The Pay Transparency Directive: Guide for Employers
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From January 2027, the EU Pay Transparency Directive applies in Denmark. Here is how it concretely affects your company - whether you have 5 or 5,000 employees.
Requirements That Apply to All Companies
Salary in job postings
Companies must disclose the salary range for new positions. Applicants are entitled to know the salary range before the interview. It may be stated in the job posting or communicated directly to the applicant.
No pay secrecy clauses
Employment contracts may not contain clauses that forbid employees from discussing pay. Existing clauses are invalid and must be removed.
Respond to pay enquiries within 2 months
Employees can request the average pay for their job category broken down by gender. The company must respond within two months and may not penalise employees for asking.
Requirements by Company Size
| Size | Requirement | From |
|---|---|---|
| All | Salary in job postings, no pay secrecy, respond to pay enquiries | January 2027 |
| 250+ employees | Pay report every year | 2027 |
| 150-249 employees | Pay report every three years | 2027 |
| 100-149 employees | Pay report every three years | 2031 |
Consequences of Non-Compliance
An employee who believes they have been discriminated against only needs to make it plausible. After that, it is your company that must prove the pay difference is based on objective criteria.
If you cannot, you risk compensation claims for lost pay and fines from the Board of Equal Treatment.
It is far cheaper to conduct the pay analysis now than to pay compensation later.
Do you have a clear picture of your pay levels?
LønRadar gives companies access to market salary data for recruitment and pay setting. Contact us to learn more.
Contact usFrequently asked questions
When must companies with 250+ employees submit their first report?
Companies with 250+ employees must submit their first pay report in 2027. Companies with 150-249 employees must start in 2027. Companies with 100-149 employees must start in 2031.
What must the pay report contain?
The pay report must show the average pay broken down by gender for groups of employees performing the same work or work of equal value. The difference must be expressed as a percentage.
Do we need to update all job postings before January 2027?
From the date of entry into force (expected January 2027), all new job postings must state pay or a salary range. Existing postings that are still active should be updated before then.
Can we exempt certain employee groups?
No. All employees are in principle covered by the directive. Freelancers and the self-employed are not employees and are therefore not covered.