Both the use and economic activity of a ship, other than that of pleasure craft, affect the possibility of it being registered in Danish registers.
The rules for non-Danish owners of a ship to be registered as owner in one of the Danish ship registers can be found in The Ship Register Executive Orders (skibsregistreringsbekendtgørelsen), Chapter 12.(link)
Who can be registered as an owner
- For merchant ships, including passenger ships, any foreign owner, person, or company may be registered as the owner.
- For fishing vessels, only foreign owners who are EU/EEA citizens/companies can be registered, and it is a requirement that the vessel has permission to be engaged in fishing in Denmark.
- Pleasure crafts with a GT over 20 and which have an EU/EEA owner who either lives or works in Denmark or has lived and worked in Denmark can be registered here.
Concerning owners who are shipping partnerships
For foreign shipping partnerships, the managing shipowner chosen must be either a citizen or a legal person from Denmark or from an EU/EEA country. Managing shipowners from countries outside EU/EEA countries cannot be selected.
Registration of owner and possibly of ship
Registration in DSRG with MitID
Notification can be made in DSRG, Self-service, if you have given power of attorney from a person who has MitID. The ship register must then receive the original physical power of attorney.
See this guide if you also need to register a ship in the Danish register
If, on the other hand, you take over a ship that is already registered in the Danish register, see the guide on change of ship.
If you need to change the information that was used when registering you as the owner of the ship, you should contact the Register of Shipping before changing anything.
However, in the change regarding ship (link) flow, you can report, for example, a new fulfillment of the activity requirement and provide additional documentation.
Report on paper – if you cannot get MitID
Registration of owner
For the purpose of registering foreign owners, one or more of the following forms shall be used:
Blanket 26 Registreringsanmeldelse Enkeltmandsrederi
Blanket 27 Registreringsanmeldelse Partrederi
Blanket 28 Registreringsanmeldelse Selskaber med begrænset ansvar
Blanket 29 Registreringsanmeldelse Selskaber el.lign. uden begrænset ansvar
Each form specifies the supporting documents to be submitted with the registration. Please note that documentation must always be submitted for the owner's nationality and how the activity condition is met. The proof of nationality can typically be an extract from the national company register. For the activity condition, it can typically be a letter stating which activities and the scope of activities in Denmark, or a declaration or agreement signed by the ship's owner and the Danish entity, as well as a copy of, for example, bareboat charter party, management agreement or the like regarding the ship.
If you also need to register a ship in the Danish register, see "Registering a ship in a Danish register, and certificates of nationality" for further documentation requirements.
If you take over a ship that is already registered in the Danish register, please see "Change of ownership" for further documentation requirements.
If you need to report changes to the information provided when registering you as the owner of the ship, see
Changes to reported information
Changes to the reported information about, for example, the owner/owners of the ship and whether the person who meets the activity requirement must be reported to the Register of Shipping by the ship's owner or the person who meets the activity condition no later than 30 days after the change has occurred.
The Register of Shipping assesses whether the conditions for registration are still met after the amendments. Depending on the nature of the change, it can be reported on one of the report forms mentioned or simply by e-mail.
You are always welcome to contact the Danish Ship Register and ask how a given change can be reported.
Fishing vessels and pleasure craft
You can read about the requirements for being registered as an owner in one of the Danish ship registers in the Ship Register Executive Orders (skibsregistreringsbekendtgørelsen), § 100(link) as a non-Danish owner of a fishing vessel.
If you want to know more about the requirements to be registered as a foreign owner of a fishing vessel or a recreational vessel with a GT over 20, please contact the Ship Register; srg@dma.dk
The activity and contact requirements applicable to merchant ships, including passenger ships and spot checks
In order to register a merchant ship with a foreign owner in a Danish ship register (DIS or DAS), it is required that the ship concerned is part of economic activity in Denmark. We call this the activity condition.
Additionally, there is a requirement that the ship's owner appoints an entity (Danish natural or legal person) that can be summoned on behalf of the foreign owner. The Danish entity must accede to the appointment. We call this the contact condition, see bekendtgørelsen § 97(link)
Both conditions must be fulfilled during the time the ship is registered in a Danish ship register. If there are changes in the basis on which the registration was accepted, the change must be reported to the Register of Shipping no later than 30 days after the change has occurred/entered into force.
The ship register always assesses the entire situation regarding the specific ship. The Ship Register therefore always offers a close, broad, and flexible dialogue both before, during and after registering a ship from a foreign country. The Ship Register assesses whether the conditions for continued registration under the Danish flag are present.
The Activity Requirement
It is required that economic activity is carried out in Denmark in connection with the ship in at least one of the following ways:
- The ship's technical or commercial operation is operated from Denmark.
- The shipping company, organization or person which has or applied for the ship's Document of Compliance is established in Denmark.
- The registrar of ships may, on a case-by-case basis, assess that a plurality of activities and measures are considered to constitute such an economic activity in Denmark that the requirements for registration can be seen as fulfilled.
The foreign owner of the ship must declare and document that one of the above three conditions in its entirety is met. Alternatively, it can be documented that a plurality of parts of the mentioned activities are carried out from Denmark. We will then make a discretionary assessment of whether the activity condition can be considered fulfilled.
If a foreign-owned ship is registered in a Danish ship register and at the same time rented by a Danish-based charterer according to, for example, a bareboat charter party, then the requirements on activity conditions for economic activity in Denmark will normally be met. However, in each case, we will assess whether the activities included in the lease agreement meet the activity condition.
A widely used form of documentation/procedure is that a foreign owner enters into an 'agency or management agreement' with a Danish shipping company or management company. The owner and the company in question then agree on exactly which activities the Danish agency will carry out on behalf of the owner. Agency agreements are often entered, regardless of the fact that there is no requirement for secondary establishment for foreign owners who want to register a merchant ship in the Danish register.
When assessing whether one or a plurality of activities meet the activity requirement, we emphasize, among other things:
- That the entire activity is actually carried out in Denmark
- If the entire activity is not carried out in Denmark, then how much is carried out from Denmark - e.g. how many people in Denmark are employed by / are involved in the execution of the activity, and how much the owner pays a Danish entity to carry out the activity. In cases of partial performance of an activity in Denmark, it is to be expected that several activities will be required to be performed in Denmark.
In situations where a foreign-owned ship bound by existing contracts (e.g. bareboat or hourly charter with a non-Danish entity) is to be entered in a Danish ship register, the Danish Ship Register assesses whether there are economic activities (maintaining the contracts) regarding the ship of a scope that meets the requirements of the legislation.
Ongoing compliance with the activity condition and spot checks
We carry out annual random checks of whether the owner of a ship, registered with a non-Danish owner, continuously meets the activity requirement. It is examined whether the information originally provided is still current and whether the assumed scope of the activities is still relevant.
It is important for non-Danish owners of ships in the Danish register to realize that non-compliance with the conditions may result in the ship being removed from the Danish register.