan is then reported in the right place (guide section 7.2).

Related Articles

• Deposit Reporting to Skat: The Indlån File Due 20 January 2027: the section 12 deposit return that shares the Udlån deadline, channels and gross or net registration.
• KGFS Reporting in Denmark: New Home Loans to High-Debt Borrowers: Finanstilsynet’s supervisory return on new home lending to high debt-to-income borrowers.
• Cooperative Capital Distributions to Skat: The Section 30 Filing: another skatteindberetningsloven return on the 20 January deadline.
• CRS Reporting in Luxembourg: the Common Reporting Standard and its tax-residence classification, which the Udlån residence test does not follow.

Key Takeaways

• Map every guarantee in the book against the guide’s three guarantor cases before the first test run, and flag instalment-only guarantees for a zero-debt record.
• Make the true-flag count in each processing report a sign-off item against the arrears ledger before production submission.
• Debt-forgiveness coding needs an input showing whether unpaid interest sat inside the reduced debt; fee waivers, rate cuts and interest stops stay uncoded.
• Outsourced collection keeps the KontoID, any UdlånKontoNummer change should wait for the turn of the year, and the contract should say which party reports the transition year.
• Loan-book purchase agreements need original start dates, CPR numbers and interest history at transfer, since the buyer owns the arrears flag from the year of takeover.
• Add an overpayment rule to the extraction: a loan whose only balance is a customer credit closes in the redemption year, and the credit stays out of Udlån.
• Branch the extraction by account type so municipal and regional late-payment interest under type 64 never carries a debt amount.

Sources and References

• Skattestyrelsen, Indberetningsvejledning om Udlån årsultimo 2026, S nr. 113, version 1.0, published 30 September 2026 (table of contents and version history): https://info.skat.dk/data.aspx?oid=2287596&vid=221428
• Udlån 2026 guide, sections 0 to 0.3: https://info.skat.dk/data.aspx?oid=2287597&vid=221428, https://info.skat.dk/data.aspx?oid=2287598&vid=221428, https://info.skat.dk/data.aspx?oid=2287599&vid=221428, https://info.skat.dk/data.aspx?oid=2287600&vid=221428
• Udlån 2026 guide, sections 1.1 to 1.1.2: https://info.skat.dk/data.aspx?oid=2287602&vid=221428, https://info.skat.dk/data.aspx?oid=2287603&vid=221428, https://info.skat.dk/data.aspx?oid=2287604&vid=221428
• Udlån 2026 guide, sections 1.2 to 1.3.3: https://info.skat.dk/data.aspx?oid=2287605&vid=221428, https://info.skat.dk/data.aspx?oid=2287606&vid=221428, https://info.skat.dk/data.aspx?oid=2287607&vid=221428, https://info.skat.dk/data.aspx?oid=2287608&vid=221428, https://info.skat.dk/data.aspx?oid=2462473&vid=221428
• Udlån 2026 guide, sections 1.4.1 and 1.4.2: https://info.skat.dk/data.aspx?oid=2287611&vid=221428, https://info.skat.dk/data.aspx?oid=2290892&vid=221428
• Udlån 2026 guide, sections 1.5 to 1.7: https://info.skat.dk/data.aspx?oid=2287613&vid=221428, https://info.skat.dk/data.aspx?oid=2287614&vid=221428, https://info.skat.dk/data.aspx?oid=2287615&vid=221428
• Udlån 2026 guide, sections 2 and 3.2: https://info.skat.dk/data.aspx?oid=2287617&vid=221428, https://info.skat.dk/data.aspx?oid=2287620&vid=221428
• Udlån 2026 guide, sections 4 to 4.2.1: https://info.skat.dk/data.aspx?oid=2287622&vid=221428, https://info.skat.dk/data.aspx?oid=2287623&vid=221428, https://info.skat.dk/data.aspx?oid=2287624&vid=221428, https://info.skat.dk/data.aspx?oid=2287626&vid=221428, https://info.skat.dk/data.aspx?oid=2290895&vid=221428
• Udlån 2026 guide, sections 4.3 to 4.4: https://info.skat.dk/data.aspx?oid=2287627&vid=221428, https://info.skat.dk/data.aspx?oid=2287628&vid=221428, https://info.skat.dk/data.aspx?oid=2287629&vid=221428, https://info.skat.dk/data.aspx?oid=2287632&vid=221428
• Udlån 2026 guide, sections 4.5 to 4.5.3: https://info.skat.dk/data.aspx?oid=2287633&vid=221428, https://info.skat.dk/data.aspx?oid=2287634&vid=221428, https://info.skat.dk/data.aspx?oid=2287635&vid=221428, https://info.skat.dk/data.aspx?oid=2287636&vid=221428, https://info.skat.dk/data.aspx?oid=2338761&vid=221428
• Udlån 2026 guide, sections 4.6 to 4.7.2: https://info.skat.dk/data.aspx?oid=2287637&vid=221428, https://info.skat.dk/data.aspx?oid=2287638&vid=221428, https://info.skat.dk/data.aspx?oid=2287639&vid=221428, https://info.skat.dk/data.aspx?oid=2287640&vid=221428, https://info.skat.dk/data.aspx?oid=2287641&vid=221428, https://info.skat.dk/data.aspx?oid=2287642&vid=221428
• Udlån 2026 guide, sections 5, 7 to 7.4 and 8: https://info.skat.dk/data.aspx?oid=2287643&vid=221428, https://info.skat.dk/data.aspx?oid=2287648&vid=221428, https://info.skat.dk/data.aspx?oid=2287649&vid=221428, https://info.skat.dk/data.aspx?oid=2394975&vid=221428, https://info.skat.dk/data.aspx?oid=2394976&vid=221428, https://info.skat.dk/data.aspx?oid=2394977&vid=221428, https://info.skat.dk/data.aspx?oid=2394978&vid=221428, https://info.skat.dk/data.aspx?oid=2394979&vid=221428, https://info.skat.dk/data.aspx?oid=2287650&vid=221428
• Udlån 2026 guide, sections 4.8 and 4.9: https://info.skat.dk/data.aspx?oid=2290894&vid=221428, https://info.skat.dk/data.aspx?oid=2459343&vid=221428
• Retsinformation, Bekendtgørelse af lov om gebyrer og morarenter vedrørende visse ydelser, der opkræves af regioner og kommuner, og om opkrævning af ejendomsbidrag (gebyrloven), lovbekendtgørelse nr. 468 af 17. maj 2024: https://www.retsinformation.dk/eli/lta/2024/468
• Udlån 2026 guide, Appendix 1 (Bilag 1): https://info.skat.dk/data.aspx?oid=2287653&vid=221428
• Retsinformation, Bekendtgørelse af skatteindberetningsloven, lovbekendtgørelse nr. 1059 af 21. august 2025, sections 13, 15, 15 b, 19 a, 47, 51, 52, 54, 56, 57, 58 and 59: https://www.retsinformation.dk/eli/lta/2025/1059
• Retsinformation, Lov nr. 1784 af 29. december 2025 om ændring af toldloven, lov om et indkomstregister, skatteindberetningsloven og skattekontrolloven, section 3 (amends section 15 b of skatteindberetningsloven with effect from 1 July 2026): https://www.retsinformation.dk/eli/lta/2025/1784
• Retsinformation, Bekendtgørelse nr. 1016 af 22. juni 2023 om skatteindberetning m.v., sections 1, 3, 4, 5, 29 and 31: https://www.retsinformation.dk/eli/lta/2023/1016
• Retsinformation, Bekendtgørelse nr. 885 af 26. juni 2024 om ændring af bekendtgørelse om skatteindberetning m.v. (new section 6, including section 6(3) on loans with two or more liable parties, effect from calendar year 2025): https://www.retsinformation.dk/eli/lta/2024/885
• Finanstilsynet, KGFS anvisning gældende fra perioden 202543 (reporting instructions for the high debt-to-income home loan return, dated 15 September 2025): https://cdn.finanstilsynet.dk/finanstilsynet/Media/638935223800880576/KGFS_Anvisning%20uden%20synlige_202543.pdf

Udlån 2026: the build window before 20 January 2027

Reporting, testing and validation for year-end 2026 open on Monday 5 October 2026 under the 01/01/2026 namespace, leaving the autumn for TFE runs on the 2026 clarifications: guarantees covering only instalments reported with a zero debt, closed overpaid loans, partial forgiveness coded only where unpaid interest is part of the reduced debt, and 31 December ownership changes split across two years. The year-end Udlån file for calendar year 2026 is due with Skattestyrelsen by Wednesday 20 January 2027, and the first quarterly report of 2027 follows at the end of April.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.