Last updated: 24 August 2026
The Pay Transparency Directive is intended to make it easier to ensure equal pay for women and men for the same work or work of equal value. Among other things, the Directive introduces requirements for greater pay transparency, more transparent pay criteria, and new rights for employees and candidates.
But what does this actually mean for Danish businesses, and when will the rules apply?
The EU deadline for implementing the Directive into national legislation expired on 7 June 2026.
In Denmark, the specific new rules have not yet been finally adopted. On 26 February 2026, the Ministry of Employment and Gender Equality submitted a draft amendment to the Equal Pay Act for external consultation. The consultation ended on 27 March 2026.
The consultation draft proposes that the rules enter into force on 1 January 2027, but both the date and the specific rules may still change.
It is therefore important to distinguish between the EU Directive and the new rules proposed in the draft legislation.
The draft legislation includes, among other things, new requirements relating to recruitment, pay structures and employees’ access to pay information.
In recruitment, it is proposed that candidates must be provided with information about the starting salary or salary range based on objective and gender-neutral criteria.
This does not necessarily mean that the salary must be stated directly in the job advertisement. The information must be provided at a time and in a manner that enables an informed salary negotiation.
The Directive stipulates that employers may not ask candidates about their current or previous salary.
A key element of the Directive is that businesses will increasingly need to be able to explain how pay is determined.
According to the draft legislation, businesses’ pay structures must be based on objective and gender-neutral criteria. The criteria are stated to include, among other things, responsibility, skills, effort and working conditions.
Employees will be entitled to request more information about their own pay and about average pay levels for employees performing the same work or work of equal value.
Several of the fundamental requirements in the draft legislation are proposed to apply broadly to all employers, while the requirements to submit pay reports depend on the size of the business.
The largest businesses are expected to be required to report first.
The draft legislation also proposes that businesses with 50–99 employees may become subject to the reporting requirements if there are at least 8 employees of each gender in the same employee group, determined according to the 6-digit DISCO code or an equivalent classification system. Businesses in the agriculture, hunting, forestry and fishing sectors are exempt from this provision.
As this is draft legislation, it should be noted that the special rules described above for businesses with 50–99 employees may change.
As the draft legislation has not yet been finally adopted, it may already be a good idea to gain an overview of:
The most important thing is not necessarily to begin a major implementation project, but to understand where the business stands today.
Pay transparency will affect HR, payroll, recruitment and management.
If you would like to explore the specific requirements, reporting deadlines and practical implications in more detail, you can read our in-depth article on the Pay Transparency Directive here.
If as an employer you need advice in relation to the Pay Transparency Directive, we’re here to help. We can assist with updating your pay structures, establishing objective job categories and preparing you for the new transparency requirements.
Read more here
