Denmark Pay Transparency Law: EUPTD Transposition Status
Local term: løngennemsigtighed
As of 28 September 2026: Denmark has published a draft bill amending the Equal Pay Act, with a planned entry into force of 1 January 2027. The draft proposes first reports by 1 September 2028 for employers with 150+ employees.
Status snapshot
| Status | Draft published |
|---|---|
| National instrument | Draft bill amending the Equal Pay Act (ligelønsloven). |
| Official source | Danish consultation portal (Høringsportalen) |
Pay gap reporting required before the Directive
Gender-disaggregated pay statistics
| Who reports | Employers with 35+ employees and at least 10 of each gender in a job function |
|---|---|
| How often | Annually |
| What is reported | Pay by gender for each job function (DISCO code) |
| Published or internal | Internal. Shared with employees |
| Legal basis | Equal Pay Act (ligelønsloven), section 5a |
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
Not yet legislated.
Things to work on now
- Priority for Denmark. The draft lets you use your own job classification alongside DISCO codes. Decide which grouping gives the most defensible categories of workers.
- Map the draft. Compare the published draft with your current practice and note where it goes further than the Directive.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.
- Pay ranges. Agree pay ranges for roles so you are ready for pre-employment disclosure (Article 5).
- Shadow reporting. Run a trial gender pay gap calculation on 2026 data using the Directive's Article 9 indicators, including by category of workers.
- Remediation budget. Model the cost of closing unexplained gaps of 5% or more, which would trigger a joint pay assessment (Article 10).
Legislative timeline
- 26 February 2026Draft bill published for consultation
- 27 March 2026Consultation closes
- Autumn 2026Bill expected in the Folketing
Frequently asked questions
Has Denmark transposed the EU Pay Transparency Directive?
Denmark has published a draft bill amending the Equal Pay Act, with a planned entry into force of 1 January 2027. The draft proposes first reports by 1 September 2028 for employers with 150+ employees.
When does gender pay gap reporting start in Denmark?
Some reporting already applies under national law: employers with 35+ employees produce annual gender-disaggregated pay statistics. Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Denmark.
What should employers in Denmark do now?
The draft lets you use your own job classification alongside DISCO codes. Decide which grouping gives the most defensible categories of workers. Compare the published draft with your current practice and note where it goes further than the Directive. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.