Danish road toll dispute drags on: hundreds of thousands of kroner frozen, 5,000 appeals pending

Denmark’s new road toll system for heavy goods vehicles came into force on 1 January 2025. Disputes soon emerged over both the amounts charged and the penalties imposed for violations.

Carriers now face two separate issues. The first concerns the recovery of overpaid tolls; the second involves the future of penalties issued under the original enforcement model. In both cases, the Danish transport organisation International Transport Danmark (ITD) is calling on the authorities to provide clear rules and definitive decisions.

More than 18 months without a toll refund

According to ITD, several thousand cases have emerged since the new system was introduced in which transport companies were charged more than they should have been. The most common problem was that companies were charged twice for the same journey. This could happen, for example, when two tolling devices were active in the same vehicle at the same time.

The organisation has also identified overpayments resulting from incorrect information in Denmark’s vehicle register, Motorregistret. In some cases, carriers were even charged for driving across their own premises.

Despite the system having been in operation for more than 18 months, ITD says companies have still not received refunds for the amounts collected incorrectly.

It is completely unacceptable for companies to wait this long to recover their own money, says Stefan K. Schou, managing director of International Transport Danmark.

ITD has raised the matter with the Danish minister responsible for taxation, calling for a clear and efficient refund process.

Hundreds of thousands of kroner tied up

For some carriers, the sums involved are far from negligible. ITD says certain companies are waiting to recover several hundred thousand Danish kroner. The uncertainty concerns not only how long the process will take, but also when the money will be returned and which procedure will apply.

ITD says it called on the authorities to create a mechanism for correcting incorrect charges quickly, even before the toll was introduced. Schou acknowledges that errors cannot be completely eliminated from complex charging systems. In his view, the priority should be a simple process that allows mistakes to be corrected quickly.

According to the organisation, no such mechanism is yet in place.

Appeal procedures remain unclear

The appeals process for incorrectly calculated tolls is creating another layer of uncertainty. Several test cases have been awaiting a decision from Denmark’s Road Directorate, Vejdirektoratet, for months. Their outcome is expected to help establish how similar cases should be handled in the future.

However, basic procedural questions remain unanswered. One point of uncertainty is whether carriers must file a separate appeal for every incorrect charge, for every vehicle and for every day.

The online system used to submit appeals has also experienced technical problems. ITD says these issues have continued for almost six months.

The second dispute: around 5,000 penalty appeals

Refunds are not the only unresolved issue surrounding Denmark’s road toll system. On behalf of its members and clients, ITD is handling around 5,000 cases involving appeals against penalties. The organisation is also engaged in legal proceedings against Denmark’s transport and taxation ministries.

At the centre of the dispute is the penalty model used after the toll system was launched.

ITD says the Danish transport and taxation ministries have acknowledged that the previous enforcement practice was not consistent with the proportionality principle under EU law. The change in approach was reported to the Danish parliament on 25 June 2026.

ITD argues that the penalties imposed under the former model should therefore be cancelled.

The ministries themselves have accepted that the earlier enforcement practice did not comply with the proportionality principle in EU law. The conclusion should be clear: these penalties must be cancelled, says Schou.

Penalties largely suspended in December

The issuing of penalties linked to the new road toll was largely suspended on 18 December 2025. Until the new rules entered into force on 26 June 2026, penalties were issued only in specific situations, such as when a vehicle had no active tolling device or no valid route ticket assigned to it. The question now is what will happen to penalties issued between 1 January 2025 and 18 December 2025.

Before the summer recess, the ministries said they were working on a solution for penalties from that period. Kammeradvokaten, which represents the Danish state, told ITD that the ministries’ position on how those cases should be handled is expected in mid-September 2026.

That decision will also affect the next stage of ITD’s legal dispute.

ITD ready to continue the court case

The organisation says it will not withdraw its legal action if the old penalties remain in force.

We cannot accept a situation in which the state first acknowledges that its penalty practice was unlawful and then makes carriers bear the cost of that practice, says Stefan K. Schou.

ITD says it is prepared to continue the court proceedings unless the ministries resolve the issue of the earlier penalties and cancel them.

Collecting the toll is only half the system

The two disputes involve different legal and procedural questions. The overpayments concern how charges are corrected and refunded, while the approximately 5,000 appeals concern the consequences of applying the previous penalty rules.

They are nevertheless linked by broader concerns about how effectively the new toll system works. Calculating the correct charge is only one part of the process. Equally important are clear error-handling procedures, a straightforward appeals route and the ability to correct decisions quickly.