Skat Årsbrev 2026: TIN Rules, OBLG Entry Tests and Key Dates

Skattestyrelsen published version 1 of the Skat Årsbrev 2026 on 29 June 2026. The annual letter lists the changes and clarifications that reporting entities must build into their eKapital reports on interest, securities and pension contributions for year-end 2026 (Årsultimo 2026) and for the ongoing and quarterly reporting that follows in 2027. Most of the year-end files it governs fall due on Wednesday 20 January 2027 under section 54(1) of the Danish Tax Reporting Act (skatteindberetningsloven).

For the banks, custodians and pension providers that file through eKapital, the letter is where Skattestyrelsen announces what its systems will reject before the subsystem guides catch up. The changes described below come from Årsbrev 2026 version 1, published on 29 June 2026. Skattestyrelsen has said it will re-issue the letter, so check the hub page on info.skat.dk for later versions and classification-list updates before implementing.

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

What the Skat Årsbrev 2026 covers and how it reaches the guides

Skattestyrelsen’s own summary calls the Årsbrev its orientation to everyone with a reporting obligation: information on the reporting changes that must be implemented in the mandatory reports for the income year concerned. The 2026 letter has seven sections. They cover general information and the production calendar, cross-cutting topics, interest, balances and debt, securities and share savings accounts (aktiesparekonti), pension contributions, the EIS system for establishment and equalisation accounts, and an annex listing the record structures and helper lists. The letter states that its changes and clarifications will be incorporated into the reporting guides (indberetningsvejledninger) for each subsystem.

The obligations themselves come from statute. The Tax Reporting Act was consolidated as lovbekendtgørelse nr. 1059 of 21 August 2025 and has subsequently been amended; the applicable text therefore consists of that consolidation together with amendments effective for the relevant reporting period. The implementing rules likewise include executive order nr. 1016 of 22 June 2023 on tax reporting (bekendtgørelse om skatteindberetning m.v.) as subsequently amended. The Årsbrev tells reporters how Skattestyrelsen will apply and validate those rules in the coming cycle, and in 2026 it also corrects one of Skattestyrelsen’s own earlier instructions.

Version numbers on the info.skat.dk page are easy to misread. The PDF linked from the page is still labelled version 1. The hub page carries its own page-version history, separate from the letter’s version number. The previous letter shows how a cycle continues after June: Årsbrev 2025 reached version 3 on 24 November 2025, with changes against version 2 printed in red. The 2026 letter already points to a re-issue. The page hosting the error-number overview says the 2026 overview will be published when the letter is re-issued, and the letter says any extension of TastSelv Erhverv file upload to further IFPA record types would be announced the same way.

Test windows, cut-offs and the 20 January 2027 deadline

The calendar in section 1.2 of the letter runs on two tracks. The interest systems (the RENTE system: Indlån, Udlån, Prioritetslån and Pantebreve) and Pensiondiverse accept year-end data from early October through the REST API web service, the FTPS Gateway and TastSelv Erhverv. The securities systems and the CPS pension-contribution system switch format over the winter, with a closed period, a user test and a first production run in January.

• 5 October 2026: the Årsbrev calendar (sections 1.2.2.3 and 1.2.3.3) opens the RENTE systems and Pensiondiverse for the Årsultimo 2026 cycle.
• Tuesday 10 November 2026 (week 46): the last FTPS Gateway deadline for old-format production data is 23:59 (2025 format on the eKapital page, 2026 format in the letter). SF-tele and TastSelv Erhverv single entry for CPS close at 16:00, and TastSelv Erhverv file upload for CPS closes at 23:59. For AKSA and IFPA file upload, the letter gives 16:00 and the eKapital page gives 23:59, with a separate 16:00 closure on the page for AKSA liquidation proceeds.
• Friday 13 November 2026, 00:01: the user test for the securities systems and CPS opens. It closes on Thursday 10 December 2026 at 23:59.
• 17 November 2026: AKSA file upload for liquidation proceeds reopens after a short closure in week 46.
• Monday 14 December 2026, 00:01 (week 51): the gateway accepts production files in the 2026 format, held until the first production run.
• 31 December 2026: the RENTE systems and Pensiondiverse close for Årsultimo 2021 reporting.
• 1 January 2027: share savings accounts open for calendar year 2026; the new TIN collection instruction applies.
• Monday 4 January 2027: the RENTE systems open for quarterly 2027 reporting. SF-tele, CPS single entry and TastSelv Erhverv file upload for AKSA and IFPA reopen at 08:00. For CPS file upload, the letter gives 00:01 and the eKapital page gives 08:00.
• Tuesday 5 January 2027 (week 1): first production run for the securities systems and CPS pension-contribution reporting. Pensionsstatistik is subject to a separate timetable: production reporting for 2026 opens on Thursday 25 March 2027 at 08:00.
• Wednesday 20 January 2027: eKapital reporting deadline for year-end 2026.

One label in the letter does not match Skattestyrelsen’s eKapital page. The letter’s heading for the 10 November cut-off calls it the last production run “in 2026 format”. The eKapital page on skat.dk describes 10 November 2026 at 23:59 as the last deadline for production data in 2025 format via FTPS Gateway, and dates the opening for 2026-format production data to 14 December 2026. The 2025 letter followed the same pattern a year earlier, with its November cut-off for “2024 format” and its first January run in “2025 format”. Read together, the sources place 10 November at the end of the old format and 14 December at the start of the new one.

The two sources also differ on file-upload times. The letter closes AKSA and IFPA file upload at 16:00 on 10 November and reopens CPS file upload at 00:01 on 4 January 2027. The eKapital page closes TastSelv Erhverv file upload for IFPA, AKSA and CPS at 23:59 on 10 November, with a separate 16:00 closure for AKSA liquidation proceeds (back on 17 November at 09:00), and reopens file upload at 08:00 on 4 January 2027. The calendar above gives both times where they differ. A schedule built to the earlier closing time and the later reopening time fits both sources; recheck the eKapital page before uploads are timed.

The user test has a narrower door than production. Only deliveries through the FTPS Gateway are included, and the test runs three times a week, on Monday, Wednesday and Friday, in weeks 47 to 50. Under the letter, files sent to the gateway between 14 December 2026 and 5 January 2027 count as 2026-format production material and wait for the first production run, so status file 3 arrives only after that run. The letter includes pensionsstatistik (CPS 2252) in that arrangement, but the eKapital page treats it separately: pensionsstatistik user tests can run through the gateway from 14 December 2026 to 18 March 2027, and 2026 production data can be sent from 25 March 2027 at 08:00.

Section 1.3 of the letter then sets out how Skattestyrelsen uses the data to change customers’ annual tax statements (årsopgørelser) automatically. After the 20 January 2027 deadline, 2026 data should appear in customers’ tax information after 1 February 2027; TastSelv opens for the 2026 statement in March 2027; early April 2027 is the last point for data to reach the first locked statement; and automatic changes to the 2026 statement start after that, in April 2027. Only the 20 January date is firm. The letter calls the 1 February date indicative, says the March and April dates have not been fixed, and notes that automatic change covers neither all citizens nor all boxes on the statement.

The eKapital systems and the sections of the Act behind them

Section 1.1 of the letter maps each eKapital system to its record types, channels and the section of the Tax Reporting Act it implements. Condensed:

Location decides who carries the duty. Section 47(1) of the Act places the reporting obligation under sections 11 a to 19 a, among others, on natural or legal persons resident in Denmark or operating from a permanent establishment there.

The 20 January date is narrower than it looks. Section 54(1) sets 20 January, or the following Monday when that day falls on a weekend, for reports under sections 8, 11 a(1) and (2), 12 to 14, 15 a, 16, 17, 18, 19 and 19 a, among others, and for pension reports under rules issued under sections 9 to 11. The same section carves out two groups. Dividends on shares and investment fund units in Danish companies and investment associations, reported under section 16 and section 18(2), are due by the last business day of the month after the decision to pay or credit the dividend (section 54(3)). Contributions to pension schemes under section 18(1), ninth sentence, of the Pension Taxation Act are due by 1 August (section 54(2)). A dividend on Danish shares declared at a general meeting in March 2026 was therefore reportable by the last business day of April 2026, months before the year-end window opened.

TIN reporting after the account-opening-date rule falls away

Section 2.1.3 is the change with the widest reach, because it covers every person the reports identify, from account holders to guarantors. For several years Skattestyrelsen instructed reporters to look at when an account, loan or custody account was opened when deciding whether a TIN had to be reported. The letter now says Skattestyrelsen has become aware that, under current law, no such distinction applies.

The legal anchor is section 3(2) of executive order nr. 1016/2023. A person reported on under the provisions it lists, which include sections 11 a to 14 and 15 a to 20 of the Act, must give the reporting entity their identification number under the rules of their state of residence, or their date, place and state of birth if they have no such number. As the letter points out, the order contains no transitional rule tied to when the account, loan or depot was opened.

The new instructions in the letter:

• Report the TIN where the state of residence issues one. Where the person has no TIN, report date, place and state of birth. This applies whenever the account, loan or depot was opened.
• Residence and tax-liability country will normally be the same. Where a customer has given a TIN issued by the country in which they are liable to tax, and not one from their country of residence, Skattestyrelsen accepts that TIN in the report.
• When a reporting entity finds that a customer has moved abroad, or moved between two countries other than Denmark, it must make reasonable efforts to obtain the TIN if the residence country issues one. If the country does not issue TINs and the birth details are not on file, the reasonable efforts go to those details instead.

Reasonable efforts come with a defined trigger. The letter ties them to customer due diligence under the Danish AML Act (hvidvaskloven): when customer information has to be updated under those rules, the reporting entity must request the TIN issued by the residence country. The instruction applies from 1 January 2027, which Skattestyrelsen says gives reporters reasonable time to adjust their collection processes. Accounts and depots within CRS keep the CRS rules on obtaining identification data.

The letter attaches the TIN request to updates the AML rules already require, from 1 January 2027 onward, and sets no separate deadline for working through the back book. Validation changes sooner. The letter says the business rules and advisories in the RENTE system that tied TIN to the account’s start date will be withdrawn from Årsultimo 2026 onward, so the year-end 2026 files are the first checked without them.

Two smaller points sit next to the main change. Among the error situations Skattestyrelsen observed in the 2025 reporting were TIN fields with incorrect content, and the letter’s instruction is that the TIN fields stay empty when the reporter holds no TIN. Skattestyrelsen also says the new TIN instructions require changes to its guidance on state forfeiture of unidentified accounts and depots, and it expected to publish updated guidance in October 2026.

Estates, tax-exempt customers and forfeited accounts

The estate rules were clarified in version 3 of the 2025 letter and built into the 2025 year-end guides; the 2026 letter repeats them as a table. Before the estate’s cut-off date (skæringsdato), records go on the deceased’s CPR number. From the cut-off date, an undivided estate (uskiftet bo) is reported on the surviving spouse’s CPR number and a divided estate (skiftet bo) on the heir’s or heirs’ CPR numbers. Where the spouse’s or heirs’ identity is not known when the report is made, reporting continues on the deceased’s CPR number.

Accounts and depots blocked at 31 December 2024 were announced in the Statstidende on 29 April 2026, and Skattestyrelsen issued a press release on unidentified accounts and depots the same day. Its forfeiture guidance is published once a year; the latest edition before the letter was dated 20 October 2025.

Section 51(1) of the Act requires reporters to omit reports under sections 12 to 16, section 17(1) and (2), section 18 and section 19 a about tax-exempt institutions covered by section 3 of the Corporation Tax Act (selskabsskatteloven), state-recognised unemployment funds, and banks, pension funds, mortgage credit institutions and insurers. The letter’s clarification is about evidence for the first group. For customer relationships established after 1 January 2024, the reporter obtains documentation when it judges that the customer may be exempt under section 3. For relationships established before 1 January 2024, the customer is reported unless documentation shows the section 3 exemption. Acceptable documentation is the institution’s registration certificate or another confirmation from Skattestyrelsen showing the exemption. Where the certificate does not show it, the institution has to obtain confirmation from Skattestyrelsen or re-register.

Skattestyrelsen also examined whether it could get legal authority to publish a list of every entity registered as exempt under section 3. Its conclusion was that the change will not be made, partly because such a list could not be expected to be complete.

The exemption has a statutory edge the letter does not repeat. Section 51(3) switches off section 51(1) for reporting under sections 16 and 18 on dividends from investment fund units and shares in Danish companies. A section 3 foundation holding Danish shares in custody is still reported on for those dividends, whatever documentation it has supplied.

Deposits, loans and mortgage deeds: the Årsultimo 2026 clarifications

The record structures for Indlån, Udlån, Prioritetslån and Pantebreve do not change for Årsultimo 2026, and the quarterly structure for 2027 stays the same too. Section 3 of the letter is about how existing fields are used. Our guide to the Udlån loan file covers the full loan return; the letter’s points are narrower.

Children’s savings accounts at the end of the binding period

The binding period on a children’s savings account (account type 10) ends at the latest at the end of the calendar year in which the child turns 21. The account must be bound for at least seven years and can be paid out at the earliest when the child turns 14. If the account carries on as an ordinary deposit, a new account period with type 13 starts. Where the binding ends on 31 December and the account stays open, the record shows a KontoperiodeOphørdato with type 10 at 31 December and a KontoperiodeOpstart with type 13 on 1 January of the following year.

Skattestyrelsen expects to add an advisory on type 10 accounts from the year the owner turns 14 until the account closes, and an error code where the owner is 21 or older in the reporting year and no closing date or period end date is given. It has also seen children’s savings accounts for the same person reported by several banks, and expects banks to have processes that, as far as possible, prevent opening one for a person who already holds one at another bank.

When a guarantor is reported

Until Skattestyrelsen instructs otherwise, a guarantor (kautionist) is reported only in three situations: one guarantor covers the borrower’s obligations on the loan in full; two or more guarantors cover them in full, jointly and severally; or the borrower is no longer liable for the debt. The letter’s examples of the third case are completed public debt relief with the whole debt cancelled, a deceased borrower whose estate has been wound up, and a legal-person borrower that has ceased, for example through bankruptcy. Where the guarantor is liable at 31 December only for the instalment under the guarantee agreement, and not for the debt, the outstanding debt is reported as zero. The system accepts a zero balance without a closing date.

Debt forgiveness codes 4 and 5

Sections 13(2), no. 4, and 14(3), no. 2, of the Act require interest to be marked on loans where debt has been forgiven as described in section 5(9) of the Tax Assessment Act (ligningsloven), in the reporting year or an earlier one. Under section 5(9), a taxpayer whose debt is reduced through forgiveness can deduct interest accrued at that point only in proportion to the share of the debt that remains payable. The letter narrows the code’s use: debt-forgiveness code 4 or 5 is reported only on partial forgiveness, and only where the reduced debt includes unpaid interest that had fallen due.

Errors Skattestyrelsen found in the 2025 files

Section 3.1.5 lists error situations Skattestyrelsen observed in the 2025 reporting for Indlån, Udlån, Prioritetslån and Pantebreve:

• accounts with outstanding debt above zero at 31 December that were not reported in the following calendar year;
• a KontoOphørDato sent with the quarterly reporting but missing from the year-end file;
• KontoID values changed during the life of an account, for example when the account passes to a collection partner or when the KontoID embeds the calendar year;
• incorrect data in the TIN field;
• a KontoPeriodeOpstartDato set at the KontoStartDato, when the XML should carry that field only if ownership or account type changed within the reporting period.

E-money from the 2027 reporting

Section 3.2 looks a year ahead. The letter states that services concerning Specified Electronic Money Products (SEMP) and electronic money tokens (EMT) fall within the section 12 deposit-reporting obligation, and that a new account type for e-money products will be introduced in Indlån from the 2027 reporting. The section sits under known and expected changes for Årsultimo 2027, the file that section 54(1) puts due in January 2028.

Securities: two OBLG entry tests, AKSA code H and IFPA file upload

Section 4.1 lists four changes to securities reporting at year-end 2026. The record structures for AKSA, BHOL, FINK, UDBY, OBLG and IFPA stay unchanged, so the changes come as validation rules, codes and a channel.

OBLG: interest code 4 and currency status code 1

Interest code 4 identifies blue-stamped bonds (blåstemplede obligationer), which must be issued in Danish kroner. Skattestyrelsen has seen code 4 used for bonds issued in a foreign currency and reported as such with currency status code 1. From January 2027, for 2026 data, a record in individ 2204 or 2206 carrying interest code 4 together with VALUTSTATUKOD 1 is rejected.

OBLG: code R with a market value

Code R in the interest-beneficiary and capital-owner field marks an interest beneficiary (rentenyder). Records have arrived with code R and a market value (kursværdi). From January 2027, for 2026 data, a 2204 record with code R and a market value is rejected. The letter spells out the split: an interest-beneficiary arrangement needs two separate records, one with the interest amount on the beneficiary and one with the holding on the capital owner. If the interest recipient also owns the capital, one record covers both. Both OBLG tests are included in the user test at the end of the year.

IFPA: commissions passed on, by file upload

From year-end 2026, commissions and similar amounts passed on to customers (section 15 a of the Act, IFPA individ 2238) can be reported by file upload in TastSelv Erhverv. The channel is meant for small files of at most 3,500 records. Corrections for calendar year 2025 can already go through it; years before 2025 cannot. Uploaded files are fully validated against the same record structure and validation rules as the FTPS Gateway. A file with errors produces a validation report; a clean file produces a receipt summarising record counts and amounts. The two channels can be combined, for example a main file through the gateway and corrections or resubmissions of rejected records through upload.

Upload requires registration for the reporting obligation, a registered certificate and assigned rights. Skattestyrelsen is working on extending upload to dividends, reinvestment and holdings, and to trades in investment fund units and investment company shares. If that is ready for year-end 2026, a re-issued letter will say so.

AKSA: KØBSALGKODE H for employee shares

Lov nr. 1781 of 29 December 2025 rewrote section 7 P(2), no. 2, fourth sentence, of the Tax Assessment Act to widen the employee share scheme for new, smaller companies. The letter describes the new route as having no limit linked to the employee’s salary, but a requirement that annual salary reach a basic amount. The law sets that amount at DKK 193,200 at 2010 level, indexed, measured at the time the agreement is made, and also requires the conditions in section 7 P(7). Executive order nr. 553 of 22 June 2026 brought the law into force on 1 July 2026, and under section 2(2) of the law the new rules apply to grant agreements concluded after commencement.

AKSA (individ 2278) gets a new KØBSALGKODE H for shares granted under the amended provision. Code G, used for grants under the earlier wording with up to 50 per cent of salary, is being phased out. The letter keeps code G usable for 2026, because the old rules applied until the new ones took effect on 1 July 2026. The employee-share reporting guide is being updated for the new codes. AKSA also carries liquidation proceeds, whose file upload closes only briefly in week 46; our guide to section 28a liquidation proceeds reporting covers that filing.

Certificates and share-based contracts ahead of the 2028 OBLG move

For FINK (individ 2265), the letter confirms practice on contracts that give access to set-off. Product categories 02, 04, 06 and 08 signal a contract that is both share-based and admitted to trading on a regulated market or multilateral trading facility (MTF), the two features that together give the set-off right under section 32(3) of the Capital Gains Tax Act (kursgevinstloven). The letter restates the two conditions: the contract contains only a right or obligation to sell or acquire shares, or is based on a share index; and the contract, the underlying shares or the shares in the index are admitted to trading on a regulated market or MTF. Both must be met, and the FINK guide will be clarified to say so.

Certificates fall under section 29(3) of the Capital Gains Tax Act as structured claims (strukturerede fordringer). Since the reporting for calendar year 2025, they are reported in the same way as other structured claims: with more data, with product type code OBL or OBV, and to both FINK and OBLG. Reporters asked for practical markers. After a meeting with Euronext on product characteristics, Skattestyrelsen assesses that products with CFI codes beginning RF and EY are probably certificates within section 29(3), provided the agreement is not settled by delivery of the underlying asset. It takes the same view of products named tracker certificates, bull/bear certificates and mini futures.

The letter treats the CFI code as a pointer to a product’s structure and features and states that it has no standing as a tax definition. The product-by-product distinction stays with the reporter. A product master that maps RF and EY codes straight to structured-claim treatment still needs a check on physical settlement.

Section 4.3 sets two expected changes for calendar year 2027 data, reported at the earliest from January 2028. Skattestyrelsen plans to bring all structured-claim reporting, certificates included, into OBLG. A key FINK data point that OBLG does not carry today is the product category (share-based 02, 04, 06 and 08; non-share-based 01, 03, 05 and 07). The expected solution is a new interest code 6 in OBLG for share-based products, with interest code 2 redefined to cover the non-share-based ones. Separately, individ 2206 gets a new purchase and sale code 5, Låneomlægning, so that bond trades and accrued interest linked to mortgage loan conversions are marked unambiguously.

Pension reporting, EIS and share savings accounts

Pensiondiverse is the one structure the letter changes for year-end 2026. The field VirksomhedFormandAdministrator is added under Valutaudlænding Person and is mandatory from 2026: false for a foreign person, true where the account holder is chairman or administrator of a foreign company without a TIN. Valutaudlænding Virksomhed is added as an account-holder option, which makes it possible to report on a foreign company acting as employer. The letter directs reporters to skat.dk/rente for the new 2026 XML delivery, under Teknisk vejledning og information and then XML-leverancer, which links to an external GitHub wiki. It says a notice on the Driftslog and an updated 2026 service description on skat.dk will follow, and that XML schemas for the RENTE systems will in future be available only on skat.dk/rente.

For CPS, the premium contribution amount leaves out premiums for non-deductible insurance that forms an unseparated part of an employer-administered scheme under section 19 of the Pension Taxation Act, such as group life and health-treatment cover. Those premiums are reported only to eIndkomst. Where a pension fund uses part of its surplus to buy group life cover for members, the member’s or employer’s contributions are not payment for that cover. The fund’s premium is therefore not deducted from reported premium contributions, and it goes to eIndkomst.

Skattestyrelsen has discontinued the December pension newsletter because of low demand, leaving the Årsbrev as the only annual publication for pension reporters. Subscribers to the pension Driftslog are notified when letters appear. The letter also reminds providers that young people are exempt from labour market contributions (AM-bidrag) up to and including 31 December of the year in which they turn 17, so no AM-bidrag is settled on pension contributions under employer schemes agreed for them.

EIS has no structural change for 2025/2026 and stays open all year, by SF-tele, file transmission via FROC and paper form. Reports after two set dates carry a notification duty: reporting on establishment and entrepreneur accounts after 24 July 2026, or on business-cycle and income equalisation accounts after 6 November 2026, must be notified to Skattestyrelsen’s eKapital unit. Our EIS reporting guide sets out the underlying filings.

Share savings accounts (section 11 a) open for calendar year 2026 on 1 January 2027. From the same date, accounts closed or moved to another bank during 2027 can be reported on an ongoing basis. Production data can be validated for 2025 and 2026 now, and for 2027 from 1 January 2027, through the DUPLA web service (Open API) and TastSelv Erhverv. The TFE test environment is always open and accepts calendar years 2025 to 2028.

The helper lists published under the letter

Section 7 of the letter confirms that the record structures and error-list records for 2026 are unchanged, and lists the helper material Skattestyrelsen publishes under the letter on the eKapital portal. Several items carry detail that feeds straight into the files:

• Classification lists. The VP list of securities registered with Euronext Securities, Copenhagen, reflects the issuer’s own classification. A note on the page says shares and investment fund units traded on an MTF are reported with OPTTHANDELKODE 1 even where the VP list shows them with code 2 for regulated market. The list at 1 August 2026 changes the classification of 10 ISINs where Skattestyrelsen’s records differ from Euronext’s, and reclassifies 15 partnerselskaber (P/S) registered as shares: for tax purposes P/S interests are not shares and are not reported as shares. The list at 1 February 2026 had changed 22 ISINs.
• Error-number overview. The 2026 overview is not ready and will be published with the re-issued letter. The page links the 2025 list of error and advisory numbers in its place.
• Blacklisted countries 2026 (Sortlistelande). Lov nr. 788 of 4 May 2021 introduced tax sanctions against countries on the EU list of non-cooperative jurisdictions. Skattestyrelsen’s page explains that 44 per cent dividend tax is withheld on Danish shares covered by sections 4, 4 A or 4 B of the Share Gains Tax Act (aktieavancebeskatningsloven) when the recipient is tax resident or registered in a listed country, with the conditions in section 5 H of the Tax Assessment Act and section 65(12) and (13) of the Withholding Tax Act (kildeskatteloven).
• Interest reconciliation form (Afstemningsskema). Section 56(1) of the Act requires reporters to keep the basis for reported data under the Bookkeeping Act’s retention rules and, where they keep accounts that include the reported data, to organise those accounts so the reported figures can be reconciled with them. The page links a best-practice reconciliation template.
• TIN and code references: the EU TIN check on Europa, the OECD Automatic Exchange of Information portal showing which countries issue TINs, country and currency codes, and a schematic overview of receipt and error lists for the securities systems.

Frequently Asked Questions

A loan customer onboarded in 2019 moved from Denmark to Norway in 2026, and we hold no Norwegian TIN. What goes on the 2026 year-end record?

The letter’s error list says the TIN fields stay empty when the reporter has no TIN, so the record does not carry a placeholder. The move abroad triggers the reasonable-efforts duty, and from 1 January 2027 that duty is met by requesting the residence-country TIN at the next customer due diligence update under the AML Act. Whether Norway issues TINs, and in what format, can be checked against the OECD portal linked under the letter.

Can a 2024 correction to IFPA commission data go through TastSelv Erhverv file upload?

No. The letter limits upload to calendar year 2025 onward and excludes earlier years without naming another route. The IFPA commission reporting guide, which Skattestyrelsen is updating with the upload channel, is the place to confirm how pre-2025 corrections are filed.

An employee-share agreement was signed in June 2026 and the shares were delivered in September 2026. Which AKSA code applies?

The letter keeps code G available for 2026 because the old rules applied until 1 July 2026. A June 2026 agreement is outside the new basic-amount route because Lov nr. 1781 applies only to agreements concluded after the law took effect on 1 July 2026. If the grant qualifies under the former section 7 P(2), no. 2, fourth-sentence route with the 50 per cent salary limit, code G applies. Other pre-1 July grants must use the code corresponding to the provision under which they qualify. The updated employee-share reporting guide should confirm how the codes split by agreement date.

We deliver OBLG data by SF-tele. Can we test the new code 4 and code R rejections over the winter?

The user test in weeks 47 to 50 includes only deliveries through the FTPS Gateway, so an SF-tele reporter cannot run the winter test through its usual channel. The letter offers no SF-tele test alternative; the new entry tests apply in production from January 2027 for 2026 data.

We issue e-money products that are not bank deposits. Are 2026 balances already reportable under section 12?

The letter states in the present tense that SEMP and EMT services fall within section 12, but it places the new e-money account type in the 2027 reporting. It does not say how e-money balances should be coded in the 2026 Indlån file before that account type exists. That gap is a question to put to eKapital through TastSelv Erhverv before the 20 January 2027 deadline.

What happens to an open correction for Årsultimo 2021 after 31 December 2026?

The RENTE systems and Pensiondiverse close for Årsultimo 2021 reporting on that date, and the letter does not describe a route for 2021 data afterwards. Any 2021 correction still outstanding in Indlån, Udlån, Prioritetslån, Pantebreve or Pensiondiverse therefore needs to go in before the closure.

Where should a question containing customer data go?

Through TastSelv Erhverv: log in, choose Kontakt, then Skriv til os, eKapital and eKapital øvrigt, and attach files if needed. The letter warns that email to ekapital@sktst.dk is not encrypted and must not contain confidential or sensitive information, and asks for the CVR number and contact details with every enquiry.

Related Articles

• Deposit Reporting to Skat: The Indlån File Due 20 January 2027: who files the Indlån return and the balance, interest and holder data each account record needs.
• Loan Reporting to Skat: Arrears, Guarantors and the 2026 Udlån File: the year-end loan file, including guarantors, arrears and debt reported at 31 December.
• EIS Reporting in Denmark: The 1 June and 15 October Filings: bank reporting on establishment, entrepreneur and equalisation accounts to the EIS system.
• Liquidation Proceeds Reporting to Skat: Section 28a for Danish Funds: how liquidating companies and investment associations report proceeds to recipients.
• Cooperative Capital Distributions to Skat: The Section 30 Filing: the separate eKapital filing for capital distributions from Danish cooperatives.

Key Takeaways

• Run OBLG 2204 and 2206 feeds through the gateway user test between 13 November and 10 December 2026 to catch the code 4 plus VALUTSTATUKOD 1 and code R plus market value rejections.
• Strip account-opening-date logic from TIN selection before the Årsultimo 2026 run; from 1 January 2027, request residence-country TINs at each AML customer due diligence update.
• For the section 7 P route changed on 1 July 2026, distinguish agreements concluded before and after commencement: code G remains relevant to qualifying grants under the former fourth-sentence 50 per cent route, while the Årsbrev introduces code H for qualifying grants under the amended basic-amount route. Do not treat G as the general code for all pre-1 July employee-share grants.
• Populate VirksomhedFormandAdministrator on every Pensiondiverse Valutaudlænding Person record: false by default, true only for a chairman or administrator of a foreign company without a TIN.
• Obtain section 3 documentation at onboarding for customers after 1 January 2024 who may be exempt; pre-2024 customers without documentation are reported, and Danish dividends stay reportable either way.
• Plan production around 10 November 2026 (last old-format date), 14 December 2026 (first new-format gateway date) and the 5 January 2027 first run.
• Check the info.skat.dk page for a re-issued Årsbrev 2026, which is due to carry the 2026 error-number overview.

Sources and References

• Skattestyrelsen, Årsbrev om indberetning af renter, værdipapirer mv. (hub page): https://info.skat.dk/data.aspx?oid=10064&vid=221479
• Skattestyrelsen, Årsbrev indkomståret 2026 (årsultimoindberetningen 2026 og løbende indberetning 2027): https://info.skat.dk/data.aspx?oid=2460619&vid=221479
• Skattestyrelsen, Årsbrev (version 1) 2026 om indberetning af renter, værdipapirer og pensionsbidrag, published 29 June 2026 (PDF): https://info.skat.dk/getfile.aspx?id=159982&type=pdf
• Skattestyrelsen, Årsbrev (version 3) 2025, published 24 November 2025 (PDF): https://info.skat.dk/getfile.aspx?id=159174&type=pdf
• Skattestyrelsen, Klassifikationslister 2026: https://info.skat.dk/data.aspx?oid=2460620&vid=221479
• Skattestyrelsen, 2026 individstrukturer: værdipapirindberetning: https://info.skat.dk/data.aspx?oid=2461585&vid=221479
• Skattestyrelsen, Fejlnummeroversigt 2026: https://info.skat.dk/data.aspx?oid=2461602&vid=221479
• Skattestyrelsen, Afstemningsskema: renter: https://info.skat.dk/data.aspx?oid=2461607&vid=221479
• Skattestyrelsen, Sortlistelande 2026: https://info.skat.dk/data.aspx?oid=2461608&vid=221479
• Skattestyrelsen, Om eKapital (production deadlines and format labels for 2026 and 2027): https://skat.dk/erhverv/ekapital/om-ekapital
• Retsinformation, Bekendtgørelse af skatteindberetningsloven, lovbekendtgørelse nr. 1059 af 21. august 2025, sections 12 to 19 a, 47, 51, 54 and 56: https://www.retsinformation.dk/eli/lta/2025/1059
• Retsinformation, Bekendtgørelse nr. 1016 af 22. juni 2023 om skatteindberetning m.v., section 3(2): https://www.retsinformation.dk/eli/lta/2023/1016
• Retsinformation, Bekendtgørelse nr. 1158 af 9. september 2025 om ændring af bekendtgørelse om skatteindberetning m.v. (in force 1 January 2026): https://www.retsinformation.dk/eli/lta/2025/1158
• Retsinformation, Lov nr. 1781 af 29. december 2025 om ændring af ligningsloven (udvidelse af medarbejderaktieordningen for nye, mindre virksomheder): https://www.retsinformation.dk/eli/lta/2025/1781
• Retsinformation, Bekendtgørelse nr. 553 af 22. juni 2026 om ikrafttræden af lov om ændring af ligningsloven: https://www.retsinformation.dk/eli/lta/2026/553
• Retsinformation, Bekendtgørelse af lov om indskud på etableringskonto og iværksætterkonto, lovbekendtgørelse nr. 1307/2025: https://www.retsinformation.dk/eli/lta/2025/1307
• Retsinformation, Bekendtgørelse af virksomhedsskatteloven, lovbekendtgørelse nr. 1836/2021: https://www.retsinformation.dk/eli/lta/2021/1836

From the 10 November cut-off to the 20 January file

The next fixed date for securities and CPS reporters is Tuesday 10 November 2026, the last old-format production deadline, followed by the gateway user test from Friday 13 November to Thursday 10 December 2026, where the two new OBLG rejections can be seen before they bite. Interest and Pensiondiverse reporters can already validate year-end 2026 data. For the returns within section 54(1), the main year-end deadline is Wednesday 20 January 2027. That deadline does not replace the separate statutory deadlines that apply to specified filings, including the dividend reporting covered by section 54(3).

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.