Debt Collection in the Nordics: Denmark, Sweden and Norway Compared
If you have customers in Sweden or Norway, different rules apply to reminders, fees and recovery than in Denmark. Here are the most important differences, and how to approach them.
Same region: different rules
Many Danish businesses sell to customers in Sweden and Norway. The countries are similar, but the rules on debt recovery are national. When a Swedish or Norwegian customer does not pay, it is as a rule the rules of the customer's country that decide how debt collection must be carried out, which fees may be charged and which authorities can help you.
Here is an overview of the main differences. Amounts and rules are adjusted regularly, so always check the current rules, or use a partner with local knowledge.
Denmark in brief
- Supervision: debt collection requires authorisation from the Danish National Police (Rigspolitiet). The Consumer Ombudsman enforces good debt collection practice.
- Letter of demand: a debt collection notice with a deadline of at least 10 days from sending (section 10 of the Debt Collection Act).
- Fees: reminder fee at most DKK 100, no more than 3 reminders; DKK 310 compensation between businesses.
- Court route: a payment order (betalingspåkrav) at the bailiff's court for undisputed claims up to DKK 100,000.
Sweden
- Legislation: debt collection is governed by the Debt Collection Act (inkassolagen) and the act on compensation for debt collection costs (lagen om ersättning för inkassokostnader m.m.).
- Supervision: since 1 January 2024, Finansinspektionen (the Swedish Financial Supervisory Authority) has licensed and supervised debt collection. The task previously lay with the Swedish Authority for Privacy Protection.
- Fees: the law caps the costs the debtor can be charged, for example for payment reminders and collection demands. A reminder fee can only be charged if it was agreed in advance.
- Court route: the Swedish Enforcement Authority, Kronofogden, handles applications for a betalningsföreläggande, a simplified procedure for monetary claims. If the debtor disputes the claim, the case can go on to court. Without an objection, Kronofogden can issue a decision that can be enforced.
Expert tip: Communicate in the customer's language
A debt collection notice in Danish sent to a Swedish or Norwegian consumer risks being seen as unclear. Write in the customer's language or in English, and consider using a local partner who knows the national requirements for the content of reminders and collection letters.
Norway
- Legislation: debt collection is governed by the Norwegian Debt Collection Act (inkassoloven) and Debt Collection Regulations (inkassoforskriften).
- Supervision: Finanstilsynet (the Financial Supervisory Authority of Norway) licenses and supervises debt collection.
- Debt collection notice: before a claim is sent to debt collection, the debtor must receive a written debt collection notice (inkassovarsel) with a payment deadline of at least 14 days.
- Demand for payment: before legal steps are taken, the debtor must as a rule receive a demand for payment (betalingsoppfordring) with a deadline of at least 14 days.
- Fees: the costs the debtor can be charged are limited by rates in the Debt Collection Regulations, which are adjusted regularly.
- Court route: unpaid claims can typically be brought before the conciliation board (forliksrådet), and enforcement takes place through the enforcement officer (namsmannen).
Judgments across borders
If you already have a Danish judgment, the question is whether it can be enforced in the customer's country:
- Sweden is an EU member. Denmark is bound by the rules of the Brussels I Regulation on the recognition and enforcement of judgments through a special parallel agreement with the EU.
- Norway is not an EU member, but both Denmark and Norway are parties to the Lugano Convention, which has corresponding rules on the recognition and enforcement of judgments in civil cases.
In practice, though, it is often simpler and cheaper to recover the claim directly in the customer's country through a local debt collection partner.
Expert tip: Agree jurisdiction and governing law in advance
State in your terms of sale which country's law applies and where any dispute is to be decided. This gives you more predictability if something goes wrong. Be aware that special rules protect consumers, so such terms cannot always be enforced against private customers.
How to approach it
- Send reminders in the customer's language and follow the customer's country's rules on fees
- Use a debt collection partner licensed and experienced in the country concerned
- Make sure you have documentation: agreement, invoice, proof of delivery and correspondence
- Act quickly: cross-border cases typically take longer
Getting started
Nordic customers are often good payers, but when things go wrong, local rules apply. Through InkassoHurtig you can get no-obligation quotes from police-authorised debt collection agencies and lawyers, including partners with experience of recovery abroad. This content is general information and not legal advice.