Country guide
Pay transparency in Denmark
What the EU Pay Transparency Directive means for employers in Denmark, based on its national transposition — status, thresholds, the joint-assessment trigger, and where to file.
Denmark missed the 7 June 2026 deadline. A transposition bill was sent to public consultation 26 February 2026 (Høringsportalen sag 71101 — published 26 February, consultation closed 27 March 2026, proposed entry into force 1 January 2027, all three read off the consultation record itself). No bill has yet been tabled: the Folketing's own open-data API returns zero Lovforslag carrying "løn", "ligeløn" or "ligelønsloven" in the title, against positive controls of 30 bills in the current session and 22 cases mentioning "ligeløn" — first reading is expected in the autumn 2026 session and passage anticipated November–December 2026. The bill creates a new competent body, Arbejdsmarkedets Institut for Ligeløn (AIFL). It does NOT move a Danish deadline from June to 1 September: the 7 June is the Directive's, and Denmark exercises the Art. 9(8) option to derogate from it precisely in order to KEEP ligelønsloven § 5 a stk. 1's existing 1 September ("foreslås det at fravige den fastsatte frist den 7. juni og i stedet indsætte en frist til den 1. september, som er den frist, der gælder for kønsopdelt lønstatistik"). Scope phases in under draft § 5 c: 250+ and 150–249 first by 1 September 2028, then annually and triennially respectively; 100–149, and 50–99 where at least 8 employees of each gender share the same 6-digit DISCO group, first by 1 September 2031 and then every third year. All bill figures are AS SENT TO CONSULTATION, not yet enacted, and may change before passage. The pre-existing Ligelønsloven § 5 a wage-statistics regime remains in force in the meantime — the bill would repeal it outright ("§ 5 a ophæves"), with pay data for 2026 staying under the old rules and 2027 onward under the new.
Denmark has a transposition bill in progress but has not yet enacted it. The figures below reflect the directive's defaults and the draft as it stands, and may change before the law is final.
Reporting duties apply by employer size: 35 or more employees, from 2007 · Annual, further conditions apply; 150 or more employees, from 2028 · Every three years (anticipated); 250 or more employees, from 2028 · Annual (anticipated); 50 to 99 employees, from 2031 · Every three years (anticipated), further conditions apply; 100 or more employees, from 2031 · Every three years (anticipated). The directive's 5% trigger for a joint pay assessment applies until national law sets its own.
Figures are reported to the competent authority rather than published openly. Either way, the underlying work is the same: establish work of equal value through gender-neutral job evaluation, produce the statutory pay-gap report in the national format, and run a joint assessment where the gap is too wide.
Obligations at a glance
| Reporting threshold |
|
|---|---|
| Joint pay assessment | — |
| Public publication | Reported to the authority only |
| Competent authority | Ligebehandlingsnævnet (Board of Equal Treatment) — existing discrimination-complaints body; the draft bill creates Arbejdsmarkedets Institut for Ligeløn (AIFL) to receive reports under the new regime, not yet operational |
Frequently asked
Is the EU Pay Transparency Directive in force in Denmark?
Denmark has a transposition bill in progress but has not yet enacted it. The figures below reflect the directive's defaults and the draft as it stands, and may change before the law is final.
Which employers have to report in Denmark?
Reporting duties apply by employer size: 35 or more employees, from 2007 · Annual, further conditions apply; 150 or more employees, from 2028 · Every three years (anticipated); 250 or more employees, from 2028 · Annual (anticipated); 50 to 99 employees, from 2031 · Every three years (anticipated), further conditions apply; 100 or more employees, from 2031 · Every three years (anticipated).
What triggers a joint pay assessment in Denmark?
The directive's 5% trigger for a joint pay assessment applies until national law sets its own.
This guide summarises publicly available information for orientation only. It is not legal advice — confirm every figure against Denmark's own transposition text before relying on it.