KSERV Reporting in Denmark: The Twice-Yearly NPL Transfer Return

ByRegReportingDesk
RegReportingDesk card: Finanstilsynet, Danish Financial Supervisory Authority, Denmark

KSERV reporting starts when a Danish bank sells a non-performing loan to a buyer that is not itself a credit institution. Sections 15 and 19 of the Danish act on credit servicers and credit purchasers (Act no. 1534 of 12 December 2023, in force since 30 December 2023) require the selling credit institution, and any credit purchaser that later sells the rights on, to inform Finanstilsynet twice a year. Finanstilsynet collects the information in FIONA Online through the KSERV schema in the KRED reporting family, under the heading “overførsel af en kreditgivers rettigheder” (transfer of a creditor’s rights).

The return itself is small: four tabs, one row per buyer, eleven fields per row. The obligation around it is wide. No size threshold applies, a nil return is due for a half-year without sales, and once an institution has transferred anything, a cumulative stock figure has to roll forward in every later filing. Section 41(2) of the act makes a breach of section 15(1) to (3) or of section 19 punishable by a fine.

Related reading: KGFS Reporting in Denmark: New Home Loans to High-Debt Borrowers

The KSERV calendar, as set in Finanstilsynet’s January 2025 guidance and repeated in its deadline list for electronic reporting:

  • Reference date 30 June: due by 11 August.
  • Reference date 31 December: due by 11 February.
  • First filing: both halves of 2024, due by 11 February 2025.
  • Transfers made by a credit purchaser before 30 December 2023: outside the act (section 42(3)).
  • Quarterly figures: only when Finanstilsynet requests them (sections 15(3) and 19(3)).

KSERV rests on Act no. 1534 of 12 December 2023 on credit servicers and credit purchasers (lov om kreditservicevirksomheder og kreditkøbere). The act’s footnote states that it implements Directive (EU) 2021/2167 of 24 November 2021 on credit servicers and credit purchasers, the EU’s NPL directive. The consolidated legislative text is LBK no. 1439 of 18 November 2025. Act no. 1638 of 16 December 2025 subsequently repealed section 21(7) and amended section 41(1), and section 13 of Act no. 764 of 8 September 2026, in force since 15 September 2026, inserted a new section 35(2) on passing confidential information to the police. None of the amending acts identified in the changes section below altered the KSERV reporting provisions in sections 15 and 19.

Two provisions create the return, one for each type of seller:

  • Section 15(2) obliges credit institutions that transfer a creditor’s rights under a non-performing credit agreement, or the agreement itself, to a credit purchaser to tell Finanstilsynet twice a year: (1) the legal entity identifier (LEI) of the purchaser, or of its representative appointed under section 18, and, where no LEI exists, the alternative identity and address information specified in section 15(2)(1); (2) the aggregate outstanding amount of the rights transferred; (3) the number and size of the rights transferred; and (4) whether the transfer includes agreements concluded with consumers, and any types of assets that serve as collateral for the non-performing credit agreements. Section 15(3) lets Finanstilsynet require the same information quarterly when it considers that necessary.
  • Section 19(1) and (2) put the same twice-yearly duty on a credit purchaser, or its representative, that transfers the rights on to a new credit purchaser, with the new purchaser’s LEI at the head of the list. Section 19(3) carries the quarterly option.

Those items follow Articles 15(2) to (4) and 20(1) to (3) of the directive closely. The act fixes the content and the twice-yearly rhythm. The reference dates, the 11 February and 11 August deadlines, the nil-return rule and the template design come from Finanstilsynet’s guidance on reporting transfers of a creditor’s rights and the schema files on its KSERV page. The guidance cites sections 15(2) to (4) and 19 of the act directly; neither it nor the KSERV page refers to an executive order.

Section 15(4) adds a cross-border layer. It applies subsections (2) and (3) correspondingly when Finanstilsynet acts as host-state authority, and it requires Finanstilsynet to pass what it receives to the authorities of the purchaser’s home state as quickly as possible. Finanstilsynet’s page on credit servicers names branches of foreign credit institutions among the institutions that report, and its FIONA Online index lists KSERV for them.

The Act entered into force on 30 December 2023 (section 42(1)), and section 42(3) provides that the Act does not apply to a credit purchaser’s transfers made before 30 December 2023. The January 2025 guidance linked from the KSERV page says instead that the act entered into force on 12 December 2023, the date it was given, and that transfers of rights made before 1 January 2024 are not to be reported. The statute and the guidance therefore draw the cut-off at different dates, and the guidance states its line in the Penge1 and Kober1 paragraphs.

Who must report KSERV: selling banks, foreign branches and credit purchasers

KSERV has two filer roles, and the role decides the tabs.

  • A credit institution that transfers non-performing rights to a credit purchaser reports on Penge1 and Penge2. The workbook labels both “Indberettes af pengeinstitutter”, reported by banks.
  • A credit purchaser that sells rights on to a new credit purchaser, or its representative, reports on Kober1 and Kober2, labelled “Indberettes af kreditkøber ved videresalg”, reported by the credit purchaser on resale.

Finanstilsynet’s FIONA Online index lists KSERV under three filer groups: banks (pengeinstitutter), branches of foreign credit institutions, and credit purchasers, which the index labels “Kreditkøbere (kreditservicevirksomheder)”. The list for mortgage banks (realkreditinstitutter) does not include KSERV, and the deadline list tags the KSERV row “(penge)” in its table for banks and mortgage banks. The act defines a credit institution by reference to section 5(1)(2) of the Danish Financial Business Act, and the KSERV documents do not say how a mortgage bank that sells a non-performing loan should report. A mortgage bank planning such a sale has a question to put to Finanstilsynet before the half-year closes.

What counts as a reportable transfer

Three provisions decide whether a sale produces a KSERV row. Section 2 defines a credit purchaser as any natural or legal person other than a credit institution that buys a creditor’s rights under a non-performing credit agreement, or the agreement itself, in the course of its business. It defines a non-performing credit agreement as one classified as a non-performing exposure under Article 47a of the Capital Requirements Regulation. And section 1(3) takes outside the act both the purchase of such rights by a credit institution established in the EU and rights under agreements that no EU credit institution issued, unless those rights or that agreement have been replaced by an agreement issued by an EU credit institution.

Read together with the guidance, those rules produce three non-examples. A sale of non-performing loans to a buyer that is itself a credit institution within the act’s definition creates no KSERV row, because section 2 excludes credit institutions from the credit purchaser definition. A sale of performing loans falls outside the return, because the trigger is classification as non-performing under Article 47a. And the guidance excludes arrangements in which a bank keeps ownership of the rights and only uses an external firm to collect. Banks already classify non-performing exposures for supervisory reporting, as covered in our FINREP reporting guide; where that classification follows Article 47a, it is the natural starting point for the KSERV population.

Credit purchasers, servicers and third-country buyers

On the Kober side the filer can be a credit servicer. Section 16(3) makes the servicer or other entity appointed under section 16(1) or (2) fulfil the credit purchaser’s obligations under sections 17 and 19 on the purchaser’s behalf. Where no servicer or other entity has been appointed, those obligations stay with the purchaser or its representative. The KSERV page matches that allocation: it describes the schema as used by credit servicers and reported by banks and credit purchasers.

A purchaser not domiciled in the EU that buys rights under an agreement issued by a Danish credit institution must appoint an EU representative under section 18(1), and section 18(2) makes the representative responsible for all of the purchaser’s obligations under the act. On the selling bank’s side, Penge2 field 1 accepts the LEI of the purchaser or of its representative.

Consolidation and thresholds are the remaining scope questions, and the documents answer only one of them. The act places the duty on each credit institution that transfers, and neither the guidance nor the workbook mentions group-level filing. Neither the act, the guidance nor the deadline list sets a size or activity threshold.

What the report contains: the Penge and Kober tabs, field by field

The KSERV workbook for period 202421 has four tabs in two mirrored pairs. Penge1 and Kober1 carry a single stock figure. Penge2 and Kober2 carry the period’s transfers, one repeating row per buyer, closed by a totals row headed “I alt for perioden”. The field numbers below follow Finanstilsynet’s guidance. Implementations should take XML element names and other technical identifiers directly from the current workbook, XML example and XSD published on the KSERV page.

Penge1 and Kober1: the cumulative stock

The single field holds the total outstanding amount, measured at the time of each transfer, of every transfer the filer has made in earlier periods plus the current one. It is stated at the end of the period, in DKK, rounded to whole kroner. A filer that has transferred rights in any earlier period reports the figure every half-year, even when nothing changed.

The guidance linked from Finanstilsynet’s KSERV page (the January 2025 PDF) says the amount for the period’s transfers is the one “angives i felt 5 under fanen Kober2” (stated in field 5 under the Kober2 tab). A bank files no Kober2 row, and the period amount a bank reports sits in field 5 of Penge2. Finanstilsynet’s error-check list points the same way: its control KSERV_Penge1_sum_23 builds the Penge1 figure from the previous period’s stock and the Penge2 total. My reading is that the Kober2 reference in the Penge1 paragraph is a slip in the guidance, and a roll-forward built from the guidance text alone is worth confirming with Finanstilsynet.

Penge2 and Kober2: one row per buyer

Each row covers the transfers to one buyer during the half-year. Kober2 uses the same layout, with the new credit purchaser in place of the credit purchaser.

Field Content Format
1 LEI of the purchaser or of its representative 20 characters, letters and digits
2 Only when no LEI can be given: name and CVR numbers of the purchaser, or of its executive and board members and the holders of qualifying holdings Text
3 Only when no LEI can be given: address of the purchaser or its representative Text
4 Number of rights or agreements transferred in the period Count
5 Total size of the rights transferred in the period DKK, whole kroner
6 Of field 4, the number concluded with consumers Count, never above field 4
7 Of field 5, the size concluded with consumers DKK, never above field 5
8 to 11 Collateral among the consumer agreements: car, home, other collateral, no collateral “Ja” or “Nej” in each

Two conventions run across the tab. Amounts are the amounts at the time of transfer, “på overdragelsestidspunktet”. Rights denominated in a foreign currency are converted to DKK at the spot rate at the end of the period being reported.

The four collateral flags carry the most rules. They describe only the consumer agreements in the row, and several can be “Ja” at once: a buyer that took consumer car loans and home-secured consumer loans gets “Ja” for car and for home collateral. The guidance says fields 8 to 11 describe collateral for consumer agreements and are reported as “Ja” or “Nej”. The workbook header for the flags covers the case the guidance leaves out: where no non-performing consumer agreements were transferred, “Ja” is entered under no collateral (“Ingen sikkerhedsstillelse”) and the other three flags are filled as “Nej”.

An inconsistency sits in the guidance’s closing line for each row tab, which says fields 1 to 8 are repeated for each buyer while describing fields 8 to 11 as the four flags. The workbook row carries all eleven fields.

KSERV reporting deadlines and reference dates on a fixed half-year calendar

KSERV runs on two reference dates, 30 June and 31 December, and the guidance sets the deadlines at 11 August and 11 February respectively. Finanstilsynet’s deadline list for electronic reporting repeats the same pair for each of the three filer groups. The half-year now closing is therefore due on the next 11 August or 11 February, whichever follows its reference date, and the next reference date is always whichever of 30 June or 31 December comes first.

The first filing was a double one. The guidance set the first report to cover both the first and the second half of 2024, with a single deadline of 11 February 2025; the semi-annual rhythm applies from then on. The nil-return rule keeps every in-scope filer on that rhythm whether or not it sold anything: “Hvis et kreditinstitut eller en kreditkøber ikke har overført rettigheder, skal blanketten stadig indberettes” (if a credit institution or credit purchaser has not transferred rights, the form must still be filed), and Finanstilsynet treats that filing as a nil report.

Quarterly reporting exists only on request. Sections 15(3) and 19(3) let Finanstilsynet require the information quarterly whenever it considers that necessary, and the directive’s matching articles give the monitoring of a high number of transfers during a crisis period as an example. Neither the guidance nor the deadline list publishes quarterly dates, so the timetable would arrive with the request.

One calendar point is left open: neither the guidance nor the deadline list says what happens when 11 February or 11 August falls on a weekend or public holiday.

Submission through FIONA Online: the KRED_KSERV XML file

KSERV goes to Finanstilsynet through FIONA Online, the reporting system Finanstilsynet runs jointly with Danmarks Nationalbank. The deadline list separates EBA returns, sent through e-Reg, from national returns sent through FIONA Online, and KSERV sits in the national group. The own funds return formerly filed as KOFS now appears among the e-Reg returns, a move traced in our KOFS own funds reporting guide; KSERV stays in FIONA.

Access requires a FIONA user, and Finanstilsynet’s FIONA pages explain how to create one. Its FIONA index says the forms there are used both to report data and to correct errors. The KSERV page offers the files a system build needs: the workbook, the guidance, the error-check list, an XML example and the XSD, all listed beneath the page’s line “Indberetning fra perioden 202421” (reporting from period 202421).

The KSERV documents say nothing about file naming or about replacing a filing that has already been accepted; the FIONA index’s statement that the forms correct errors is the only pointer. The KSERV page sends technical questions to the FIONA service desk at Danmarks Nationalbank and content questions to Finanstilsynet.

Validation: the separate KSERV error-check workbook

Finanstilsynet publishes a separate error-check workbook for KSERV from period 202421. The current validation inventory and formulas should be taken directly from that workbook before implementation.

The guidance and the act do not themselves list the validation rules, and the documents reviewed here do not say whether any check is a warning rather than a blocking error, or whether a tolerance applies to the sums.

Caveats and interactions: data templates, penalties and the host-state route

KSERV is easy to confuse with the data set a bank hands to prospective buyers. Section 15(1) obliges a credit institution to give a potential purchaser the information needed to assess the rights and any collateral, and Finanstilsynet’s page on credit servicers points to Commission Implementing Regulation (EU) 2023/2083, the implementing technical standards for data templates, for that exchange; Article 16 of the directive mandated those templates for the Article 15(1) information. The templates travel from seller to buyer before the sale. KSERV travels from seller to supervisor after it, aggregated per buyer. Both draw on the same loans, and KSERV needs only counts, sizes and four flags from them.

Proportionality is minimal. The act and the guidance set no threshold, exemption or simplified version, and the one discretion runs the other way, with Finanstilsynet able to demand quarterly figures. Recital 37 of the directive asks competent authorities to take account of information already available to them, to avoid duplication, but the Danish documents do not turn that into a carve-out for KSERV.

The penalty clause is specific. Section 41(2) of the consolidated act lists breaches of section 15(1) to (3) and of section 19, among others, as punishable by a fine. Section 41(5) allows criminal liability for companies and other legal persons under chapter 5 of the Danish Criminal Code, and section 41(6) sets a five-year limitation period. The nil return, by contrast, is a requirement of the guidance; the act does not mention it.

Cross-border sales add a second audience for the data. Finanstilsynet forwards section 15 information to the purchaser’s home-state authority under section 15(4), and Article 20(3) of the directive has the competent authority receiving a credit purchaser’s report pass it to the host state and to the new purchaser’s home state. For a cross-border sale, the KSERV row is the data another supervisor receives.

Section 17 creates two neighbouring duties that sit outside KSERV: the purchaser or its representative must tell Finanstilsynet which servicer it has appointed, by the day servicing starts, and must report a change of servicer no later than the date of the change. The KSERV documents do not route those notifications through the KSERV schema.

Changes to KSERV: the 202421 schema set and the amending acts

KSERV has changed little since launch, and the record is short:

  • 12 December 2023: Act no. 1534 given; published in Lovtidende on 13 December 2023.
  • 30 December 2023: the Act entered into force (section 42(1)). The January 2025 KSERV guidance linked from the KSERV page states that the act entered into force on 12 December 2023 and that transfers made before 1 January 2024 are not to be reported.
  • 1 January 2025: Act no. 1666 of 30 December 2024 takes effect; its amendment to the credit servicers act concerns the first sentences of section 7(2) and 7(5), the fit-and-proper rules.
  • January 2025: the guidance version on the KSERV page, dated January 2025 in its file name.
  • 11 February 2025: first KSERV deadline, covering both halves of 2024.
  • 25 February 2025: KSERV page last updated, listing the 202421 workbook, error checks, XML example and XSD.
  • 1 July 2025: Act no. 712 of 20 June 2025 takes effect; its amendment concerns sections 3(2)(4), 5(1)(6) to (9), 7a and 41(2), and the change to section 41(2) adds section 7a to the provisions punishable by fine.
  • 18 November 2025: consolidated act LBK no. 1439 issued; published on 3 December 2025.
  • 1 January 2026: Act no. 1638 of 16 December 2025 takes effect; it repealed section 21(7) and amended section 41(1), and did not amend sections 15 or 19.
  • 15 September 2026: Act no. 764 of 8 September 2026 takes effect; its section 13 inserts a new section 35(2), under which the confidentiality duty in section 32(1) does not prevent confidential information being passed to the police where relevant to the tasks of Finanstilsynet or the police, and it did not amend sections 15 or 19.

Finanstilsynet’s current KSERV page continues to publish the technical files for reporting from period 202421. The KSERV page states the period from which the current files apply (“Indberetning fra perioden 202421”) and carries a last-updated stamp. Both are the signals to check before each half-year close.

Frequently Asked Questions

A non-EU fund buys our non-performing portfolio through an EU representative. Whose LEI goes in Penge2 field 1?

Either is permitted. Section 15(2)(1) accepts the LEI of the credit purchaser or the LEI of its representative appointed under section 18, and the workbook header for field 1 says the same. Fields 2 and 3 are filled only when no LEI can be given. Using one identifier for that buyer in every period keeps its rows comparable from filing to filing.

Part of the consumer book we sold to one buyer was secured on homes and part was unsecured. How do we set the flags?

Home collateral “Ja”; car, other collateral and no collateral “Nej”. Finanstilsynet’s guidance allows several of fields 8 to 11 to be selected at once, but its error-check list limits the no-collateral flag: controls KSERV_Penge2_sum_8 and KSERV_Kober2_sum_18 require car, home and other collateral to be “Nej” whenever no collateral is “Ja”. A row with both home and no collateral set to “Ja” therefore fails the check. On my reading of “eventuelle typer af aktiver” (any types of assets), the wording of section 15(2)(4) of the act and of the workbook’s flag header, one home-secured consumer loan in the row is enough for the home flag to be “Ja”; the share of each type plays no part.

The sale was signed on 20 December and the rights passed on 10 January. Which half-year reports it?

The guidance measures amounts at the time of transfer, “på overdragelsestidspunktet”, and does not address signing and completion falling in different periods. My reading is that the date the rights pass governs, which puts this sale in the January to June half-year. With the documents silent, the reasoning belongs in the reporting file in case Finanstilsynet asks.

A credit purchaser that bought from a Danish bank resells part of the book to an EU bank. Is that a Kober2 row?

Section 19 applies when a credit purchaser transfers rights to a new credit purchaser, and section 2 defines a credit purchaser as a person other than a credit institution. An EU bank buying the rights is therefore not a new credit purchaser, and section 1(3)(2) takes its purchase outside the act. My reading is that the resale produces no Kober2 row. The guidance does not discuss the case, so it is one to confirm with Finanstilsynet.

Do we report the price we received?

Neither the act nor the workbook asks for the consideration. Fields 5 and 7 hold the size of the rights transferred, measured at the time of transfer, and the stock fields hold the outstanding amount (“udestående beløb”). The documents do not define “size” further, and reading it as the claim against the borrowers matches the outstanding-amount wording of the stock fields better than reading it as the price.

What does a nil return look like in the XML?

The documents do not specify it. Finanstilsynet’s page on credit servicers says to report 0 when nothing was transferred, and the guidance says the form must still be filed. The accessible guidance does not establish the corresponding XML structure. The current XML example or XSD, or the FIONA service desk, should therefore be used to determine the required nil-file representation.

Key Takeaways

  • Map each planned NPL sale to a filer role before signing: a sale to a non-bank buyer creates a Penge2 row, while a sale to a credit institution within the act’s definition creates none.
  • Collect the buyer’s 20-character LEI, or its EU representative’s, as a closing condition; without one, the file needs the name and CVR numbers of the buyer, or of its executive and board members and qualifying holders, and an address.
  • Keep a transfer ledger that records each transfer at its amount on the transfer date, converting foreign-currency rights to DKK at the spot rate at the end of the period reported; every Penge1 or Kober1 figure must reconcile to the last filed stock plus the period total.
  • Tag consumer agreements and their collateral type at loan level before the sale, because the four flags are set per buyer row.
  • Generate the XML from the published XSD and XML example, and run Finanstilsynet’s error-check workbook against the file before upload.
  • Mortgage banks and credit purchasers reselling to banks face open scope questions; a written answer from Finanstilsynet settles them before the half-year closes.
  • Watch the period label and last-updated stamp on the KSERV page, and the consolidated act on Retsinformation, for any change to sections 15 and 19.

Sources and References

Preparing each half-year KSERV file

Each half-year, a bank needs the list of non-performing rights it transferred to non-bank buyers, grouped by buyer, with counts, transfer-date sizes, the consumer subset and its collateral types, and an identifier for every buyer. A credit servicer filing for a purchaser needs the same for every resale it handles. For the half-year now closing, that file is due on the next 11 August or 11 February, nil return included.

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.

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