Pay transparency in Denmark
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Pay information requests 1 Jan 2027 (proposed)
Own individual pay level and sex-disaggregated average pay levels for the same work or work of equal value (proposed).
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Time to respond 2 months
Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.
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Salary history questions are banned
Applicants learn the pay range before the interview, and employers may not ask what they earn today.
Denmark has published a draft bill that would amend the country’s existing Equal Pay Act to implement the EU Pay Transparency Directive. This is a formal consultation draft, not enacted law, so none of its employer obligations are binding yet.
The proposal is nationwide in scope and would take effect from 1 January 2027, if enacted as drafted. Rather than building a brand new reporting system from scratch, it plugs into Denmark’s existing gender pay statistics framework, so the reporting model is expected to be a hybrid: Statistics Denmark or an employer organisation would typically generate the report, with employers responsible for the underlying data.
For now, the practical task is to watch how the bill moves through the legislative process. The first proposed reporting deadlines, 1 September 2028 for larger employers and 1 September 2031 for smaller ones, give a sense of the runway, but nothing is locked in until the bill is passed.
The measure
- Law or measure
- Bill amending the Equal Pay Act to implement Directive (EU) 2023/970
- Core obligations start
- 1 Jan 2027 (proposed)
- Who is covered
- Proposed rules cover public and private employers
What the law requires
- Pay range before the interview
- Salary history questions banned
- Pay information requests, 2 months to respond
- Gap reporting from 100 employees
- Joint pay assessment at a 5.0% gap
How Denmark differs from the Directive
Proposed hybrid reporting built on existing Danish payroll-statistics infrastructure; first reports are proposed for 1 September 2028/2031. Certain 50-99 employers would be covered where a worker category contains at least eight employees of each sex. Salary information may be provided in an ad, before interview or otherwise before contract; job-ad publication is not mandatory.
On at least one point the national rules go beyond the Directive minimum, so preparing to the EU baseline alone is not enough here.
What this means for employers
Because this is still a draft, you are not yet required to act. But the proposal is detailed enough that you can start preparing now rather than scrambling later, especially since Denmark’s version goes further than the EU baseline in places, such as potentially covering some employers with as few as 50 employees.
- Review your pay structures so you can objectively justify differences in pay for the same work or work of equal value.
- Get ready for recruitment disclosures: the draft would let you share salary information in the job ad, before the interview, or otherwise before a contract is signed, so decide now where in your process that will sit.
- Build in a salary history ban: under the proposal you would not be allowed to ask applicants about their current or past pay, so recruiter training and application forms need a look.
- Plan for employee pay information requests, including a workflow that can produce a response within the proposed two-month window.
- Check your payroll and category data quality, since even under the hybrid reporting model, you would remain responsible for the accuracy of category-level information Statistics Denmark or your employer organisation uses to build the report.
None of this guarantees compliance once the law is finalised, but it helps you prepare for a system that is already well defined in draft form.
Enforcement and open questions
- Competent authority
- Ministry of Employment and Equality
- Equality body
- Danish Institute for Human Rights
- What could still change
- The text is an official consultation draft, not enacted law. Proposed commencement and reporting dates may change. The reporting workflow is hybrid: Statistics Denmark or an employer organisation normally generates the report, while employers remain responsible for category-level completeness and filing.
Common questions
Is Denmark's pay transparency law already in force?
No. It is currently a published draft bill amending the Equal Pay Act, not enacted legislation. The proposed commencement date is 1 January 2027, but that could still change.
When would Danish employers first have to report gender pay data?
Under the draft, employers with 250 or more employees would file their first report by 1 September 2028. Employers with 100 to 149 employees, and certain qualifying employers with 50 to 99 employees, would follow with a first report by 1 September 2031.
Would employees in Denmark be able to ask what others earn?
Yes, under the proposal employees would have the right to see their own pay level and sex-disaggregated average pay for the same or equivalent work. Employers would have a proposed two-month window to respond in writing.
Does the Danish proposal ban asking candidates about their salary history?
Yes. The draft would prohibit employers from asking applicants about their current or previous pay, and would require sharing the initial pay or pay range with candidates before contract.
- Pay information request right Art. 7(1)
- 1 Jan 2027 (proposed)
- Response deadline Art. 7(4)
- 2 months
- Salary range in recruitment Art. 5(1)
- Yes
- Salary history questions banned Art. 5(2)
- Yes
- Joint pay assessment trigger Art. 10(1)
- 5.0%
Own individual pay level and sex-disaggregated average pay levels for the same work or work of equal value (proposed).
Workers would obtain their own pay level and comparator averages.
The employer must answer in writing within this period.
The proposed written response period is two months.
Applicants receive the pay or pay range before the interview, based on objective, gender-neutral criteria.
Applicants would be entitled to the initial pay or pay range.
Whether employers are prohibited from asking applicants about their current or previous pay.
Employers would be prohibited from asking applicants about current or previous pay.
The unjustified gap that obliges the employer and worker representatives to assess pay together.
The draft uses a five-percent category-level gap threshold with cumulative conditions.
- Reporting threshold
- 100 employees
- Reporting model
- Proposed hybrid / centralised Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- First report, 250 or more employees
- By 1 Sep 2028 (proposed)
- First report, 100 to 149 employees
- By 1 Sep 2031 (proposed)
- Metrics required
- EU seven only Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- The draft replaces and builds on the existing Danish gender-segregated pay-statistics framework rather than creating an entirely employer-self-calculated model.
- Formal transposition stage
- Published draft
- Scope
- Nationwide
Next milestone
Monitor enactment; proposed commencement is 1 January 2027 and the first 150+ reports are due 1 September 2028.
Primary sources
- Bill amending the Equal Pay Act to implement Directive (EU) 2023/970 Primary source, checked 8 August 2026 · link temporarily unavailable, we are re-verifying it
- Formal transposition stage Published draft · proposed · high confidence
- Core employer obligations Published draft · proposed · high confidence
- Transposition scope Nationwide · proposed · high confidence
- Salary range in recruitment Yes · proposed · high confidence
- Salary history questions banned Yes · proposed · high confidence
- Pay information request right Yes · proposed · high confidence
- Response deadline 2 months · proposed · high confidence
- Reporting threshold 100 · proposed · high confidence
- First report, 250 or more employees By 1 Sep 2028 (proposed) · proposed · high confidence
- First report, 100 to 149 employees By 1 Sep 2031 (proposed) · proposed · high confidence
- Reporting model Proposed hybrid / centralised · proposed · high confidence
- Joint pay assessment trigger 5% · proposed · high confidence
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.