Denmark’s Road Toll System Under Scrutiny: What Does It Mean for Operators?
Fines of more than DKK 240 million were imposed on Danish companies during 2025 under Denmark’s new kilometer-based and CO₂-differentiated road toll. The European Commission is demanding answers from the Danish government as to the proportionality of the enforcement measures – but what is the position for foreign operators?
Since January 1, 2025, Denmark has introduced a kilometer-based and CO₂-differentiated road toll system for heavy goods vehicles (HGVs) over 12 tonnes. The system replaces the Eurovignette model and applies to both Danish and foreign trucks – including those in transit. Failure to register or incorrect data can result in significant penalties.
The toll is calculated based on three factors:
- Distance travelled on the toll road network
- CO2 emission class of the HGV, based on European standards
- Environmental zone surcharges in designated urban areas. Journeys through environmental zones - including the cities Copenhagen, Aarhus, Odense and Aalborg - incur a 50% surcharge on top of the base toll.
As of 2025, approximately 10.900 km of state and municipal roads are covered by the toll. From 2028, this is expected to expand to the full public road network of approximately 75.000 km.
As of July, the fine was increased to DKK 9,000 per vehicle per day, and since implementation, fines have exceeded DKK 240 million. Many cases stem from system errors, and the European Commission has now asked Denmark to clarify whether these penalties comply with EU Directive 1999/62/EC on proportionality.
Practical advice for foreign operators:
- Register vehicles properly: Ensure all HGVs are accurately registered in the Danish toll system with correct CO2 classifications.
- Choose the appropriate toll payment method: Determine whether an OBU or digital toll ticket best suits your operational needs.
- Plan routes carefully: Be aware of environmental zones and plan routes to avoid unnecessary surcharges.
- Maintain documentation: Keep records of all toll payments and vehicle registrations to facilitate any necessary appeals.
DLA Piper advises both domestic and international transport companies on regulatory matters, dispute resolution, and strategic compliance within the logistics sector.
If you have any questions about the new Danish road toll rules, compliance obligations, or transport law in general, please do not hesitate to contact Christian Benedictsen-Nislev at christian.nislev@dk.dlapiper.com or Carl Erik Skovgaard at Carl.Erik.skovgaard@dk.dlapiper.com
