With the closure of orders from the Danish Financial Supervisory Authority (the Danish FSA), the setting of debt to zero for almost 13,000 customers in the legacy systems, and the submission of the impartial reviewers’ final reports, Danske Bank is taking the last steps towards closing its debt collection case.

As of 19 November 2025, the Danish FSA has decided to close orders issued to Danske Bank to address and mitigate past errors in its debt collection systems. This also marks the end of the impartial review.

The final reports from the impartial reviewers focus on the progress made in remediating customers affected by the debt collection errors and the restart of the bank’s debt collection activities.

Danske Bank is satisfied that, in their final reports on the progress on remediation and restart of debt collection, the impartial reviewers conclude that:
“In addition, it is our overall assessment that the bank with a high degree of certainty has calculated or will calculate compensation that matches or exceeds the loss incurred by customers as a result of the issues for which the bank has decided to provide compensation at its own initiative.”

And furthermore:

“Initially, we note that the material that we have received generally reflects that the bank has made a large number of choices to reduce the risk of errors in the new debt collection solution and that the bank also actively draws knowledge from Programme Olympia¹ in order to ensure that the errors having affected the bank’s debt collection via the DCS and PF debt collection systems do not occur in the bank’s new debt collection solution.”

Status on remediation
The ongoing remediation of debt collection cases affected by systemic errors in Danske Bank’s debt collection has entered its final phase. Danske Bank has compensated or attempted to compensate approximately 90% of the customers in scope for compensation, excluding estate case customers. To date, more than 50,000 debt collection customers have received compensation. At the same time, the bank is working closely with the courts to expedite the resolution of the estate cases as quickly as possible (covered in the impartial reviewers’ report no. 6).

Setting debt to zero
To provide clarity and to minimise the risk of repeating past mistakes upon restarting the debt collection, the bank has decided to set the debt to zero for almost another 13,000 personal customers whose debt collection cases have been paused since October 2020 and remain paused to date.

Regarding the impartial reviewers’ report no. 8 on the progress on remediation
Danske Bank is satisfied that the impartial reviewers conclude as follows:
” … it is our overall assessment that the bank’s overall approach to remediating and paying compensation in the debt collection case – with the reservations and comments made in the report – is suitable for ensuring that the affected customers, with a high degree of probability, will receive adequate compensation and that the remaining cases can be closed within the planned time horizon.”

During the clean-up of the debt collection case, the bank discovered that some customers had mistakenly been charged unjustified reminder fees. This had occurred in the bank’s reminder process and not in the debt collection systems, which the debt collection case concerns. The vast majority of these customers have neither previously nor subsequently been involved in the bank’s debt collection case, and the issue has not been considered part of the actual debt collection case. Some of these customers are entitled to remediation, and the bank has decided to compensate customers who made their last payment in June 2010 or after, in line with legal requirements.

Danske Bank has, on the same legal basis, decided to remediate cases from June 2010 and onwards related to sub-issue 21b, where customer data was deleted due to the implementation of GDPR-related measures in 2018 and 2019.

According to the impartial reviewers, Danske Bank has implemented and continues to maintain preventive measures considered appropriate to avoid unjustified accrual of debt and collection of debt. This includes the suspension of debt collection and the suspension of interest accrual, generally from 1 October 2020. For outstanding balances as of this date, the bank has largely opted for debt relief and resetting, with recalculations carried out in a few cases. This combined approach has brought the portfolio close to final resolution.

The impartial reviewers also note that compensation to customers who have been subject to overcollection has been calculated and paid on an ongoing basis, primarily using Programme Olympia’s calculation model, supplemented by individual recalculations and manual reviews where required.

Finally, the impartial reviewers state that the bank’s validation framework and risk controls ensure a minimal risk of under-compensation. For cases where losses cannot be determined without input from customers, a process has been established to handle customer enquiries, supported by targeted communication in conclusion letters and on the bank’s website.

Solution for new debt collection customers
At the same time, Danske Bank has initiated the process of restarting its debt collection activities, which is progressing according to plan. The bank has entered into an agreement with a debt collection agency to manage part of the bank’s debt collection process.

The bank has designed a debt collection framework that will manage all incoming debt collection cases. Approximately 68% of these – primarily related to simple products and loans – are correctly processed by the bank’s new setup, which is expected to handle 90% of all new debt collection cases by next year. Until this setup is fully operational, new cases not yet managed by it will be transferred directly to the above-mentioned debt collection agency. Over the next year, the bank expects to transfer around 1,700 new debt collection cases to this partner. The bank has thoroughly reviewed the cases to be transferred to ensure they do not contain flawed data stemming from historical issues.

Regarding the impartial reviewers’ report no. 7 on the restart of debt collection
Danske Bank is satisfied that the impartial reviewers conclude as follows:
“The bank generally involves relevant experts in its development work, which also helps reduce the risk of future errors. In the areas examined – and subject to the comments set out in this report, the bank is found to have established a sound basis for further developing the new debt collection solution.”

The review of the new debt collection solution is based on investigations conducted by Group Internal Audit during the second half of 2024, including an audit report issued in March 2025 and the supporting working papers. Additional consideration has been given to the bank’s subsequent actions addressing the observations raised by Group Internal Audit, as well as Group Internal Audit’s follow-up assessment in August 2025.

According to the impartial reviewers the reviewed material indicates that the bank has implemented numerous measures to minimise the risk of errors in the new solution, while actively applying learnings from Programme Olympia to prevent issues previously encountered in the bank’s debt collection. Furthermore, the bank’s involvement of relevant experts in the development process further mitigates the risk of future errors.

Overall, it is the assessment of the impartial reviewers that the bank has established a solid foundation for further development of the new debt collection solution, subject to addressing specific observations outlined in the report. Additionally, the internal audit report demonstrates thorough and comprehensive work, and the development programme has responded swiftly and effectively to Group Internal Audit’s findings. A plan is also in place for Group Internal Audit’s activities, ensuring a focus in the first half of 2026 on areas that could not be fully addressed in the March 2025 report.

Danske Bank notes that, in relation to the restart of debt collection, the impartial reviewers highlight certain topics that have posed challenges during the process. The bank emphasises that it is crucial for the new debt collection system to be both compliant and well-functioning in order to prevent a recurrence of past issues in the future debt collection. Accordingly, Group Internal Audit is closely monitoring the implementation of the new system. At the same time the bank closely coordinates with the Danish FSA to ensure that the system is only regarded as definitively implemented once all relevant quality checks have been completed and the bank has confidence in the new setup.

Closure of the impartial investigation process
Danske Bank notes the findings of the impartial reviewers in reports nos. 7 and 8 and their contribution to the development of the remediation of customers affected by the debt collection errors and the restart of the bank’s debt collection activities.

Download the impartial reviewers report 7 (Danish) on the progress on the restart of debt collection.
Download the impartial reviewers report 8 (Danish) on the progress on remediating customers affected by the debt collection case.
Download report 8, appendix 1 (Danish).
Download report 8, appendix 2 (Danish).

¹Danske Bank's Programme Olympia is the bank’s internal name for the remediation project related to its debt collection systems.