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Pay transparency in Denmark

Published draft Last verified 8 August 2026 High confidence
  • 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).

  • Time to respond 2 months

    Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.

  • 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.

Author

Julius Aho

Co-founder, CTO

Julius Aho is the co-founder and CTO of Evenpay. At Evenpay he is responsible for product, engineering and AI, building the tools that make fair pay the default.