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

Skattestyrelsen published the Indberetningsvejledning om Indlån 2026 (S nr. 116) on 30 September 2026, the guide that sets out how deposit reporting to Skat works for calendar year 2026. Under section 12 of the Danish Tax Reporting Act (skatteindberetningsloven), banks, lawyers and others within the Act’s territorial scope that receive or intermediate deposits are subject to annual reporting, subject to the statutory exemptions: the report covers interest and other returns, the year-end balance and the relevant account-holder information. The statutory filing deadline for the 2026 return is 20 January 2027.

Skattestyrelsen uses the records to fill in the tax information citizens see on skat.dk/tastselv, to build annual statements (årsopgørelser) and to supply other authorities, for example for calculating public benefits. The guide warns that data reported after 1 March 2027 cannot with certainty reach a citizen’s annual statement automatically. For the reporting institution, section 59 of the Act makes an intentional or grossly negligent failure to report within the deadline punishable by a fine, and the guide’s fine scale runs from DKK 5,000 for up to 1,000 records to DKK 80,000 above one million records.

Related reading: EIS Reporting in Denmark: The 1 June and 15 October Filings

Deposit reporting to Skat: dates for the 2026 income year

The calendar mixes statutory deadlines with system windows that Skattestyrelsen sets. Each entry below names its source.

• 30 September 2026: version 1.0 of the 2026 guide published.
• 5 October 2026 (Monday): Skattestyrelsen opens reporting, test and validation for year-end 2026; the XML namespace for 2026 is dated 01/01/2026 (guide section 0.1).
• 31 December 2026: reference date for the balance, for each holder’s resident or non-resident status, and for blocking accounts whose holder’s identity is not established (guide sections 1.4.2, 4.4 and 4.5.2).
• 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: when customer-due-diligence data is updated under the Danish AML Act from this date, the TIN request extends to accounts opened before 1 July 2016 (guide section 1.4.1).
• 20 January 2027 (Wednesday): statutory deadline for the year-end report and for a nil report (section 54(1) of the Act; guide sections 1.2.1 and 2). The rule that moves a Saturday or Sunday deadline to the following Monday does not come into play this year.
• 14 days after Skattestyrelsen’s response: resubmission of rejected records, a deadline Skattestyrelsen sets under section 54(6) (guide section 1.5).
• 1 March 2027: data reported after this date cannot with certainty flow automatically onto the citizen’s annual statement (guide section 2).
• Within 10 days of cessation: the year-end report for a business that stops reporting (executive order section 5; guide section 2).

Two of these dates interact in a way the guide’s deadline table makes explicit. Section 54(6) of the Act treats a rejected file as an attempted report: once Skattestyrelsen tells the institution the data has to be resubmitted because of errors, the obligation becomes a resubmission within the deadline Skattestyrelsen notifies, which the guide sets at 14 days from the response. For a single record keyed into TastSelv Erhverv, the 14 days run from the submission date (guide section 7.1).

Section 12 and the executive order behind the Indlån file

The obligation sits in section 12 of skatteindberetningsloven, consolidated as lovbekendtgørelse nr. 1059 of 21 August 2025. Section 12(1) requires banks (pengeinstitutter), lawyers and others that receive or intermediate deposits to report every year the interest and other returns paid, credited or charged to each account holder and any interest beneficiary in the previous year, the balance at the end of that year, and each holder’s ownership share of it. Section 12(2) adds the account designation, including the type of account, its currency, the identity of the holders or interest beneficiaries, and the opening date.

Section 12(3) pulls in accounts closed or transferred during the year, with the date of closure or transfer and the returns up to that point. Section 47 places the duty on natural and legal persons resident in Denmark or operating from a permanent establishment here.

The operational detail lives in the executive order on tax reporting, bekendtgørelse nr. 1016 of 22 June 2023, as amended. Section 27 extends the section 12 duty to interest that cooperatives pay on members’ claims, including member capital or guarantee capital, and to interest that insurers, the state, regions and municipalities pay on compensation. Section 27(2) puts that compensation interest into the year of payment. Section 28 requires the account currency as an ISO code, and section 4(4) requires amounts in Danish kroner.

The guide describes the practical procedure for building and filing the report, and its 2026 text is version 1.0. It states its own rank in section 0: where the guide and the legislation or Den juridiske vejledning diverge, the legislation and Den juridiske vejledning prevail.

Who files, and the registration that has to come first

The perimeter is set by activity. Section 1.1.1 of the guide applies the duty to banks, lawyers and others that receive or intermediate deposits for an open or closed circle, and lists examples beyond banking: loan-based crowdfunding platforms, gaming operators, savings associations, investment associations, and businesses that take deposits from customers, with DIY retailers (byggemarkeder) named as one. The guide tells institutions to read the term deposit broadly (section 1.1.2). An account counts whether or not it bears interest and whether the rate is positive or negative, and lawyers’ client accounts are named as deposits.

Two groups report only a narrow slice. Insurers, the state, regions and municipalities report interest on compensation payments and on payments for lost earnings, and the public bodies also report interest connected with expropriation (guide section 4.1). Interest an insurer calculates under section 24 of the Insurance Contracts Act when it pays out a compensation sum falls within section 12. Compensation paid in an employment relationship sits outside Indlån; the guide points to eIndkomst for any reporting of that interest.

Cooperatives report interest on members’ claims, including member capital or guarantee capital, as deposits under account type 12. That stream is separate from the cooperative return covered in our article on cooperative capital distributions to Skat under section 30.

Registration within eight days

Section 1(1) of the executive order requires registration no later than eight days after the reporting obligation begins. The guide dates that start to the first deposit agreement with a customer (guide section 1.3). Registration runs through form 03.047 on virk.dk, and doubt about whether the business is in scope does not relieve it of registering (executive order section 1(3)). Changes to the registered information follow the same eight-day clock (section 1(7)).

The form asks a question with consequences for the whole file: gross or net interest principle under section 12. The net principle is open only to banks, and a bank cannot be registered for both (guide sections 1.3.1 and 4.5.1.1). A business whose obligation pauses can keep its registration and file a nil report (nulindberetning) through TastSelv Erhverv by the 20 January deadline (executive order section 1(8); guide section 1.2.1). Deregistration is due within eight days after the obligation ends (guide section 1.3.3).

Accounts in scope, and the ones the return leaves out

The guide’s starting point in section 4.1 is every account that was active during the calendar year. An account closed during 2026 is still reported, with a zero balance, the closing date and the interest up to closure. For banks the scope covers demand deposits, notice and time deposits, and special forms including structured deposits and pool schemes.

Where an account can be in credit or in debit, the balance at 31 December decides whether it goes to Indlån or to the loan file, Udlån. A share savings account (aktiesparekonto) is always reported as a deposit, even with a negative balance. Children’s savings accounts and self-pension accounts opened before 2 June 1998 are reported until the year their binding period ends, after which they move to account type 13. Education and housing savings accounts carry only the calculated premium as at 31 December 1993 (guide sections 4.1 and 4.5.3).

Exclusions written into the Act and the guide

Several pension and savings arrangements are excluded from full Indlån reporting, while certain children’s savings and pre-2 June 1998 self-pension accounts remain subject to limited identification and account-number reporting. Section 50(3) of the Act takes instalment savings for pension purposes, other pension savings and index schemes out of section 12, and the guide lists ratepension, kapitalpension, aldersopsparing, index accounts and frigørelseskonti as accounts not to report (guide section 4.1.1). For children’s savings and pre-1998 self-pension accounts, section 50(3) limits the duty to identity and account number, which is why those account types carry no amounts.

Section 12(4) lets a bank skip a deposit transferred to a pooled account (samlekonto) without running interest, provided the balance at transfer did not exceed DKK 300. The duty returns if interest crediting resumes, and the accumulated interest for the gap is then reported with that year’s interest (section 12(5)). Interest penalties on notice accounts are outside the file too (guide section 4.1.1).

The tax perimeter has its own definitions. The deposits a Danish bank reports to Finanstilsynet as covered by the deposit guarantee, on the Dind tab of the KRGS reporting instructions under sections 9 and 10 of the deposit guarantee act, are defined by a different act for a different purpose; our deposit guarantee scheme explainer covers that side.

Tax-exempt customers: the 2026 guide makes documentation the test

Some holders are never reported. Section 2 of the executive order excludes the monarch and the members of the royal house it covers, with their estates. On the diplomatic side it excludes foreign missions, diplomatically notified persons, and administrative, technical and service staff who are not Danish citizens, together with household members of the diplomatic and the administrative and technical staff who are not Danish citizens; identity cards from the Ministry of Foreign Affairs document the status. Section 51(1) of the Act excludes tax-exempt institutions and state-recognised unemployment funds listed in section 3 of the Corporation Tax Act (selskabsskatteloven), and banks, pension funds, mortgage credit institutions and insurers. The guide adds that those financial firms must be under Finanstilsynet’s supervision, or their home supervisor’s if foreign (guide section 4.2.1).

The 2026 edition adds new text on how the tax-exempt carve-out works. With documentation that the customer falls within section 3 of the Corporation Tax Act, the institution does not report. Without it, the institution reports, and the guide says this applies regardless of when the account was opened. The documentation can be the institution’s registration certificate, or a confirmation from Skattestyrelsen where the certificate does not show the status.

The guide also sets the collection point. When a customer relationship is established and the bank assesses that the customer may fall within section 3, the documentation is obtained then. For older relationships the guide acknowledges that there was no instruction to collect documentation before 2024, and asks institutions without it to obtain it the next time they are in contact with the customer. On that reading, a foundation flagged as tax-exempt in a core system with no document on file is a reportable customer for 2026.

One record per account: identifiers and account periods

The data structure is RenteIndberetningIndlånStruktur, delivered as XML, with one report per account (guide section 4.3). Only fields relevant to the account are included unless a field is mandatory, and the guide states there are no new fields this year. Each report carries the 2026 reporting period and, in VirksomhedSENummer, the CVR number under which the obligation is registered (guide section 4.3.1).

KontoID and IndberetningID

KontoID is the institution’s unique identifier for the account, used for every report and correction on it. It follows the account for its whole life, including through a move to another IT system and a change of data provider (guide section 4.3.2). It is limited to 30 characters, with no spaces and none of the special characters the guide lists. Accounts created after 1 October 2021 must not contain a CPR number in KontoID, and the guide tells institutions not to correct older KontoIDs that do.

IndberetningID identifies each report and cannot be reused within the same report type. TastSelv Erhverv generates it for single entries; for files, Skattestyrelsen recommends a UUID (guide section 4.3.3). Neither identifier is shown to the customer.

Account details the customer does see

IndlånKontoNummer is the account number the customer sees in their tax information, and it should not change for a given KontoID during the year (guide section 4.4). Banks report the registration number and the IBAN as a pair: one without the other is incomplete. KontoStartDato is the date the account was opened; for a children’s savings account or self-pension account transferred from another bank it remains the original opening date, and where the date is unknown the guide prescribes 1900-01-01. The currency goes in KontoValutaKode as an ISO code.

Account periods

Each report holds at least one account period, and a new period starts whenever the ownership circle or the account type changes during the year (guide section 4.6). A move between deposit and loan status does not start a new period. The interest across all periods has to add up to the interest reported for the account, or the report is rejected (guide section 4.6.1).

The 2026 guide clarifies the edge case of a change of owner on 31 December. The account then needs periods in both years: in 2026 the outgoing owner’s period ends on 31.12.2026, and in 2027 the incoming owner’s period starts on 01.01.2027, with the original KontoStartDato kept (guide section 0.2).

Interest, balance and the field that must be left out

Amounts are reported in kroner. Øre are included only when above zero, after a decimal point, so DKK 1,125.00 can go in as 1125 and DKK 1,125.50 has to go in as 1125.50 (guide section 4.5). The guide’s error section asks institutions to reconcile reported amounts against their books and to check specifically for duplicates and for amounts reported in øre (guide section 0.3).

For foreign-currency accounts, section 4(4) of the executive order converts at the daily rate when the right to the amount was acquired, and at the 31 December rate where the year-end value is reported. The guide adds that a payment made out of a krone account can use the bank’s own daily rate, and that Danmarks Nationalbank’s middle rate applies where the institution does not convert at payment.

The interest field

The interest field carries interest and other returns paid, credited or charged in the year (guide section 4.5.1). Negative interest credited to a deposit that is not overdrawn takes a minus sign; a missing sign is read as plus. An account with no interest in the year is reported with 0.

That last rule has an exception that produces one of the errors Skattestyrelsen lists in section 0.3. For account types 8, 10 and 26 the interest amount field is left out of the record altogether, and a record that includes it, even filled with 0, fails with error 91. A mapping that writes 0 for every account with no interest will therefore fail on every share savings account, children’s savings account and pre-1998 self-pension account in the portfolio.

For negative interest at customer level, the guide accepts two methods: a separate interest account credited at customer level, or a proportional allocation at account level, where the negative interest is charged to one account with the allocation secured if the account has several owners. Where several of a customer’s accounts enter the negative-interest calculation, the allocation has to be proportional, and it does not matter which account the charge is taken from (guide section 4.5.1).

The balance field

The balance is the position at 31 December, and 0 for an account closed during the year (guide section 4.5.2). A negative balance can be reported only on a share savings account, where Indlån takes the cash balance. Structured deposits report the invested amount. Children’s savings accounts and pre-1998 self-pension accounts report no balance, and compensation interest reported by insurers and public bodies goes in with a balance of 0.

Account-type codes that change the record

The codes come from guide section 4.6, and the guide’s error list in section 0.3 adds a formatting rule: the code carries no leading zero, so a share savings account is 8 and never 08. The tax-favoured accounts under codes 17 to 29 also appear in the system covered in our EIS reporting guide, which uses its own code set; section 5 of the EIS guide has banks feed the 31 December balance to the EI-system through their Indlån reporting.

Gross or net interest: the registration choice that splits the file

The principle chosen at registration decides how an account that swings between credit and debit is reported (guide section 4.5.1.1). Under the gross principle, credit interest goes to Indlån and debit interest to Udlån, and positive balances go to Indlån while negative balances go to Udlån. Under the net principle, the bank reports the difference between debit and credit interest.

The guide’s first worked example is an overdraft facility with DKK 1,000 of credit interest, DKK 5,000 of debit interest and DKK 20,000 owed at 31 December. A gross-principle bank files two records: Indlån with interest of 1,000 and a balance of 0 under account type 13, and Udlån with interest of 5,000 and debt of 20,000 under account type 56. A net-principle bank files one Udlån record with net interest of 4,000 and debt of 20,000.

Net reporting still splits when the net interest and the balance belong to different account types. With DKK 1,000 of credit interest, DKK 5,000 of debit interest and a positive balance of DKK 20,000, the guide shows two records: Indlån with interest 0 and balance 20,000, and Udlån with interest 4,000 and balance 0. When an account moves from deposit to loan status, the guide treats it as the same account continuing, with no closure in Indlån and the original opening date carried into Udlån.

Holders, interest beneficiaries and the 31 December residence test

Every account holder goes into the record, because Skattestyrelsen divides the reported interest and balance equally between the holders reported (guide sections 4.5 and 4.7). The executive order says the same for co-owned accounts in section 6(2), as rewritten by bekendtgørelse nr. 885 of 26 June 2024 with effect from calendar year 2025. Two holders appear at 50 per cent each in their tax information. Holders with a different agreed split can ask Skattestyrelsen to change it, and jointly taxed spouses can change it themselves on the annual statement (guide section 8).

An interest beneficiary (rentenyder) is a person who receives the return on capital they do not own. The owners go on the account-holder list and the beneficiaries on a separate interest-beneficiary list, both per account period (guide sections 4.7 and 4.8).

Resident or non-resident

The holder’s status in the record turns on residence. A person resident in Denmark, or an entity established here, at 31 December 2026 is reported as resident (indlænding); everyone else is reported as non-resident (valutaudlænding). For a relationship that ended during the year, the status at termination decides. Estates and bankruptcies administered in Denmark count as resident (guide section 1.4.2).

Tax liability plays no part in that test, and the guide states that CRS and FATCA follow other rules. A customer who is tax resident elsewhere but still has a Danish residence at year-end is a resident for Indlån, while the same customer’s CRS classification follows the due-diligence rules described in our CRS reporting guide. Holders resident in Greenland are reported as non-resident, with the CPR or CVR number and country code GL. Where the customer has a CPR number but the institution has no certain knowledge of the country of residence, the holder goes in as non-resident with KontohaverIdentifikationMulig set to false and the CPR number always filled in; a person with no fixed address, such as a homeless customer, is reported as resident.

Sole traders and representatives

A sole proprietorship can be reported on the owner’s CPR number or the business’s CVR number, and the guide recommends picking one for the life of the account (guide section 4.7). A CVR number is converted to the owner’s CPR number, and the tax information then shows that the account belongs to the business. Where the record names a company chairman or administrator (VirksomhedFormandAdministrator set to true), there is no automatic pre-print on the annual statement (guide section 8). The placeholder structure KontohaverUkendt is reserved for a missing full CPR number on a resident or, in a case the guide says should not occur, a missing name for a non-resident.

Identification data, TIN and blocked accounts

Section 3(1) of the executive order sets the identification data: name, address (with home country for a foreign address) and CPR number, falling back to CVR number, then SE number, then date of birth. Section 3(2) adds the identification number issued under the rules of the holder’s state of residence, or birth date, birthplace and country of birth where there is none; the guide applies this to holders living abroad (guide section 1.4.1). For companies, foundations, associations and estates with no number, the data of the chairman or another authorised representative is given (section 3(3)).

The account cannot be opened until the data is provided. Section 52(2), no. 5, of the Act bars opening an account reportable under section 12 where identification is missing, and the guide repeats the rule in section 1.4.1. Customers must notify changes within one month (executive order section 3(5)), and identity is verified under chapter 3 of the AML Act.

What changes for TIN

Two TIN passages in the 2026 guide are new. When a customer moves abroad, the guide requires reasonable efforts to obtain a TIN from the new country of residence, or birth date, birthplace and country of birth (guide section 1.4.1). From 1 January 2027, when customer information is updated under the AML Act’s customer-due-diligence rules, the institution also requests a TIN for accounts opened before 1 July 2016. The guide ties the request to that due-diligence update.

The TIN reported is the one for the country of residence at 31 December. The guide now notes that residence and tax country usually coincide, and that a TIN issued by the country of tax residence is acceptable where the residence country issues none (guide section 1.4.2).

The validation side is spelled out in section 0.3. For a non-resident individual on an account opened after 1 January 2004 and before 1 July 2016, error 50 and advis 8 flag a record with neither a TIN nor birth details. For accounts opened from 30 June 2016, advis 2 flags a missing TIN where the residence country issues one, and error 141 rejects a TIN identical to the CPR number. A CPR number serves as the foreign identifier only for Greenland residents.

Blocking and forfeiture

Section 53 of the Act lets Skattestyrelsen bar dispositions over accounts where the institution lacks certain knowledge of the holder’s identity, for six months and a further six months, a combined period the guide describes as 12 months. After a public notice in Statstidende with a 12-month deadline, unidentified funds can be forfeited to the State. Skattestyrelsen runs blocking as a continuous annual process, and the guide requires blocking as at 31 December without further notice (guide section 1.4.3).

In the file this becomes IndlånKontoInddragelseSpærringDato. Where the institution does not have certain knowledge of the holder’s identity on 31 December 2026, the account is blocked as at that date and the field carries 2026-12-31; the field is included only when none of the holders can be identified (guide section 4.4). The 2026 guide also clarifies error 58, raised when a CVR or SE number ceased more than a year before the income year: the founders are reported (for a ceased company, at least one founder, marked as chairman), and where their details cannot be obtained despite reasonable efforts, error 58 stays on the record until they are known or the account ends.

Filing channels, test runs and what a valid status means

Skattestyrelsen offers three channels (guide section 3.2). The REST API web service takes single XML reports and zipped batches system to system. The FTPs gateway takes zipped batches of XML files over an encrypted connection. TastSelv Erhverv takes single entries keyed on the web and file uploads, which suits low volumes.

The guide notes that an institution can deliver the large first submission through the API or the gateway and make corrections as single entries in TastSelv Erhverv. Whoever submits needs a MitID certificate, and a bureau delivering through the FTPs gateway for others uses the data-handler arrangement in the technical guide (guide section 3.3).

The TFE test environment is open for system-to-system testing all year, and files can also be validated against production data in production (guide section 5). The response file then gives every report a status, and the status decides the next step (guide section 7).

A valid status means the submission has passed the applicable technical and correction-principle checks, but it does not guarantee that the data appears in the customer’s tax information (guide sections 7 and 8). A FejlKonto report is valid and still invisible to the customer, and the guide cites a non-resident without a CPR number as a case where even an approved report may not be displayed.

For a valid report, changes follow the correction principle on the existing report. For FejlFormat or FejlIndberetning, the institution files a new initial report where there is no existing valid report on the account. Where a valid report already exists and a later attempted correction receives FejlFormat or FejlIndberetning, the correction instead refers to the existing valid IndberetningID in RettelseID (guide section 7.1). Advis lists on approved reports still need reading, according to section 0.3.

Corrections, late data and closing down

Records with status FejlFormat, FejlIndberetning, FejlKonto or FejlKontohaver are corrected or resubmitted within 14 days of the response file (guide section 7.1). Errors found in an approved report are corrected as soon as they are discovered, which the 2026 guide spells out as without undue delay; a recalculation of wrongly charged customer interest is the guide’s example (guide sections 2 and 7.1).

Section 7.1 also describes a sequencing trap. The interest system always uses the latest submission on an account as its reference, in search results and in the reconciliation report on TastSelv Erhverv. If a FejlFormat or FejlIndberetning file lands on top of a valid report, the latest submission is now the failed one, and the guide asks the institution to resubmit, even an identical file, so that the latest submission is valid again. Where an Indlån correction also changes data already sent under CRS or FATCA, those reports need correcting as well (guide section 7); the FATCA side is covered in our FATCA reporting guide.

Late data reaches citizens through a different route once the first annual statements exist. The guide notes that new data reported after the first annual statement often produces an automatic proposal to change it (guide section 8), and asks for advance notice where a missed deadline leaves a large number of records to report after the annual statements have been produced (guide section 2). Section 54(7) of the Act lets Skattestyrelsen order a business that reports late to notify the people concerned. An invalidated report that had been approved stays visible in tax information, with the amounts shown with a minus sign (guide section 8).

Cessation and mergers

A business that stops reports the year of cessation within 10 days (executive order section 5; guide section 2). Bulk delivery uses the XML structure valid at the cessation date, so a business that ceases on 2 May uses the previous year’s structure with the current year in the income-year field. A merger works differently: the continuing institution takes over the ceased institution’s activities, obligations and rights, including its earlier reports, and reports on the ordinary deadline. The guide recommends that it reports the deposits for the whole year in the year-end report (guide sections 0.2 and 1.3.3).

Penalties, retention and reconciliation

Section 59 of the Act punishes with a fine an institution that intentionally or with gross negligence fails to report by the section 54 deadlines, fails to resubmit by the deadline Skattestyrelsen sets under section 54(6), or fails to keep or hand over material under section 56. Section 58 covers intentionally false, misleading or incomplete information that leads to too low a tax assessment, with a fine or imprisonment of up to one year and six months unless a higher penalty applies under section 289 of the Criminal Code; a grossly negligent breach is fined (section 58(2)). The guide states that responsibility stays with the reporting institution when employees or an external provider do the reporting (guide section 1.7).

The guide’s fine scale by number of records:

• DKK 5,000: 1 to 1,000 records.
• DKK 10,000: over 1,000 to 10,000.
• DKK 20,000: over 10,000 to 100,000.
• DKK 40,000: over 100,000 to 1,000,000.
• DKK 80,000: over 1,000,000.

Separately, section 57 lets Skattestyrelsen order a late reporter to report within a set deadline under daily coercive fines (tvangsbøder) until it complies, and the guide states that under current practice those run at a minimum of DKK 1,000 a day. The guide adds that the fine level can be adjusted up or down for aggravating or mitigating circumstances, with a reference to chapter 10 of the Criminal Code (guide section 1.7).

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). Where the reporting institution keeps books and the reported data forms part of its accounts, the same subsection requires the accounts to be organised so the reported figures can be reconciled with them.

Frequently Asked Questions

A customer’s identity was stolen and an account was opened in their name. Is that account reported?

No. The guide says accounts opened through the unlawful use of another person’s data are not reported, and that a report already filed on such an account is invalidated afterwards (guide section 0.2).

A sole trader converted the business into a company in 2026 under the tax-free transformation rules, with retroactive effect to 1 January. Which number goes on the account?

The new CVR number, for the whole year. The account period start date is set to 01.01.2026, otherwise the record fails with error 54, and the original KontoStartDato is kept (guide section 0.2).

An account was closed by mistake in June and reopened in September. Does it get a new KontoID?

No. The guide asks for the same KontoID, IndlånKontoNummer and KontoStartDato, and no separate account period for the closed interval unless the ownership also changed (guide section 0.2).

A refugee’s deposit account is overdrawn at 31 December. Where does it go?

The guide allows two methods: report the negative interest in Indlån with the negative balance shown as 0, or report the account in Udlån with an unknown account holder (guide section 0.2).

Who reports interest on a law firm’s client accounts?

On a pooled client account, the lawyer reports any interest to the individual clients with money on it. A separate client bank account is reported by the bank even when the balance at 31 December is 0, and for a separate account opened in the name of an estate the bank reports the full interest. Where a bank opens a client account for a law firm run as a sole proprietorship, the guide recommends opening it on the lawyer’s CPR number and reporting it with VirksomhedFormandAdministrator set to true; a report on the CVR number is converted to the lawyer’s CPR number, and the interest and balance are then wrongly pre-printed on the lawyer’s own annual statement (guide section 0.2).

A company customer closed down two years ago and its NemKonto is still open. What happens to the record?

NemKonti of a closed business are closed after 360 days. Records under account type 13 in Indlån and type 56 in Udlån are rejected from the second year after the closure, and Skattestyrelsen sends an advis that the business is deregistered in the closure year and the year after (guide section 0.2).

Do creditor-protected accounts need a flag in the file?

No. They are reported like any other deposit, and the structure has no marking for them (guide section 0.2).

Related Articles

• EIS Reporting in Denmark: The 1 June and 15 October Filings: how banks report deposits and withdrawals on establishment and equalisation accounts to the EI-system.
• Cooperative Capital Distributions to Skat: The Section 30 Filing: the separate Skat return Danish cooperatives file on distributions to members.
• Liquidation Proceeds Reporting to Skat: Section 28a for Danish Funds: another eKapital stream under skatteindberetningsloven, for proceeds on fund liquidations.
• CRS Reporting in Luxembourg: the OECD Common Reporting Standard from the filing side, with its tax-residence classification.
• FATCA Reporting in Luxembourg: account reporting on US persons, the other regime an Indlån correction can touch.

Key Takeaways

• Before the first production run, match every customer coded as tax-exempt under section 3 of the Corporation Tax Act to a registration certificate or Skattestyrelsen confirmation; an unmatched customer belongs in the 2026 file.
• The zero-interest default needs an account-type branch: types 8, 10 and 26 are the only codes where a blanket 0 breaks the record.
• Taking the blocking date, the resident or non-resident split and the balance from one 31 December snapshot keeps the three consistent within each record.
• TIN requests for accounts opened before July 2016 belong in the due-diligence refresh workflow, ready for the first refreshes of 2027.
• A core-banking migration has to carry KontoID across unchanged, since every later correction is matched on it.
• Response files need an owner and a 14-day clock from receipt, plus a check that the latest submission on each account is a valid one.
• The gross or net choice on the 03.047 registration should match how the core system actually splits overdraft interest between Indlån and Udlån.
• Keep the evidence behind each excluded account with the filed data; section 56(1) covers the information used to decide reportability.

Sources and References

• Skattestyrelsen, Indberetningsvejledning om Indlån 2026, S nr. 116, version 1.0, published 30 September 2026 (table of contents and version history): https://info.skat.dk/data.aspx?oid=2287949&vid=221427
• Indlån 2026 guide, section 0 Indledning: https://info.skat.dk/data.aspx?oid=2287950&vid=221427
• Indlån 2026 guide, section 0.1 Hvad er nyt for 2026: https://info.skat.dk/data.aspx?oid=2287951&vid=221427
• Indlån 2026 guide, section 0.2 Særlige situationer: https://info.skat.dk/data.aspx?oid=2287952&vid=221427
• Indlån 2026 guide, section 0.3 Særlige fejl-situationer: https://info.skat.dk/data.aspx?oid=2287953&vid=221427
• Indlån 2026 guide, sections 1.1, 1.1.1 and 1.1.2 (scope, who reports, definition of deposit): https://info.skat.dk/data.aspx?oid=2287955&vid=221427, https://info.skat.dk/data.aspx?oid=2287956&vid=221427 and https://info.skat.dk/data.aspx?oid=2287957&vid=221427
• Indlån 2026 guide, section 1.2.1 Nulindberetning: https://info.skat.dk/data.aspx?oid=2287959&vid=221427
• Indlån 2026 guide, sections 1.3, 1.3.1 and 1.3.3 (registration and deregistration): https://info.skat.dk/data.aspx?oid=2287960&vid=221427, https://info.skat.dk/data.aspx?oid=2287961&vid=221427 and https://info.skat.dk/data.aspx?oid=2462519&vid=221427
• Indlån 2026 guide, sections 1.4.1, 1.4.2 and 1.4.3 (identification, TIN, blocking): https://info.skat.dk/data.aspx?oid=2287964&vid=221427, https://info.skat.dk/data.aspx?oid=2291024&vid=221427 and https://info.skat.dk/data.aspx?oid=2291025&vid=221427
• Indlån 2026 guide, sections 1.5, 1.6 and 1.7 (resubmission, retention, responsibility and fines): https://info.skat.dk/data.aspx?oid=2287966&vid=221427, https://info.skat.dk/data.aspx?oid=2287967&vid=221427 and https://info.skat.dk/data.aspx?oid=2287968&vid=221427
• Indlån 2026 guide, section 2 Tidsfrister: https://info.skat.dk/data.aspx?oid=2287970&vid=221427
• Indlån 2026 guide, sections 3.2 and 3.3 (channels and certificates): https://info.skat.dk/data.aspx?oid=2287973&vid=221427 and https://info.skat.dk/data.aspx?oid=2287974&vid=221427
• Indlån 2026 guide, sections 4.1, 4.1.1, 4.2 and 4.2.1 (accounts and holders in and out of scope): https://info.skat.dk/data.aspx?oid=2287976&vid=221427, https://info.skat.dk/data.aspx?oid=2287977&vid=221427, https://info.skat.dk/data.aspx?oid=2287978&vid=221427 and https://info.skat.dk/data.aspx?oid=2291033&vid=221427
• Indlån 2026 guide, sections 4.3, 4.3.1, 4.3.2, 4.3.3 and 4.4 (data structure, identifiers, account details): https://info.skat.dk/data.aspx?oid=2287979&vid=221427, https://info.skat.dk/data.aspx?oid=2287980&vid=221427, https://info.skat.dk/data.aspx?oid=2287981&vid=221427, https://info.skat.dk/data.aspx?oid=2287982&vid=221427 and https://info.skat.dk/data.aspx?oid=2287984&vid=221427
• Indlån 2026 guide, sections 4.5, 4.5.1, 4.5.1.1, 4.5.2 and 4.5.3 (amounts, interest, gross and net principle, balance, premium): https://info.skat.dk/data.aspx?oid=2287985&vid=221427, https://info.skat.dk/data.aspx?oid=2287986&vid=221427, https://info.skat.dk/data.aspx?oid=2287987&vid=221427, https://info.skat.dk/data.aspx?oid=2287988&vid=221427 and https://info.skat.dk/data.aspx?oid=2287989&vid=221427
• Indlån 2026 guide, sections 4.6, 4.6.1, 4.7, 4.7.2 and 4.8 (account periods, account types, holders, interest beneficiaries): https://info.skat.dk/data.aspx?oid=2287990&vid=221427, https://info.skat.dk/data.aspx?oid=2287991&vid=221427, https://info.skat.dk/data.aspx?oid=2287993&vid=221427, https://info.skat.dk/data.aspx?oid=2287995&vid=221427 and https://info.skat.dk/data.aspx?oid=2291036&vid=221427
• Indlån 2026 guide, sections 5, 7, 7.1 and 8 (testing, statuses, corrections, publication in tax information): https://info.skat.dk/data.aspx?oid=2287996&vid=221427, https://info.skat.dk/data.aspx?oid=2288001&vid=221427, https://info.skat.dk/data.aspx?oid=2288002&vid=221427 and https://info.skat.dk/data.aspx?oid=2288003&vid=221427
• Skattestyrelsen, Indberetningsvejledning til etableringskontosystemet (EIS), section 5 Kontomarkeringer i Indlån: https://info.skat.dk/data.aspx?oid=170666&vid=221442
• Retsinformation, Bekendtgørelse af skatteindberetningsloven, lovbekendtgørelse nr. 1059 af 21. august 2025, sections 12, 47, 50, 51, 52, 53, 54, 56, 57, 58 and 59: https://www.retsinformation.dk/eli/lta/2025/1059
• Retsinformation, Bekendtgørelse nr. 1016 af 22. juni 2023 om skatteindberetning m.v., sections 1, 2, 3, 4, 5, 27 and 28: 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 on co-owned assets, effect from calendar year 2025): https://www.retsinformation.dk/eli/lta/2024/885
• 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
• Finanstilsynet, KRGS reporting instructions 2026 (Dind tab, deposits covered by the deposit guarantee): https://cdn.finanstilsynet.dk/finanstilsynet/Media/639114110883645756/krgs-vejledning-202641-uden-synlige.pdf

From the 2026 build cycle to the 20 January filing

The 2026 cycle has two dates that matter more than the rest. Reporting, testing and validation for year-end 2026 open on Monday 5 October 2026 (guide section 0.1), which leaves the autumn to run the 2026 specification, the zero-interest logic and the tax-exempt documentation check through TFE before production. The year-end Indlån file for calendar year 2026, with balances at 31 December 2026 and every holder identified, is due with Skattestyrelsen by Wednesday 20 January 2027.

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.