On Jun. 11, 2025, DEN PRL said that it had adopted both bill L193A and bill L193B.
Bill L193A enters into force Jul. 1, 2025 except for S 259(1) 2(11) of the Law on Insurance Business, as amended by S 1(10), 2(7) which are force on Mar. 1, 2026; S 1, no. 15, 16 and 20, and S 2, nos. 18, 19, 21, which enter into force Jul. 2, 2026; S 1, no. 5-7 and 22, which enter into force on Jan. 10, 2030.
Bill L193B enters into force Jul. 1, 2025, except for S 6(4), 10, 13, 14, 54, which enter into force the following day the executive order in the Official Gazette; S 5, no. 30, and § 6, nos. 3, 5, 7, 8, 18, 20, 23-33, 49, 51,which enter into force on Sep. 29, 2025.
Also § 1, no. 1, 2, S 5(1)(61-63) of Danish Financial Business Act as amended by Para 1(8), Para 1(9), (18), 20-22, 28, 30-36, 55, 56, 59, 60, 62-64, 66 67, § 170 b i of the Financial Business Act as amended by Para 1; No. 69, § 1, nos. 71-77, 79-83, 103, 104, 108, 109, 111-113, 115, 121, 123, 125, S 4(3), S 5(3) to (7); which enter into force Jan. 1, 2026; S 1, nos. 100 and 102, Section 2, no. 56, S 3, no. 42, S 5, no. 21, S 6, no. 37, S 7, no. 7 which enter into force Mar. 1, 2026.
Also S 5, subsection 1, no. 64, of Financial Business Act as amended by L193B's S 1, no. 8, S 1, nos. 10–16, 37, 40–48, 52–54, 99, 118, 119, 122, S 2, nos. 2–14, 16–43, 49–54, 62–64, 69–76, 78, 80, 84–87, and S 3, nos. 1, 4–6, 8–20, 22–33, 36, 41, 43, 47–49, 56, 60 which enter into force Apr. 16, 2026
S 1, no. 117, 120, 124, S 2, Nos. 77, 83, S 3, Nos. 53, 54, 58, S 5, Nos. 25, 27, 31, S 6, No. 56, S 7, No. 11, 15, S 117(3) of Act on Company Pension Funds, as amended by Para 7(16) which enter into force Jul. 2, 2026; S 6(2), 11, 45, 52, 53, which enter into force Jul. 10, 2026.
§ 1, no. 3 and 5, and section 6, no. 6, which enter into force Jan. 1, 2027.
S 1, no. 98, and S 2, nos. 45-48, which enter into force Apr. 16, 2027.
S 3, no. 35, 38, 39, which enter into force Jan. 10, 2028.
S 1, no. 38, 39, 78, 95, S 2, No. 44, S 5, Nos. 8, 9, 12, 13, 18, S 6(1), (12), (19), (21), (22), (46), (48), S 7(3) to (5); S 14(4) which enter into force Jan. 10, 2030.
The Minister for Industry, Business and Financial Affairs shall determine the date for entry into force of section 9, nos. 1, 4 and 5, and section 21.
Note also that Section 1(65), (69) and (130) take effect from Jan. 1, 2025.
Both bills are subject to transitional provisions as set out in the relevant act.
On Apr. 30, DEN PRL said DEN EM miscellaneous bill had been issued.
DEN PRL issued, following 1st reading, L 193 proposal for an act amending the financial business act, the alternative investment fund managers act, etc., the investment associations act, the money laundering act and various other acts. (handling crypto exposures, preparation of ESG transition plans, new documentation requirements for the institutions' management structure, division of responsibilities and reporting lines, clearer rules for the authorisation of credit institutions from countries outside the EU/EEA (third countries), new supervisory authority for the danish financial supervisory authority to approve significant acquisitions of equity interests in other companies, criminalization of the disclosure regulation, modernisation of the rules in the AIFM-UCITS II directive, strengthening the rules on combating national and international money laundering and establishing a single European access point (ESAP) for submitting a number of published information, etc.).
Follows, DEN FSA Dec. 2024 consulted on Act amending financial acts, see #238253.
Document dated Apr. 30, 2025, was added on May 6, 2025 due to editorial backfill.
Contents
The bill contains numerous amendments regarding the following subjects.
2.1. Access of cross-sector pension funds/insurance companies to own/operate forests.
2.2; State guarantee regarding real estate credit agreements in rural areas, #253134.
2.3; Terms of access to payment systems by payment system providers, see #253186.
2.4; Introduction of output floor in the calculation of institutions' RWEs, see #253196.
2.5; The introduction of transitional rule regarding the output floor, see #253205.
2.6; Amendments that are made regarding the output floor at group level, #253208.
2.7; More frequent disclosure of credit institutions’ risk information, see #253217.
2.8; Approving bank, mortgage firm, financial holding company holdings, #253223.
2.9; Authorization and notification for mergers/significant asset transfers, #253226.
2.10; Fitness/propriety of management members in financial undertakings, #253227.
2.11. Branches of credit institutions from countries outside the European Union.
2.12. Withdrawal of a licence as a bank or mortgage-credit institution in the event of non-compliance with net stable funding.
2.13. Management of crypto-assets by banks and mortgage-credit institutions.
2.14. Benchmarking in the area of market risk.
2.15. The Danish Financial Supervisory Authority's authority to require changes to assumptions in banks' and mortgage-credit institutions' internal models.
2.16. The Danish Financial Supervisory Authority's authority to require adjustments to internal models for market risk.
2.17; Effective forms of corporate governance for financial holding company, #253238.
2.19; DEN FSA powers re concentration risks in banks/mortgage firms, see #253230.
2.20. Powers of the Danish Financial Supervisory Authority regarding crypto risks of banks and mortgage-credit institutions.
2.21. Approval of financial holding companies.
2.22. The FSA's duty of confidentiality.
2.23. Access to sharing confidential information with Finansiel Stabilitet.
2.24. Adjustment of rules on publication of certain supervisory reactions.
2.25. Duration of refusals and orders based on lack of integrity.
2.26. Submission of decisions on suitability and integrity to courts.
2.27. Conditional suitability approvals.
2.28. Collective suitability for board members in credit service companies.
2.29. Confidentiality of fit and proper decisions.
2.30. Publication requirements for fit and proper decisions in different laws.
2.31. Integrity requirements for art dealers.
2.32. Competence requirements for employees of crypto-asset service providers who provide investment advice, etc.
2.33; Banks/mortgage institutions ESG transition plans and stress testing, #253243.
2.34; Rules on the National Supervision of the ESG Ratings Regulation, see #253244.
2.35. Expanded options for not registering in the money laundering register.
2.36. Expansion of participants cooperating in money laundering prevention, #253253.
2.37. Processing lawyer pooled client bank account by financial institution, #253309.
2.38. Adjustment of the rules on notification and confidentiality obligations in the area of money laundering.
2.39. Following changes resulting from the AIFM-UCITS II Directive: 2.39.2.1. Loan-issuing funds 2.39.2.2. Cross-border provision of depositary services for alternative investment funds 2.39.2.3. Tightened regulation of delegation agreements 2.39.2.4. Liquidity management tools 2.39.2.5. Better data collection, reporting, knowledge sharing and cooperation between authorities.
2.40. Disclosure of confidential information and penalties for breach of new provisions in EMIR.
2.41. Powers to monitor compliance with the Crypto-Assets Markets Regulation.
2.42. Establishment of a ESAP for reporting across financial legislation, #253325.
2.43. Penalties for infringement of certain provisions of the Crowdfunding Regulation.
2.44. Penalties for infringement of the Disclosure Regulation.
2.45. Presentation of annual accounts in accordance with International Financial Reporting Standards (IFRS) for insurance companies authorised to carry on non-life insurance business.
2.46. Requirements for operators of trading venues regarding data quality, #253341.
2.47. Definition of participant in payment/securities settlement systems, #253354.
2.48. Amendment of the Danish FSA's Board of Directors' use of external experts.
2.49. Transfer of decision-making authority regarding NBCR terrorist acts to the Government.
2.50. Relaxation of the cash rule for municipalities.
2.51. Clarification of the framework for licensing requirements for investment firms
2.52. Dividends in savings banks.
2.53. Winding up of banks or mortgage-credit institutions outside the public interest.
2.54. Handling of distressed banks, mortgage credit institutions, investment firms and certain holding companies and financial institutions.
2.55 Debt buffer requirement for mortgage credit institutions in SIFI group, #253346.
Effectiveness
Act shall come into force on Jul. 1, 2025, subject to the following.
§ 6, numbers 4, 10, 13, 14, and 52, come into force the day after publication in OG.
§ 5, number 30, and § 6, numbers 3, 5, 7, 8, 18, 20, 23-33, 47, and 49, shall come into force on Sep. 29, 2025.
§ 1, numbers 1, 6, 7, 9, 17, 19, 20, 27, 29-32, 34-36, 54, 55, 58, 59, 61-63, 65, 66, § 170b of the Act on Financial Business, as amended by § 1, numbers 68, 69-75, 77-81, 100, 101, 105, 106, 108, 109, 110, 112, 118, 121, § 4, number 3, and § 5, numbers 3-5, shall come into force on Jan. 1, 2026.
§ 1, numbers 78, 97, and 99, § 2, numbers 12 and 53, § 3, number 42, § 5, number 21, § 6, number 36, § 7, number 11, § 8, number 7, § 9, number 8, § 10, number 8, and § 13, number 1, shall come into force on Mar. 1, 2026.
§ 1, numbers 8, 10-15, 37, 40-48, 51-53, 96, 115, 116, and 119, § 2, numbers 2-12, 14-40, 46-51, 60, 66-73, 75, 81-93, § 3, numbers 1, 4-6, 8-20, 22-33, 36, 41, 44, 48-50, and 61, shall come into force on Apr. 16, 2026.
§ 1, numbers 114, 117, and 120, § 2, numbers 55 and 77, § 3, numbers 54, 55, and 59, § 5, numbers 25, 27, and 31, § 6, number 54, § 7, numbers 16, 17, and 21, § 8, numbers 11, 15, and 19, § 10, numbers 18, 19, and 21, come into force Jul. 2, 2026.
§ 6, numbers 2, 11, 45, 50, and 51, shall come into force on Jul. 10, 2026.
§ 1, numbers 2 and 3, shall come into force on Jan. 1, 2027.
§ 1, number 95, and § 2, numbers 42-45, shall come into force on Apr. 16, 2027.
§ 3, numbers 35 and 39, shall come into force on Jan. 10, 2028.
§ 1, numbers 38, 39, 76, and 92, § 2, number 41, § 5, numbers 8, 9, 12, 13, and 18, § 6, numbers 1, 12, 19, 21, 22, and 48, § 7, numbers 5-7, § 8, numbers 3-5, and § 17, number 4, shall come into force on Jan. 10, 2030.
§ 1, numbers 64, 68, and 126, shall take effect from Jan. 1, 2025; transitional provisions apply as set out in the Act.
May 2025 DEN CRG Survey
On May 15, 2025, DEN CRG issued details of survey in response to bill making amendments to several law primarily in the financial area, including creation of ESAP.
The survey shows that the bill is expected to result in administrative restructuring costs for businesses of DKK 6.2 mn, as well as administrative costs of DKK 5.7 mn.
May 2025 Report Submitted
On May 27, 2025, DEN PRL issued submission of report on Bill L193 proposal for act amending the financial business act, the alternative investment fund managers act, etc., the investment associations act, the money laundering act and various other acts.
Bill place on agenda for 2nd reading on Jun. 3, 2025, 3rd reading on Jun. 11, 2025.
Jun. 2025 Bill Split
On Jun. 6, 2025, DEN PRL said bill L193 has now been divided into two separate bills.
Bill L193A - Proposal for an Act amending the Law on Insurance Business, the Act on Payments, the Act on the Establishment of a State Guarantee on Part of the Property Credit Agreements in Rural Areas and various other Acts. (Cross-sector pension funds' and insurance companies' access to own and manage forests, conditions for access to payment systems for payment service providers and the establishment of a state guarantee on some of the property credit agreements in rural areas, etc.).
Bill L193B - Proposal for an Act amending the Financial Business Act, the Act on Alternative Investment Fund Managers, etc., the Investment Funds Act, etc., the Money Laundering Act and various other acts. (Handling of crypto exposures, preparation of ESG transition plans, new documentation requirements for the institutions' management structure, division of responsibilities and reporting lines, clearer rules for the authorisation of credit institutions from countries outside the EU/EEA (third countries), new supervisory powers for the Danish Financial Supervisory Authority on the approval of significant acquisitions of shareholdings in other companies, penalisation of the Disclosure Regulation, modernisation of the rules in the AIFM-UCITS II Directive, strengthening of the the rules on the fight against national and international money laundering and the establishment of a single European access point (ESAP) for the submission of a number of published information, etc.).
Both planned to come into force Jul. 1, 2025 subject to provisions set out in the Act.
Jun. 2025 Bills Adopted
On Jun. 11, 2025, DEN PRL said that it had adopted both bill L193A and bill L193B.
Bill L193A enters into force Jul. 1, 2025 except for S 259(1) 2(11) of the Law on Insurance Business, as amended by S 1(10), 2(7) which are force on Mar. 1, 2026; S 1, no. 15, 16 and 20, and S 2, nos. 18, 19, 21, which enter into force Jul. 2, 2026; S 1, no. 5-7 and 22, which enter into force on Jan. 10, 2030.
Bill L193B enters into force Jul. 1, 2025, except for S 6(4), 10, 13, 14, 54, which enter into force the following day the executive order in the Official Gazette; S 5, no. 30, and § 6, nos. 3, 5, 7, 8, 18, 20, 23-33, 49, 51,which enter into force on Sep. 29, 2025.
Also § 1, no. 1, 2, S 5(1)(61-63) of Danish Financial Business Act as amended by Para 1(8), Para 1(9), (18), 20-22, 28, 30-36, 55, 56, 59, 60, 62-64, 66 67, § 170 b i of the Financial Business Act as amended by Para 1; No. 69, § 1, nos. 71-77, 79-83, 103, 104, 108, 109, 111-113, 115, 121, 123, 125, S 4(3), S 5(3) to (7); which enter into force Jan. 1, 2026; S 1, nos. 100 and 102, Section 2, no. 56, S 3, no. 42, S 5, no. 21, S 6, no. 37, S 7, no. 7 which enter into force Mar. 1, 2026.
Also S 5, subsection 1, no. 64, of Financial Business Act as amended by L193B's S 1, no. 8, S 1, nos. 10–16, 37, 40–48, 52–54, 99, 118, 119, 122, S 2, nos. 2–14, 16–43, 49–54, 62–64, 69–76, 78, 80, 84–87, and S 3, nos. 1, 4–6, 8–20, 22–33, 36, 41, 43, 47–49, 56, 60 which enter into force Apr. 16, 2026
S 1, no. 117, 120, 124, S 2, Nos. 77, 83, S 3, Nos. 53, 54, 58, S 5, Nos. 25, 27, 31, S 6, No. 56, S 7, No. 11, 15, S 117(3) of Act on Company Pension Funds, as amended by Para 7(16) which enter into force Jul. 2, 2026; S 6(2), 11, 45, 52, 53, which enter into force Jul. 10, 2026.
§ 1, no. 3 and 5, and section 6, no. 6, which enter into force Jan. 1, 2027.
S 1, no. 98, and S 2, nos. 45-48, which enter into force Apr. 16, 2027.
S 3, no. 35, 38, 39, which enter into force Jan. 10, 2028.
S 1, no. 38, 39, 78, 95, S 2, No. 44, S 5, Nos. 8, 9, 12, 13, 18, S 6(1), (12), (19), (21), (22), (46), (48), S 7(3) to (5); S 14(4) which enter into force Jan. 10, 2030.
The Minister for Industry, Business and Financial Affairs shall determine the date for entry into force of section 9, nos. 1, 4 and 5, and section 21.
Note also that Section 1(65), (69) and (130) take effect from Jan. 1, 2025.
Both bills are subject to transitional provisions as set out in the relevant act.
