Denmark CPD: 90 Hours Plus an Evaluation, or 120 Flat

Denmark does something no other European regime we have examined does: it lets you choose your own obligation. Either 90 hours over three years plus an annual competence evaluation, or 120 hours and no evaluation. The catch is that the choice is not entirely yours — miss a single evaluation filing and you are moved onto the 120-hour option for the whole period.

And the current three-year period closes on 31 December 2026, with reporting due by 1 April 2027.

The two options

Under the current regulation, a Danish godkendt revisor satisfies the requirement in one of two ways:

• Option 1 — 90 hours if affiliated with an approved audit firm, or 60 hours if not, plus an annual competence evaluation completed by year-end.
• Option 2 — 120 hours, with no evaluation.

So the evaluation is worth 30 hours a year of training to the firm-affiliated auditor, and 60 to the unaffiliated one. That is a substantial trade, and it explains why the regime is designed this way: it rewards a documented, reflective assessment of your own competence over simply accumulating attendance.

The trap. Failing to file a competence evaluation does not merely cost you the evaluation — it moves you to Option 2 for that period, meaning the full 120 hours. An auditor who has been working to 90 and misses one filing is suddenly 30 hours short with no warning in the arithmetic.

The cycle is fixed, and it closes in weeks

Danish periods are fixed three-year blocks running from 1 January 2009, so every auditor is on the same clock. The current period is 1 January 2024 to 31 December 2026.

Reporting follows: cycle hours are due by 1 April in the year after the period ends, and competence evaluations annually by 1 April of the year they cover.

One feature worth knowing about, because it is unusually public: the hours are entered into the public register of approved revisors, in whole numbers per subject area, rounded up. Danish CPD compliance is visible to anyone who looks.

What the hours must cover

The regulation defines two subject areas:

• Revision and assurance — the examples given include professional ethics and independence, professional scepticism, risk management and sustainability assurance.
• Other relevant law and professional standards — financial reporting standards, company law, tax and data protection.

Under Option 2, at least 30 hours must fall in each of the two areas across the three years, leaving 60 to follow individual need. Specialists must put at least 30 hours into their specialisation.

There is no separate ethics minimum. Professional ethics and independence sit inside the first area as examples of qualifying content, not as a quota. That is consistent with almost every European regime we have examined — only Romania sets an explicit ethics hours floor.

Sustainability: 30 hours, and it counts twice

The regulation requires at least 30 hours for sustainability work, covering sustainability reporting law and standards, sustainability analysis, due diligence on sustainability matters, and assurance requirements. It must be completed within the three years before registration.

Usefully, and unlike the Belgian position, these hours count toward the general three-year requirement rather than sitting on top of it. If you are comparing the two countries, that is a real difference: Belgium’s 60 ESG hours may or may not count toward its 120 — neither of its communications says — whereas Denmark is explicit. See our guide to Belgium’s two regimes and its 31 December ESG deadline.

There is also a transitional route: the Business Authority approves for sustainability assurance an auditor approved as statsautoriseret or registreret revisor before 1 January 2026 who documents the necessary knowledge through continuing education.

Financial-sector auditors carry more

Certified auditors of financial institutions and insurers owe an additional 60 hours within the sector over three years, with at least 15 hours per year. That annual floor is notable, because the general Danish regime has none.

What does and does not count

The format caps are specific and worth checking your plan against:

• Structured on-the-job coaching — requires defined learning objectives, and is capped at 30 hours per cycle.
• Self-study — capped at 5 hours per year. This is among the tightest self-study limits in Europe. Germany, by contrast, allows roughly half its annual target to be self-study including reading professional literature.
• Learning from extraordinary tasks — capped at 10 hours per cycle.
• One 45-minute lesson counts as one hour. So 120 “hours” is 90 clock hours, the same convention Poland and Austria use.

Retention: there isn’t a period, there’s a deadline

This is the structurally interesting part. Danish law sets no record-retention period at all. Instead it imposes a production duty: documentation must reach the Business Authority within four weeks of a request.

The statute reinforces it — an auditor must be able to document compliance at any time. So the practical answer to “how long do I keep records?” in Denmark is: indefinitely, because the obligation to produce them has no end date attached.

Denmark is not alone in this. Sweden and Norway also state no retention period for the practitioner and rely on production instead, while Belgium fixes 7 and 10 years and Finland 6. The split between fixed retention and on-demand production is a genuine design difference across the Nordic and Benelux regimes.

Where the numbers actually live

The statutory duty sits in the Danish audit act, currently consolidated as LBK nr 206 of 20 February 2025. The act itself specifies no hours — it imposes the duty, empowers the Business Authority to make rules, and requires auditors to be able to document compliance at any time.

The numbers are in BEK nr 752 of 2 September 2026, in force from 10 September 2026, which repealed the previous 2024 regulation.

A citation trap worth flagging. The consolidated act’s own opening sentence cites a different number — the 2022 consolidation — because that is the text it consolidates from. If you are referencing Danish audit law, cite LBK 206/2025, not the 2022 number that appears in its first line.

Two things we are not telling you

What the September 2026 regulation changed. It replaced the 2024 version two months ago, but the Business Authority’s own guidance page still dates from February 2022 and links to the superseded regulation. We could not compare the two texts, so nothing above should be read as “new in 2026” — it is simply what the current regulation says.

Whether the professional body adds anything. FSR – danske revisorer’s own page on obligatory continuing education names no regulation and states no hours, periods or deadlines; it describes its courses as a means of obtaining the statutory hours and registers them on member profiles. On that evidence it appears to impose no separate membership obligation — but that is an inference from one page, not a statement by FSR, and we report it as not established.

That matters because the Swedish position is the opposite: there the professional body sets a materially stricter rule than the regulator.

Frequently asked questions

How many CPD hours do Danish auditors need? Either 90 over three years with an annual competence evaluation if affiliated with an approved audit firm, 60 plus the evaluation if not, or 120 with no evaluation.

What happens if I miss a competence evaluation? You move to the 120-hour option for that period.

When does the current cycle end? 31 December 2026, with reporting due by 1 April 2027. Periods are fixed three-year blocks from 1 January 2009.

How much self-study can I count? Five hours a year — one of the tightest limits in Europe.

How long must I keep records? No period is set. Documentation must reach the Business Authority within four weeks of a request, and you must be able to document compliance at any time.

Close a cycle that ends this December, with Learnsignal

With a fixed period closing on 31 December and self-study capped at five hours a year, the remaining room is structured, certificated training. Our courses record activity, date, duration and subject area — the fields that go into the Danish public register. For the legal frame these national rules sit inside, see the EU Statutory Audit Directive, and for how the totals converge across Europe, why European CPD keeps landing on 120 hours. The act and regulation are published at Retsinformation.