Companies on Nasdaq First North Growth Market Denmark must publish an annual report every year. The rules are lighter than on the main market, but the deadlines are fixed, and there are more requirements than most companies expect the first time.
This guide covers what the Nasdaq rulebook and Danish law require, and a timeline that gives you a calm March instead of a rushed one.
Note that each Nordic First North market has its own supplement to the rulebook. This guide covers Denmark. Stockholm, Helsinki and Iceland have different deadlines.
In short
- The annual report must be published as a company announcement no later than 4 months after the end of the financial year.
- The half-year report must be published no later than 3 months after the end of the period. Quarterly reports are optional.
- The report must be attached to the company announcement as a file. A link is not enough.
- The financial calendar must be on your website before the financial year begins.
- The ESEF format (iXBRL) does not apply to First North companies.
The deadlines: 4 months to the market, 6 months to the Danish Business Authority
Two deadlines apply at the same time, and the shorter one drives your plan.
| What | Deadline | Source |
|---|---|---|
| Annual report published as a company announcement | No later than 4 months after the end of the financial year | First North Rulebook, Supplement D, 4.3.4 |
| Half-year report published as a company announcement | No later than 3 months after the end of the period | Supplement D, 4.3.5 |
| Approved annual report filed with the Danish Business Authority | No later than 6 months after the end of the financial year | Danish Financial Statements Act |
| Financial calendar for the coming year | Before the financial year begins | Rulebook, 4.5 |
With a calendar financial year, the annual report deadline is 30 April. The rule says "as soon as possible", so the deadline is a ceiling, not a target. Many companies publish earlier, so the annual general meeting can be held in April or May.
The 6-month filing deadline applies to companies in reporting classes B and C. Companies on a regulated market, meaning the main market, are in class D and have a shorter deadline. A First North listing does not by itself put a company in class D.
The duty to publish the annual and half-year reports comes from Nasdaq's rulebook, not from the Danish Capital Markets Act. First North companies therefore do not file their annual report in the Danish FSA's OAM system, as main market companies must (Danish FSA, overview of issuers' disclosure obligations).
If the company is in the First North Premier Growth Market segment, the main market's disclosure rules apply instead of Chapter 4 of the rulebook, and IFRS is required (Rulebook, 7.2.1 and 7.3.1). The deadlines in this guide apply to the standard First North Growth Market Denmark.
What the rules require of the annual report
Accounting standard
The rulebook requires financial information to be prepared under the accounting rules that apply to the company (Supplement D, 4.3.3). For most Danish First North companies, that means the Danish Financial Statements Act. IFRS is not required, but some companies choose it because investors know it.
Attach the report to the announcement
The annual report must be attached to the company announcement as a file. Linking to your website is not enough (Supplement D, 4.2.1(a)). The same applies to the half-year report and the notice of the general meeting.
Name your Certified Adviser in every announcement
Every company announcement under the rulebook must include the name of your Certified Adviser (Rulebook, 4.2.8). The announcement must be sent to your Certified Adviser and to Nasdaq at the same time (6.1.3). If you later find an error in the report, publish the correction as soon as possible, and start the announcement by stating what is being corrected (4.2.1(b)).
Language
Announcements must be published in Danish, Swedish, Norwegian or English (Supplement D, 4.7). If you have international investors, English is often the natural choice for the report itself.
Your website
All financial reports must be available on your website for at least 5 years (Rulebook, 4.6). The website must also show your articles of association, the financial calendar, the name and contact details of your Certified Adviser, and information about the board and management, including their holdings of the company's shares.
ESEF does not apply
The ESEF format (iXBRL) is mandatory for issuers with securities admitted to trading on an EU regulated market. In Denmark, it applies to issuers covered by chapter 5 of the Capital Markets Act. First North is a multilateral trading facility, not a regulated market, and the Danish Business Authority states directly that companies listed on First North are not in reporting class D. You can therefore publish the annual report as a standard PDF. Filing with the Danish Business Authority is still digital under the normal rules.
One exception: if the company also has other securities, such as bonds, admitted to trading on a regulated market, the ESEF requirement may still apply. Check with your auditor.
The financial calendar must be ready before the year begins
Before each financial year, you must publish a financial calendar on your website with the dates on which you expect to publish the annual report and the half-year report, and the date of the annual general meeting (Rulebook, 4.5).
If you move a date, update the calendar as soon as possible. If the change falls within two weeks of the original or the new date, you must publish the new date in a company announcement, ideally with the reason. All dates stay in the calendar for the whole year.
With a calendar financial year, your 2027 financial calendar must be published no later than 31 December 2026.
Closed period for management
The EU Market Abuse Regulation (MAR) also applies to First North. Persons discharging managerial responsibilities may not trade in the company's shares during the 30 calendar days before the publication of a half-year or annual report (MAR Article 19(11)). The date in your financial calendar therefore also decides when management can trade, so it pays to fix it early.
If you miss the deadline
If a company breaches the rulebook, Nasdaq can issue a reprimand, a fine or, in serious cases, remove the shares from trading (Rulebook, 8.2.1). In Denmark, the more serious cases go to the exchange's disciplinary committee, which can fine an issuer up to DKK 1 million, and its decisions are normally published with the company's name (Supplement D, 8.3.3). A late annual report is a reputational problem as well as a compliance one.
A realistic timeline
Here is a timeline for a company with a calendar financial year that plans to publish its annual report at the end of March. Shift it if your date is earlier or later.
| Month | What happens |
|---|---|
| December | The date is fixed in the financial calendar. Structure, responsibilities and timeline are agreed with your auditor, Certified Adviser and reporting partner. The equity story is updated. |
| January | The narrative sections are written: management review, CEO letter, strategy and the year's highlights. Photos and data that do not depend on the accounts are collected. |
| February | The audit is completed and the figures fall into place. Layout, charts and key figures are set up. First review round with management and the auditor. |
| March | The board approves the report. Final proofreading, final PDF and company announcement. Publication on the announced date. |
| April to May | Annual general meeting. The approved annual report is filed with the Danish Business Authority. |
What usually causes the rush is not the design. It is text and figures having to be finished at the same time. Write the narrative sections in January while the audit runs, and only figures and charts remain when the accounts are ready.
More than compliance
The rules tell you when the annual report must go out, not how it will be read. For a smaller listed company, the annual report is often the document investors and analysts read most closely. A good annual report has:
- A clear investment case that runs from the first page to the last.
- A management review that explains the figures instead of repeating them.
- Key figures and charts that can be read in seconds.
- A design that matches the half-year report, presentations and website.
See how we did it for Erria and Bar Djus, or read more about how we work on annual reports.
Checklist
- Next year's financial calendar published on your website before the financial year starts
- Timeline agreed with your auditor and Certified Adviser
- Equity story and management review written before the figures are final
- Language chosen: Danish, English or both
- Annual report attached to the company announcement as a file, with your Certified Adviser named in the announcement
- Report published on your website, where it must stay for at least 5 years
- Management informed about the 30-day closed period
- Approved annual report filed with the Danish Business Authority after the general meeting
Sources
- Nasdaq: First North MTF Rules (opens in a new tab) (always lists the rulebook currently in force)
- Nasdaq First North Growth Market Rulebook for Issuers of Shares, 1 October 2026 (opens in a new tab), the version this article is based on (sections 4.2.8, 4.5, 4.6, 7.3, 8.2 and Supplement D)
- Danish Business Authority: Guidance on annual reports (opens in a new tab) (in Danish; deadlines and reporting class D)
- Danish FSA: Issuers' disclosure and reporting obligations (opens in a new tab) (in Danish; main market compared with First North Denmark)
- Danish FSA: European Single Electronic Format (ESEF) (opens in a new tab) (in Danish)
- ESMA: Electronic Reporting (ESEF) (opens in a new tab)
- Market Abuse Regulation (EU) No 596/2014 (opens in a new tab), Article 19(11)
About this article: The content is general information, not legal, accounting or other professional advice. It reflects the rules as they stood when it was published on 22 October 2026, and rules and practice may have changed since. Venari Digital cannot be held liable for decisions made on the basis of this content. Always consult your Certified Adviser, auditor or legal adviser before acting.