The Danish Competition and Consumer Authority (DCCA) has determined that 14 of Denmark’s largest banks illegally issued Dankort and Visa/Dankort payment cards to business customers in breach of the EU Interchange Fee Regulation. The banks have been ordered to correct the violation by 31 December 2026.
According to the DCCA, the banks failed to ensure that the cards could be electronically identified as corporate cards, a key requirement under the regulation. This technical deficiency prevents merchants from distinguishing between consumer and corporate cards during payment transactions — a distinction that determines whether card fees may be charged.
Regulatory Findings and Deadline
Deputy Director General Jacob Schaumburg-Müller explained that merchants accepting Dankort payments must be able to recognize when a transaction is made with a company card. Without this identification, merchants lose the legal right to pass on card fees to corporate customers.
The DCCA’s investigation, which concluded in September 2024, found that all 14 supervised banks issued non-compliant Dankort and Visa/Dankort cards to business customers. In total, approximately 200,000 cards — or about 6% of all Dankort and co-badged cards in circulation — were affected.
While the banks must replace these cards with legally compliant ones by the end of 2026, the DCCA acknowledged that technical solutions are not yet available to enable electronic identification of corporate Dankort cards. The extended deadline is intended to give banks and payment service providers time to develop and implement the necessary systems.
Political and Technical Developments
In June 2025, the Danish Parliament approved a political agreement to strengthen the Dankort system. The agreement enables Nets, the company that operates Dankort, to invest in developing new technical solutions within the existing revenue framework. These developments will allow the issuance of corporate Dankort cards that meet regulatory requirements by late 2026.
The DCCA noted that it has been informed of the banks’ ongoing development plans and that the current compliance timeline reflects these industry efforts.
Legal Context and Implications
The Interchange Fee Regulation, in force since 2016, requires that payment systems be able to electronically distinguish between consumer and corporate payment cards. The rule is essential for enforcing differential treatment of transaction fees: business card payments may incur surcharges, whereas consumer card payments may not.
The DCCA clarified that the ruling does not prohibit banks from issuing corporate Dankort or Visa/Dankort cards. The issue lies solely in the cards’ lack of technical identifiability as business payment instruments.
Supervision of compliance within Denmark’s payment services sector is conducted under the authority of the Danish Competition Council, which oversees the DCCA’s enforcement activities in this area.
