EU Pay Transparency Directive Status Denmark: Missed: Draft Delayed
Denmark's Ministry of Employment published a draft bill on 26 February 2026 to transpose the Directive through amendments to the Danish Equal Pay Act, and sent it out for public consultation. The draft had been targeting 1 January 2027 for entry into force, roughly six months after the missed EU deadline, with wider gender pay gap reporting obligations expected to follow around September 2028. However, a snap general election held on 24 March 2026 and the coalition negotiations that followed have introduced real uncertainty into whether the January 2027 target will hold, and the bill's final form and timing have not been confirmed. The draft proposes pay range disclosure at recruitment, a salary history ban, an expansion of Denmark's existing wage statistics system, and a new dedicated oversight body for equal pay. Because the legislation is still moving through a period of political transition, these dates and provisions should be treated as indicative rather than final.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
Denmark's existing equal pay framework is built on the Consolidation Act on Equal Pay to Men and Women, commonly known as the Danish Equal Pay Act, which dates back to 1976 and already requires equal pay for the same work or work of equal value. Denmark also had to transpose the EU Pay Transparency Directive (2023/970) into national law by 7 June 2026, a deadline that has now passed without the country completing the process.
All Danish employers are already bound by the 1976 Equal Pay Act's core equal pay principle. Employers with 35 or more employees must currently produce gender segregated wage statistics or an agreed Equal Pay Report, except in a few exempt sectors, while the pending draft would add recruitment stage pay transparency duties and expanded reporting for a wider group of employers once it takes effect.
What employers must do in Denmark
All employers, regardless of size
- Comply with the existing Danish equal pay principle for the same work or work of equal value
- Note that pay discrimination claims can shift the burden of proof to the employer under current Danish law
Employers with 35 or more employees
- Produce annual gender segregated wage statistics using Denmark's DISCO job classification codes, with a minimum of 10 employees per gender per group, due by 31 December each year
- Alternatively, agree an Equal Pay Report with employees instead of producing wage statistics
- Note that farming, gardening, forestry, and fisheries employers are currently exempt from this requirement
Proposed under the draft transposition, not yet in force
- Disclose pay ranges to job applicants during recruitment
- Comply with a ban on asking applicants about salary history
- Report expanded gender pay gap data to a proposed new Danish equal pay oversight body, expected around September 2028
Key deadlines
Penalties for non-compliance in Denmark
Under current Danish law, employers that breach equal pay obligations can face fines and, in some cases, criminal liability under the Danish Criminal Code, with the burden of proof shifting to the employer once an employee raises a credible pay discrimination claim. The draft transposition bill could allow for higher penalties than the Directive's own minimum where they follow from other Danish legislation, but no specific new fine amounts have been finalised.
Denmark's Ministry of Employment currently oversees equal pay enforcement, and the draft transposition bill proposes creating a new dedicated body to oversee equal pay compliance going forward.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Copenhagen
Denmark
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Copenhagen
Denmark
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Aarhus
Denmark
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Aarhus
Denmark
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
Odense
Denmark
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
Odense
Denmark
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Denmark
No. Denmark missed the 7 June 2026 deadline. A draft bill was published for consultation in February 2026, but political uncertainty following a snap election has delayed its final passage into Danish law.