Denmark
Is there any existing legal requirement to report on any gender pay gap?
Yes.
If so, what are the requirement triggers?
Employers with at least 35 employees and which at the same time have a least 10 persons of each sex employed with the same work function are required to prepare a gender-disaggregated salary statistics report. The report must be presented to the employees via the works council. If there is no works council, the employer must ensure that the report be presented to the employees in another way.
What frequency of reporting is required?
Annually.
Is the report required to be published externally?
No.
Is there a sanction for non-compliance with the duty to report?
Yes. Non-compliance can lead to the company being required to pay a fine under section 6b of the Danish Equal Pay Act. A company may also face criminal liability under the Danish Criminal Code. In addition, the Equal Pay Act is implemented in several collective agreements, and non-compliance may therefore constitute a breach of the collective agreement and result in a penalty.
Has Denmark yet fully transposed the requirements of the Pay Transparency Directive? If yes, what was the implementation date and what is the name of the legislation?
No.
If the Pay Transparency Directive has not yet been transposed, what steps have been taken towards implementation?
The Danish government sent a bill for external consultation on 26 February 2026, proposing a comprehensive reform of the existing Danish Equal Pay Act. Following consultation, the government formally presented an updated bill to Parliament on 8 October 2026, with the first reading scheduled for 22 October 2026. The bill largely mirrors the requirements of the Directive. However, implementation is set to the later date of 1 March 2027. Reporting will be auto-generated by Statistics Denmark (or an employer organisation) when the company's reporting of wage information makes this possible, using the existing classification of employees according to a 6-digit DISCO code, although companies may choose to prepare the pay report themselves. Reporting for employers with 250 or more employees will be annually from 1 September 2028, every three years from 1 September 2028 for employers with 150-249 employees, and every three years from 1 September 2031 for employers with 100-149 employees. Certain reporting will also apply to employers with 50-99 employees where there are at least eight employees of each sex in the same employee group, with the first reporting on 1 September 2031.
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