The Insurance and Reinsurance Law Review: Denmark
The majority of Danish insurance companies are members of Insurance and Pension Denmark (IPD), an association that promotes the interests of the entire insurance (and pensions) industry. Foreign insurance companies engaged in the provision of services in Denmark may become 'info' members.
The Danish insurance market is characterised by strong competition for customers. According to the statistics published by the association, the number of Danish insurance companies has more than halved over the past 20 years, from 138 companies subject to Danish supervision in 1999 to 62 in 2019.2 In the same period, the number of employees fluctuated, from 13,751 in 1999 to 10,305 in 2005, to 13,533 in 2014, to 10,343 in 2017, to 8,211 in 2018 , but then rose to 10,636 in 2019.3 Customers are also switching between companies more frequently to get better cover and prices.4 Customer satisfaction in 2020, with a score of 77.2 per cent, was at the lowest it has been since 2012, when the customer satisfaction score was 75.7 per cent.5
The annual profit of the insurance industry increased by 65.1 per cent from 2018 to 2019, to 13.8 billion Danish kroner before tax.
In terms of the balance sheet total in 2019, Tryg Forsikring was the biggest insurance company in Denmark, followed by Codan and Danica.6 The statistics only cover companies in the Danish market under Danish supervision.
i The insurance regulator
The insurance market is regulated and the requirements for establishing and carrying on insurance business are laid out in the Danish Financial Business Act.7
However, a large number of other statutory provisions also apply, including those contained in:
- the Danish Anti-Money Laundering Act;
- the Danish Companies Act;
- the Danish Capital Markets Act; and
- the Danish Act on Processing of Personal Data.
The Financial Business Act also applies to reinsurers. However, special rules for these companies may also apply.
The Danish Financial Services Authority (FSA)8 monitors and regulates the financial sector in Denmark, including insurance and reinsurance companies. The purpose of the FSA is to supervise, legislate and provide information. In 2018, the FSA was authorised to obtain information from enterprises subject to the new Danish Insurance Mediation Act9 (see Section II.ii, 'Insurance distribution'). The FSA is also authorised to obtain information from persons and enterprises not subject to the Act to assess whether they should be subject to the rules.
The FSA may prosecute, issue orders and report issues to the police if insurers or reinsurers fail to comply with the rules applying to financial services firms and, as another consequence of the new Act, violation of the rules of the Act could be punishable by a fine or imprisonment for up to four months.
ii Registration with the FSA
Insurance and reinsurance companies
Insurance and reinsurance business in Denmark require a licence from the FSA.10 The licence is issued based on a plan of operations prepared by the insurer or reinsurer. The FSA establishes the rules for the information that must be included in the plan of operations.
Foreign insurance and reinsurance companies in the European Economic Area and European Union
Insurance and reinsurance companies from other Member States of the European Economic Area (EEA) or the European Union (EU) may carry on insurance business in Denmark on either an establishment or a freedom-of-services basis (without the need for a licence from the FSA) if they have already been licensed in another EEA or EU Member State.
These companies may operate in Denmark on a cross-border basis immediately after the FSA has received notification from the supervisory authorities of the company's home country or the home country can notify the FSA and the company may operate through a branch in Denmark two months after the notification has been given.11
The company must observe Danish good business practice rules, consumer protection regulation and certain insurance contract requirements that are contained in, for example, the Insurance Contracts Act (ICA).12
Foreign insurance and reinsurance companies from outside the EEA or the EU
Insurance and reinsurance companies from outside the EEA or the EU may not carry on insurance business in Denmark using a licence from their home country.
If the company wants to carry on business in Denmark, it is required to set up an insurance company or a branch in Denmark and apply for a licence from the FSA.
As a result of the implementation of the EU Solvency II Directive into Danish law (with effect from 1 January 2016), the law distinguishes between Group 1 and Group 2 insurers. Group 1 insurers are big companies calculated (among other factors) according to their gross annual premium. Group 2 companies include all other companies.
Depending on which group the insurer belongs to, there will be different additional capital and solvency requirements, as well as organisational requirements.
On 1 October 2018, the new Insurance Mediation Act came into force, implementing the EU Insurance Distribution Directive into Danish law. The Act increases the protection of consumers by, among other things, introducing stricter licence and registration requirements. It is no longer enough for agents and subagents to be registered; they must also have a licence from the FSA (provided that they fall under the definition of insurance intermediaries).
Enterprises selling goods or services and selling insurance in connection with the sale of these other goods or services are not required to have a licence but must be registered. This applies to travel agents and car dealers, for example.
One requirement for receiving a licence from the FSA to distribute insurance is that the registered office of the enterprise is in Denmark. It is also a requirement that the enterprise has liability insurance or another corresponding guarantee against claims for damages and has measures in place ensuring that customers are protected against the distributor's inability to pay. The enterprise must also have a management fulfilling the suitability and integrity requirements of the Act, ensuring a responsible and efficient operation of the insurance intermediaries.
It follows from the transitional provisions of the Act that enterprises already licensed as insurance brokers before the Act entered into force have to submit a new application, but that the enterprise may continue its activities until the FSA has made a decision on the matter.
The same applies to enterprises registered as insurance agents or as subagents and to enterprises selling insurance that did not require a licence under the preceding Act. These enterprises must submit an application for a licence but may continue their activities until the FSA has made a decision.
If insurance is effected before a licence to carry on insurance business has been issued and registration has been made, the individuals who have effected the insurance or who are responsible are jointly and severally liable for the performance of the contract. However, if the insurer accepts the liability no later than four weeks after registration, the liability is repealed (provided that the policyholder's security is not significantly weakened as a result).13
If the rules for are not complied with, the FSA can exercise certain powers. For instance, an order may be issued stipulating that the insurer or reinsurer will be subject to strict supervision. Ultimately, the company could risk losing its licence to carry on business in Denmark.
The members of the executive board and the board of directors of an insurance or reinsurance company may incur liability if the management does not fulfil the necessary requirements.
iii Compulsory insurance
A number of specific laws, contracts and other regulation stipulate that compulsory insurance cover must be taken out in certain areas, including the following: motor vehicle; professional liability (for some advisers, such as lawyers and accountants); industrial injury; dog and horse liability; railway liability; aviation liability; occupational disease; oil pollution; maritime claims (for all Danish ships with a gross tonnage of 300 or more); drones (that are not micro-drones); and, as of 15 May 2018, injuries caused by jet skis, etc., in connection with maritime accidents.
Insurance brokers must also take out liability insurance and provide security for the claims that may be raised against them as a result of their business.
Insurance and reinsurance law
i Sources of law
The ICA regulates insurance contracts and provisions, which are mandatory to a certain extent, governing the relationship between an insurer and a policyholder.
Different rules on consumer protection and good practice also apply (e.g., the insurer must give correct advice on insurance products). These rules must be complied with or the advisers may incur professional liability. The rules on good practice are laid down in Part 6 of the Financial Business Act and they apply to insurers in contractual relationships.
The ICA does not apply directly to reinsurance, but it is applied by analogy together with the general law of contract, including the freedom of contract.
Insurance brokers and others selling insurance commercially are subject to the Danish Insurance Mediation Act (see Section III.iv).
ii Making the contract
Any issues relating to the rights and obligations between an insurer and a policyholder are regulated by the ICA. However, the characteristics of an insurance contract are not defined in the ICA but are governed by the Contract Act14 and the general principles of Danish contract law, including freedom of contract (for some areas insurance is compulsory – see Section II.iv).
An insurance contract is generally defined as 'an agreement to take over a financial risk for the occurrence of an unexpected event, against a consideration calculated statistically based on the distribution of that risk on a plurality of policyholders'.15
When entering into an insurance contract, an insurance seeker will usually apply for cover from the insurance company, after which it will fill out a form with a number of questions provided by the insurance company. The underwriters will draft the policy terms based on the information provided and enter into an insurance contract with the insurance seeker on behalf of the insurer.
A general duty of good faith and fair dealing in respect of other contracting parties applies to all contractual relationships. Furthermore, when it comes to insurance and reinsurance contracts, the ICA stipulates that the insurance seeker has a duty of disclosure and to provide answers. If it fails to answer the questions in the application form truthfully or fails to disclose an important fact, the rules of the ICA will determine whether an insured event is to be compensated and whether the company is bound by the contract at all.16
The insurance premium must be paid 21 days after a claim for payment has been made. Only then may the insurer terminate the insurance contract.
iii Interpreting the contract
Denmark has a civil law system that is based to some extent on general rules and principles and, in line with the interpretation of other contracts, the interpretation of insurance and reinsurance contracts is subject to these rules and principles.
The interpretation of an insurance contract involves both the disputed provision and the agreement as a whole, including the other provisions of the contract and the background and purpose of the contract.
As a general rule, the provisions of an insurance policy should be interpreted strictly and in relation to the other provisions of the policy (both general and specific).
If the policy wording generates doubt as to the contents, the circumstances of the conclusion of the contract and the purpose of the insurance may be included in the interpretation. Occasionally, ambiguities regarding the contents of the specific policy provision will be detrimental to the insurers that wrote the policy (the ambiguity rule).
When interpreting the contract, the ICA and the general rules of contract law must always be read with a consideration of trade usage, case law and other legal standards and rules of interpretation that apply (which can vary depending on the contract type).
iv Intermediaries and the role of the broker
Insurance mediation is regulated by the Insurance Mediation Act. The Act does not apply to insurers, but rather to brokers and other parties that have a licence to sell insurance commercially. This licence is issued by the FSA. According to the Act, insurance agents will also require a licence from the FSA to carry out activities (see Section II.ii, 'Insurance distribution').
The parties responsible for insurance mediation must have general knowledge of insurance mediation. The responsible persons must have theoretical training in, and practical knowledge of, insurance mediation activities. Insurance brokers must comply with the duty of disclosure and other obligations about regular reporting.
The FSA monitors insurance brokers. If the insurance broker does not comply with the guidelines laid down in the Insurance Mediation Act, the FSA may cancel the insurance broker's licence to sell insurance commercially.
The party with an insurance claim must file the claim with the insurer before the statute of limitations expires. There are no formal requirements on how an insurance claim must be filed and thus it can be made both orally and in writing. In recent years it has become commonplace to file the claim through a form on the insurer's website.
It is sufficient in respect of certain types of business insurance that a party entitled to damages has filed its claim for damages with the policyholder in time (the business covered by insurance).
A policyholder must provide the insurer with all available information on matters of significance to the assessment of the claim. If the holder fails to do so, the insurer may refuse to take a position on the insurance claim.17
An insurer may also refuse to provide cover to a policyholder or a third party entitled to damages if the claim for damages or the insurance event has not been proved or if it is clear that the claim is not covered by or is exempt from the insurance cover.
An insurer may also refuse cover if the insurance contract was based on incorrect information given by the policyholder. The insurance contract is either void (based on fraudulent misrepresentation or non-disclosure) or the insurer is exempt from liability or entitled to reduce compensation (based on a negligently false statement).
vi Third-party action
An injured third party is free to file a claim directly with the insurer if the claim is filed under liability insurance. The insurer is directly liable to an injured third party in certain situations (e.g., bodily injury caused by a motor vehicle).
When the insured's liability for damages to the injured party has been established and the amount of damages assessed, the injured party must be subrogated to the insured's rights against the insurer, but only to the extent that the party entitled to damages has not already received the amount claimed in whole or in part.18
A policyholder cannot be a party to a reinsurance contract and cannot file a claim directly with the reinsurer. As a contractual party, the insurer may file a claim with the reinsurer.
As a general rule, if an insurer has paid damages to an injured party, it is subrogated to the injured party's claim. However, the Danish Act on the Liability to Pay Compensation contains important exemptions in this regard, as it limits an insurer's right to recourse in many situations where insurance cover has been taken out.19
i Jurisdiction, choice of law and arbitration clauses
Insurance litigation and arbitration are governed by the Danish Administration of Justice Act20 and the Danish Arbitration Act.21 Regarding the issues of jurisdiction and the choice of laws, Denmark has ratified the relevant parts of the Brussels I Regulation, the Lugano Convention, the Hague Convention and the Rome Convention.22
As a general rule, parties may agree both before and after a dispute has occurred that proceedings are to be heard in Denmark by a specific court. However, in certain instances the courts in a specific country have exclusive jurisdiction and the consequence is that the agreement cannot be relied upon. The parties are not allowed to agree that a case is to be heard by a court that has no jurisdiction in respect of the substance of the matter. For example, the parties are not allowed to agree that the case is to be brought before the Danish Supreme Court as the court of first instance.
In addition, the parties may agree to resolve disputes by arbitration. They may also enter into an arbitration agreement either before or after a dispute has arisen, which Danish courts will recognise and enforce, if the arbitration clause has the necessary clarity. Both written and oral arbitration agreements are valid under Danish law. However, to enforce the agreement, the Danish Institute of Arbitration recommends the following standard clause to be included in the contract:23
Any dispute arising out of or in connection with this contract, including any disputes regarding the existence, validity or termination thereof, shall be settled by arbitration administrated by The Danish Institute of Arbitration in accordance with the rules of arbitration procedure adopted by The Danish Institute of Arbitration and in force at the time when such proceedings are commenced.
With regard to a consumer contract, the costumer is not bound by an arbitration agreement concluded before the conflict arose.
Any disagreement between the insurer and a consumer regarding an insurance policy may be brought before the Insurance Complaints Board, directly before the courts or settled by arbitration (see Section IV.iii).
The Insurance Complaints Board
In the event of any disagreement between the insurer and a consumer regarding an insurance policy, the matter may be brought before the Insurance Complaints Board,24 which is a private complaints board authorised by the Minister for Business and Growth.
The advantage of bringing the matter before the board is that it is possible to get a decision in a few months if the policyholder pays a nominal amount. Any decision by the board may be brought before the relevant district court. As a main rule, the board only hears complaints concerning insurance taken out by private individuals.
The judicial system
In broad terms, the judicial system is composed of the Supreme Court, the High Courts of Western and Eastern Denmark, the Maritime and Commercial Court, the Land Registration Court and 24 district courts.25 No courts in Denmark are specialised in insurance disputes, so as a general rule insurance cases (like all other court cases) commence in the district courts.
The legal system is based on a two-tier principle, according to which it is usually possible to appeal against a decision made by a court once. However, there are many exceptions to this rule. If a case is of general public importance (implications for rulings in other cases),26 the Danish Appeals Permission Board27 may grant leave to appeal to a court of third instance (the Supreme Court).
In addition, if the case involves a matter of general public importance, the district court may commit the case to one of the high courts upon request.28 In this case, the first instance high court judgment may be appealed directly to the Supreme Court.
Judgments delivered by a district court concerning an amount of less than 20,000 kroner cannot be appealed without leave from the Appeals Permission Board. The high courts may also dismiss an appeal if there are no prospects of a result different from that of the district court.
The Maritime and Commercial High Court is a specialised first instance court.29 The Court hears cases concerning the Danish Trademarks Act, the Danish Designs Act, the Danish Marketing Practices Act and the Danish Competition Act and cases concerning international trade conditions, as well as other commercial matters. The Court is not specialised in insurance law. Decisions passed by the Maritime and Commercial High Court may be appealed to the Supreme Court if the case is of general public importance; otherwise, they will be appealed to one of the high courts.
The main stages in civil proceedings30
A court case is initiated by the plaintiff filing a writ with the court. The defendant will then file a statement of defence if the defendant disputes the plaintiff's claim. The exchange of pleadings may take several months.
Further pleadings will often be exchanged and a pretrial hearing (by telephone) will be held during which the court discusses the matter with the parties. An expert opinion may also be requested at that stage. The duration of the procedure depends on the nature of the case and can vary from a few months to more than a year.
When the case has been set down for the final hearing, the court will inform the parties of when the pretrial stage ends. After this date, new claims, allegations or evidence will not, as a general rule, be permitted. After the final hearing, the court will make its decision on the claims submitted. Normally, one to two months will pass from the time of the conclusion of the pretrial stage until a final appealable judgment is delivered.
Sometimes the court will decide on procedural issues during the case, including on whether to admit certain evidence, whether to commit the matter to another court, etc. These procedural issues may, as a general rule, be appealed during the case; however, this is often subject to prior leave by the Appeals Permission Board.
For cases involving claims of up to 50,000 kroner, the case may be brought before the courts according to the cheapest and fastest small-claims procedure.
Time frame for insurance litigation
Insurance litigation includes everything from small cases to large and complicated claims for damages covered by business insurance. A hearing by a court of first instance could take anything from a few months to several years. According to the most recent statistics published by the courts in 2018, the average case processing time in civil cases decided by settlement or judgment before the district courts was 10 months.31
As a general rule, the parties are free to determine which evidence and legal issues should be considered in cases and all types of evidence, in board terms, are admissible.
The most important types of evidence are documents, witness statements and expert surveys by specialists who may be examined in court. Expert opinions or expert witnesses are not widely used because expert surveys (reports based on an appraisal by experts appointed by the court) are preferred; however, new rules encourage their use to a wider extent. Courts may bar unnecessary evidence, but they are generally reluctant to do so. Evidence produced by an illegal or criminal act is also admissible in most cases, but the court will decide the level of importance to attach to the evidence.
The court may also, either at the request of one of the parties or on its motion, request the opponent to produce relevant evidence and may also bar unnecessary evidence.32 The evidence is for the court to assess and is not subject to particular rules. Even in the absence of a pending case, evidence may be taken before a court without a trial, including for use in a later case. In personal injury matters, special bodies have been established by law that provide medical assessments of the nature of the personal injury or assessments of the extent and impact of the personal injury.
Persons called as witnesses of fact are not allowed to make observations as experts when giving evidence. They are therefore only allowed to give evidence of their knowledge of the incident in the specific case. Written statements on factual information may be used as documentary evidence and are sometimes used as an alternative to witness statements, provided that the court has no objections.
Witness statements are generally presented during the final hearing. However, in special cases, the court may decide that the statement is to be given before the final hearing. The witness statement may be given by using telecommunication (with or without an image) if found appropriate and if special considerations for the witness favour the procedure (e.g., if a witness resides abroad).33
The disclosure of documents and witness statements is subject to some limitations.34 As a result, persons bound by professional secrecy cannot give evidence about matters that have come to their knowledge in the course of their function.
The institution of proceedings is subject to a court fee of 500 kroner.35 If the value of the case exceeds 50,000 kroner, another 250 kroner is added, plus 1.2 per cent of the part of the value of the case exceeding 50,000 kroner. However, the court fee cannot exceed 75,000 kroner. If the matter concerns a review of a decision by an authority, the maximum fee is 2,000 kroner. The same applies to certain other types of cases. If appealing to the Supreme Court, the court fee is increased by 50 per cent.
In addition to the fee payable if the value of the matter exceeds 50,000 kroner, a fee is to be paid for the final hearing (the trial hearing) or the written proceedings that may replace the trial hearing. The fee will generally be the same as the fee for instituting proceedings.
As a general rule, it is the party making or requesting a procedural step that, provisionally, has to pay the costs in this respect. The unsuccessful party to a case will usually have to compensate the costs of the successful party. Legal fees, however, are not covered according to realised costs, but will be fixed according to certain rates as a rule, depending on the financial value of the claim and whether an expert opinion has been obtained.
The parties are entitled to agree that an insurance dispute is to be settled by arbitration and both ad hoc and institutional arbitration are widely used. The framework applying to arbitration follows from the parties' contract and the Arbitration Act, which follows the UNCITRAL Model Law of 1985 to a wide extent.
Denmark does not have a specific board of arbitration that deals with insurance disputes, but several institutes handle arbitration cases. The Danish Institute of Arbitration36 processes all types of cases, and the rules governing the arbitration procedures of the institute entered into force on 1 May 2013. The Arbitration Board37 is reserved for construction matters.
In the Danish Institute of Arbitration, the judges are usually appointed by the parties, whereas the chairman is appointed by the Institute. Expert judges usually participate in Arbitration Board cases. Both institutions offer mediation, conciliation and expert opinions. These methods are used to a minor extent, but in particular there is a trend towards mediation being an attractive alternative to the parties. Mediation is also offered by the special institution, the Mediation Institute, and by individual mediators.
At the request of the parties, the court may appoint a mediator to assist the parties in reaching a settlement during the proceedings,38 but it has no powers to force the parties to participate in mediation.
Mediation is also offered by the Danish Mediation Institute39 and other private, independent institutions.
Year in review
In Denmark, as in most of the world, covid-19 has been the dominating topic in 2020. This also holds true for the area of insurance law, where questions such as whether insurance policies cover covid-19-related losses (e.g., a business interruption policy and losses related to Denmark's lockdown) have yet to be answered. It is reported that covid-19 made the second quarter of 2020 very busy for insurance companies, which had to help thousands of Danes who had to end their holiday abroad abruptly, cancel their planned holiday or were stranded abroad. During the summer, however, the insurance companies recorded a lower number of claims arising from burglary. The IPD reports that this decrease resulted from more people working from home. The insurance companies have in general also reported a lower number of claims under car and travel insurance policies in this period. There has, however, been an increase in claims under private health insurance policies, as people working from home have experienced more physical health detriments as a result of their changed working conditions.40
As expected, 2020 was a year of increased focus on cyber risk, and this was also due to covid-19. Both the sales of cyber insurance and the number of incidents and consequential claims increased in 2020. In 2019, Tryg sold 10,000 cyber insurance policies (22 per day) to mid-cap companies.41 In September 2019, the Danish hearing healthcare company Demant announced in a message to its investors42 that a ransomware infection had resulted in a significant loss of up to US$95 million, including an anticipated payout from Demant's insurance company of 100 million kroner.
The Danish Insurance Mediation Act entered into force in October 2019. There has been an intense focus of attention on the Act, but so far there have been no published complaints or cases to show how the Act will be administered or sanctioned and thus it must be assumed that there will be a continued focus on the Act in 2021.
Outlook and conclusions
i Climate change risk and litigation
There has been a significant focus on climate change risk and litigation in 2020 and this focus is expected to increase in 2021. While our Scandinavian neighbours in Sweden and Norway as well as a wide range of other European countries have been hit by climate-related legal actions against the oil, gas and energy sector and against public authorities, Denmark has not (yet) seen any climate-related litigation. Thus, the various actions and decisions within this field highlight the need for the Danish insurance industry also to address the issue of climate change, at both the underwriting and the structural level.
An aspect to consider is the fact that some companies, such as those in the oil, gas and energy industry, could be more vulnerable to climate change risks. It will become even more important in 2021 for directors and officers (D&O) to demonstrate that they have considered climate change risks and taken action to mitigate these risks where necessary. This means that D&O insurers may be affected by climate change disclosure claims in the year ahead.
It is also likely that more may be asked of insurers in terms of taking steps to prevent a worsening of the situation in relation to climate-related losses, including adjusting activities to mitigate the impact of risks of this kind.
ii Cyber risk
The above-mentioned increased focus on cyber risk in 2020 is likely to continue in 2021, with constantly evolving cyberthreats giving rise to different scenarios concerning the devolvement of losses and ongoing considerations as to how customers' risk should be assessed and how premiums and damage coverage should be priced.
Also in relation to cyber risk, covid-19 continues to create new challenges for businesses as they adapt to an operating model in which working from home has become the 'new normal'. Despite the rising use of technology, many organisations still do not provide a 'cyber-safe' remote working environment.
Thus the question of whether claims from shareholders against boards of directors and senior executives in relation to cyberattacks can trigger D&O insurance is expected to continue to be a hot topic in 2021.
As a result of increasingly sophisticated information technology and the corresponding extent of cyber-related damages, we expect to see an increased focus on asset tracing investigations, especially in relation to fraud concerning chief financial officers.
iii Digitisation and new technologies
Digitisation and new technologies provide insurers new opportunities for customer retention, customer satisfaction and access to new segments that have been out of reach, so far.
Several new insurtech startups are challenging the traditional Danish industry with user-friendly solutions. A common feature is that they have a clear focus on the customer's needs while offering flexible solutions and good user experiences. An example of this is Undo,43 a Danish start-up that reaches its customers through an app and has a focus on, and mainly appeals to, a young target group.
As mentioned above, the hottest topic in 2020 within the area of insurance law (as in most areas of law) has been covid-19. As yet, there have been no (published) judgments regarding covid-19 related claims and only a few Insurance Complaints Board cases have been recorded – all relating to travel insurance policies. It is thus expected that questions and disputes regarding coverage for covid-19-related losses will continue to be a hot topic in 2021.
1 Henrik Nedergaard Thomsen and Sigrid Majlund Kjærulff are partners at Poul Schmith.
7 Consolidated Act No. 1447 of 11 September 2020.
9 Consolidated Act No. 378 on Insurance Distribution of 2 April 2020.
10 Section 11(1) of the Financial Business Act (Consolidated Act No. 1447 of 11 September 2020).
11 Sections 30 and 31 of the Financial Business Act (Consolidated Act 1447 of 11 September 2020).
12 Consolidated Act No. 1237 of 9 November 2015.
13 Section 22 of the Financial Business Act (Consolidated Act No. 1447 of 11 September 2020).
14 Consolidated Act No. 193 of 2 March 2016.
15 Ivan Sørensen, Forsikringsret, sixth edition, p. 57, with additional references.
16 Sections 4 to 10 of the ICA (Consolidated Act No. 1237 of 9 November 2015).
17 Sections 21 and 22 of the ICA (Consolidated Act No. 1237 of 9 November 2015).
18 Section 95 of the ICA (Consolidated Act No. 1237 of 9 November 2015).
19 Part 2 of Consolidated Act No. 1070 of 24 August 2018. Corresponding limitations can be found in other acts.
20 Consolidated Act No. 1445 of 29 September 2020.
21 Consolidated Act No. 553 of 24 June 2005.
22 Consolidated Act No. 1282 of 14 November 2018 on Recognition and Enforcement of Certain Judicial Decisions in the area of Civil and Commercial Law and Consolidated Act No. 139 of 17 February 2014 implementing the Rome Convention on the Law Applicable to Contractual Obligations.
25 www.domstol.dk/om/otherlanguages/english/thedanishjudicialsystem/Pages/TheDanishjudicialsystem.aspx and Section 1 of the Administration of Justice Act.
26 Section 371 of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
28 Section 226 of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
29 Section 14-17 of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
30 Part 33 of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
32 Sections 298 and 299 of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
33 Section 174(2) of the Administration of Justice Act (Consolidated Act No. 1445 of 29 September 2020).
34 Sections 169 to 172 the Administration of Justice Act.
35 Consolidated Act No. 1252 of 27 November 2014 on Court Fees.
38 Part 27 of the Administration of Justice Act (Consolidated Act No. 938 of 10 September 2019).