Danish companies must shield themselves from sanctioned owners’ control

Danish companies directly or indirectly owned or controlled by persons subject to the specified EU sanctions must introduce measures that prevent those persons from exercising controlRetsinformation. Law 727, signed on 1 September 2026, gives Erhvervsstyrelsen responsibility for approving the necessary protective measures and supervising complianceRetsinformation. Its commencement clause provides for entry into force on the day after publication in Lovtidende.

The requirement covers both individuals and legal entities subject to restrictive measures under Article 29 of the Treaty on European Union or Article 215 of the Treaty on the Functioning of the European UnionRetsinformation. A company that fails to introduce the necessary measures can receive an order from Erhvervsstyrelsen to do so. The authority can demand the information needed to decide whether measures submitted for approval are sufficient.

The law also suspends the governance and economic rights attributable to a sanctioned person who directly or indirectly owns or otherwise controls a company domiciled in DenmarkRetsinformation. Other owners’ shares of voting rights recorded in the ownership register, or an equivalent register, increase proportionately by the sanctioned person’s voting rights. If a sanctioned person is part of management, Erhvervsstyrelsen can remove that person’s registration in CVR and can refuse a new management registration.

For advisers, the assurance provision is a further practical point. Erhvervsstyrelsen can require a company, within a specified period, to obtain a statement from an approved auditor, a lawyer or another expert about the accuracy of information or explanations it has suppliedRetsinformation. The person giving that statement must confirm independence from the company.

Failure to comply with an order to introduce protective measures can lead Erhvervsstyrelsen to ask the bankruptcy court to dissolve the companyRetsinformation. The authority can also delete a foreign company’s branch from CVR, or delete the registration of a general partnership or limited partnership, in the circumstances specified by the law.

The legal basis is Law 727 of 1 September 2026, introducing sections 1 a and 1 g–1 i into the Danish legislation on the application of certain EU acts concerning economic relations with third countries.