Denmark

As a member of the European Union (EU), Denmark is subject to accounting, auditing, and financial reporting requirements established in EU Regulations and Directives as transposed into national laws and regulations. Denmark has aligned its legal and regulatory framework with the EU acquis communautaire as it relates to corporate reporting, statutory audit, and professional oversight.

The financial reporting framework in Denmark is primarily set out in the Danish Financial Statements Act, which incorporates the requirements of the EU Accounting Directive. Under this framework, entities whose securities are admitted to trading on a regulated market are required to prepare consolidated financial statements in accordance with International Financial Reporting Standards (IFRS) as adopted by the EU. Listed entities that do not prepare consolidated financial statements are also required to apply EU-endorsed IFRS in their separate financial statements where applicable. Other entities generally prepare financial statements in accordance with the Danish Financial Statements Act and related national requirements. Certain non-listed entities may elect to apply IFRS on a voluntary basis.

The Danish Business Authority (DBA) is the principal authority responsible for corporate reporting and oversight of statutory auditors and audit firms. The Danish Financial Supervisory Authority (DFSA) is responsible for prudential supervision and financial reporting oversight of regulated financial institutions, including banks, insurance companies, and pension institutions. Sector-specific requirements apply to these entities in addition to the general corporate reporting framework.

Statutory audit requirements are established under the Danish Act on Approved Auditors and Audit Firms, which transposes the EU Statutory Audit Directive and related audit reform measures into national law. The Act regulates the approval, registration, supervision, and disciplinary oversight of statutory auditors and audit firms. Mandatory audits are required for entities meeting prescribed size thresholds, public interest entities, and other entities specified by law.

Audits in Denmark are required to be conducted in accordance with International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board and translated for application in the jurisdiction. In practice, ISA are applied in their entirety for all statutory audits.

Denmark has not adopted the IFRS for Small and Medium-sized Entities (IFRS for SMEs). Small and medium-sized entities instead apply the differentiated reporting requirements established under the Danish Financial Statements Act based on entity size and public interest status.

Only statutory auditors are regulated at the state level in Denmark. The audit profession is governed by the Danish Act on Approved Auditors and Audit Firms (the Audit Act), which establishes the legal framework for the approval, registration, supervision, and discipline of statutory auditors and audit firms. Public oversight of the profession is vested in the Danish Business Authority (DBA), which operates under the Ministry of Industry, Business and Financial Affairs and is overseen by the Danish Parliament.

The State Authorized Public Accountant (SPA) designation is the protected professional title for statutory auditors in Denmark. Entry into the profession is regulated under the Audit Act and related executive orders. Responsibility for establishing and administering initial professional development requirements is shared among the Danish Business Authority, the Danish Financial Supervisory Authority (DFSA), universities, and relevant professional bodies. Candidates are generally required to hold a master’s degree in a relevant field, complete a minimum of three years of practical experience, and successfully pass a final professional competence examination.

The Danish Business Authority is responsible for approving, registering, and licensing statutory auditors and audit firms; protecting the SPA designation; establishing regulatory requirements related to education, ethics, auditing, and reporting; conducting quality assurance reviews; administering investigation and disciplinary procedures; and cooperating with competent authorities in other jurisdictions in line with EU requirements.

In addition to state regulation, FSR – danske revisorer operates as the principal professional accountancy organization in the jurisdiction on a voluntary membership basis. While membership is not legally required for statutory auditors, FSR represents the majority of State Authorized Public Accountants in public practice. Its responsibilities include prescribing professional guidance and standards, establishing and enforcing ethical requirements for members, cooperating with the Danish Business Authority in relation to investigation and disciplinary matters, and supporting the development and implementation of initial and continuing professional development requirements.

FSR requires its members to complete a minimum of 120 hours of continuing professional development over a rolling three-year period, with compliance subject to monitoring and verification. In addition, auditors performing statutory audits of financial institutions are subject to enhanced continuing professional development requirements established by the Danish Financial Supervisory Authority. These include a minimum of 180 hours of continuing professional development over a three-year period, including at least 60 hours specifically related to accounting and auditing services for regulated financial institutions.

This framework reflects a shared regulatory model in which statutory oversight is exercised by the state, while the professional body plays a significant role in supporting standard-setting, ethics, education, and member oversight.

Independent public oversight of the audit profession in Denmark is established under the Danish Act on Approved Auditors and Audit Firms (the Audit Act), which provides the legal framework for the regulation and supervision of statutory auditors and audit firms.

The Audit Act designates the Danish Business Authority (DBA), operating under the Ministry of Industry, Business and Financial Affairs and overseen by the Danish Parliament, as the independent public oversight authority for the audit profession.

Under the Audit Act, the DBA is responsible for approving, registering, and licensing statutory auditors and audit firms; protecting the State Authorized Public Accountant (SPA) designation; establishing regulatory requirements related to education, ethics, auditing, and reporting; conducting quality assurance reviews; administering investigation and disciplinary procedures; and cooperating and exchanging information with competent authorities in other jurisdictions on matters relating to audit supervision.

The DBA is a member of the International Forum of Independent Audit Regulators, which supports international cooperation and the sharing of best practices among independent audit oversight authorities.

FSR - danske revisorer

FSR – danske revisorer was established in 1912 as a voluntary professional accountancy organization representing auditors and other accountancy professionals in Denmark.

In 2011, three professional bodies—the former FSR (chartered accountants), the Danish Institute of Certified Public Accountants (FRR), and the association representing younger accountants and trainees (REVIFORA)—merged into a single organization under the name FSR – danske revisorer. This consolidation strengthened the organization’s role as the principal professional body for the accountancy profession in Denmark.

Membership in FSR is voluntary, including for statutory auditors. However, FSR reports that the majority of State Authorized Public Accountants in public practice are members.

FSR plays a significant role in supporting the regulation and development of the profession. Its responsibilities include prescribing professional guidance and standards in accounting and auditing, establishing and enforcing ethical requirements for its members, cooperating with the Danish Business Authority in relation to investigation and disciplinary matters involving members, and collaborating with the Danish Business Authority and the Danish Financial Supervisory Authority on matters related to initial and continuing professional development.

In addition to its national role, FSR is a member of the International Federation of Accountants, Accountancy Europe, and the Nordic Federation of Accountants.

The quality assurance (QA) review system in Denmark is established under the Danish Act on Approved Auditors and Audit Firms (the Audit Act), which provides the legal foundation for mandatory QA reviews of all statutory audits.

The Danish Business Authority (DBA), operating under the Ministry of Industry, Business and Financial Affairs, is responsible for supervising and administering the QA review system in the jurisdiction. The system applies to all statutory auditors and audit firms.

The DBA conducts QA reviews of auditors and audit firms performing audits of public interest entities on a three-year review cycle. For audits of non-public interest entities, the DBA engages qualified practitioners to conduct inspections at least every six years. The authority is responsible for assessing the findings of these reviews, recommending appropriate remedial actions, and imposing sanctions where necessary.

The International Standards on Quality Management (ISQM 1 and ISQM 2) are adopted and effective in the jurisdiction and form part of the applicable quality management framework for audit firms.

The QA review framework is operational and applies to all mandatory audits. Accordingly, the system incorporates the requirements of Statement of Membership Obligations 1 and is assessed as adopted.

Current Status: Adopted

Initial and continuing professional development requirements for statutory auditors in Denmark are established under the Danish Act on Approved Auditors and Audit Firms and related executive orders. The State Authorized Public Accountant designation is reserved for statutory auditors.

Responsibility for establishing and administering education and training requirements is shared among the Danish Business Authority, the Danish Financial Supervisory Authority, universities, and FSR – danske revisorer.

Candidates are required to hold a master’s degree in a relevant field, complete a minimum of three years of practical experience, and successfully pass a final professional competence examination.

Continuing professional development requirements are established and monitored at the jurisdiction level. Statutory auditors are required to complete continuing professional development on an ongoing basis, including enhanced requirements for auditors of financial institutions. Non-compliance may result in regulatory sanctions, including withdrawal of approval.

Accordingly, the requirements for entry, practical experience, assessment, and continuing professional development for statutory auditors are assessed as aligned with the International Education Standards in effect as of the time of the assessment.

Current Status: Adopted

Statutory audit requirements in Denmark are established under the Danish Act on Approved Auditors and Audit Firms, which incorporates the European Union audit reform measures into national law.

The Act requires statutory audits to be conducted in accordance with generally accepted auditing practices. In practice, the auditing standards issued and translated by FSR – danske revisorer are applied for all statutory audits.

Denmark has applied the International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board since 2010. FSR is responsible for translating ISA for application in the jurisdiction and continues to incorporate new and revised standards on an ongoing basis. Independent sources confirm that post-2018 standards and revisions, including ISA 540 (Revised), International Standard on Quality Management 1, International Standard on Quality Management 2, and International Standard on Auditing 220 (Revised), have been translated and are effective in the jurisdiction.

Accordingly, ISA in their entirety in effect as of the time of the assessment are adopted and required for application in all statutory audits in Denmark.

Current Status: Adopted

Ethical requirements for statutory auditors in Denmark are established under the Danish Act on Approved Auditors and Audit Firms, which authorizes the Danish Business Authority to establish ethical and independence requirements for State Authorized Public Accountants.

In practice, the ethical requirements issued by FSR – danske revisorer are applied in the jurisdiction. FSR has maintained an ongoing process to incorporate amendments to the International Code of Ethics for Professional Accountants (including International Independence Standards) and has translated the 2018 Handbook into Danish, including amendments related to non-assurance services and responding to non-compliance with laws and regulations. Additional requirements are included where necessary to comply with Danish legal and regulatory requirements.

However, further confirmation is required to demonstrate that the most recent version of the Handbook in effect as of the time of the assessment (2025) has been fully adopted and made effective in the jurisdiction. Accordingly, the Code is assessed as partially adopted.

Current Status: Partially Adopted

Public sector accounting standards in Denmark are established by the Danish Ministry of Finance, which is responsible for setting the financial reporting framework for public sector entities.

Public sector entities prepare financial statements on an accrual basis using national public sector accounting standards. However, International Public Sector Accounting Standards (IPSAS) have not been adopted in the jurisdiction, and there is currently no formal timeline for their adoption.

The Central Government Accounts Council, which comprises representatives from various ministries, the National Audit Office, and FSR – danske revisorer, monitors developments in IPSAS and their use by other European Union member states.

Current Status: Not Adopted

The investigative and disciplinary (I&D) system in Denmark is established under the Danish Act on Approved Auditors and Audit Firms and applies to State Authorized Public Accountants (statutory auditors).

The Danish Business Authority (DBA) is responsible for initiating and conducting investigations into potential breaches of professional duties and regulatory requirements. The independent Auditors’ Tribunal, established under the Act, is responsible for adjudicating cases and imposing sanctions where appropriate, including fines, restrictions, and withdrawal of approval.

FSR – danske revisorer supports the operation of the I&D framework through its internal regulations governing members’ professional conduct. FSR may refer cases involving statutory auditors to the Auditors’ Tribunal and may also take membership-related disciplinary actions, including expulsion. In addition, FSR is authorized by law to file complaints regarding professional misconduct, including in respect of non-members where relevant.

FSR also investigates conduct matters relating to members who are not statutory auditors in order to safeguard the integrity and reputation of its membership.

The investigative and disciplinary system is operational and incorporates the requirements of Statement of Membership Obligations 6 for all regulated statutory auditors in the jurisdiction. Accordingly, the system is assessed as adopted.

Current Status: Adopted

The Danish Business Authority (DBA) and the Danish Financial Supervisory Authority (DFSA) are the designated authorities responsible for establishing and overseeing the financial reporting framework in Denmark.

In line with European Union requirements as transposed into the Danish Financial Statements Act, entities whose securities are admitted to trading on a regulated market are required to prepare consolidated financial statements in accordance with International Financial Reporting Standards (IFRS) as adopted by the European Union. Listed entities that do not prepare consolidated financial statements are also required to apply EU-endorsed IFRS in their separate financial statements where applicable. IFRS Foundation

Non-listed entities are required to comply with the Danish Financial Statements Act and may elect to apply IFRS on a voluntary basis. Alternatively, they may apply Danish accounting standards developed by FSR – danske revisorer’s Danish Accounting Standards Committee. While these national standards are based on IFRS principles, they differ from IFRS in certain respects.

The DFSA oversees financial reporting by financial institutions under the Danish Financial Business Act and related executive orders. Non-listed financial institutions are required to apply the standards set out in the Danish Financial Statements Act together with DFSA directives.

Denmark has not adopted the IFRS for Small and Medium-sized Entities standard. However, this does not affect the assessment of IFRS adoption for publicly accountable entities.

Accordingly, IFRS Accounting Standards in effect as of the time of the assessment are adopted and required for application by domestic publicly accountable entities in consolidated general purpose financial statements.

Current Status: Adopted

Relevant Organizations

• Danish Business Authority (DBA)
• Danish Financial Supervisory Authority (DFSA)
• FSR - danske revisorer

Relevant Legislation

• Danish Act on Approved Auditors and Audit Firms (the Audit Act) Consolidated Act No. 1287 of November 20, 2018
• Danish Companies Act (Public and Private Limited Companies)
• Danish Capital Markets Act
• Danish Financial Business Act
• Danish Financial Statements Act

Relevant Publications

• Accountancy Europe, Audit Exemption Thresholds in Europe: Update After the Transposition of the Accounting Directive, May 2016
• Accountancy Europe, Definition of Public Interest Entities in Europe: State of Play After the Implementation of the 2014 Audit Reform, November 2017
• Accountancy Europe, Organisation of the Public Oversight of the Audit Profession in Europe, March 2018
• Deloitte, IPSASs in Your Pocket, 2019
• Deloitte, New EU Audit Regulation, November 2019
• European Commission, Implementation of the IAS Regulation 1606/2002 in the EU and EEA, February 2012
• European Commission, SME Business Environment in the EU and EEA: Case of Denmark, 2011
• European Financial Reporting Advisory Group, Setting Accounting Standards in Europe and the Endorsement Process, 2014
• Fédération des Experts Comptables Européens, Survey on Structure and Organization of the Accountancy Profession across 30 European Countries, 2012
• FSR – Danish Auditors, SMO Action Plan, July 2021
• International Forum of Independent Audit Regulators (IFIAR), IFIAR Member Profile: Denmark, 2025.
• IFRS Foundation, IFRS Application Around the World-Jurisdiction Profile: Denmark, March 2019.
• RSM, Accounting and Statutory Audit Requirements in Denmark
• World Bank, Danish Public Oversight System, April 2011.
• UNCTAD, International Accounting and Reporting Issues—2013 Review, 2013.