The Pay Transparency Directive introduces several new rights and obligations, which we have previously described here. The deadline for implementing the EU rules was 7 June 2026. We also wrote more about the bill when it was sent for consultation here.
The bill is broadly the same as the one sent out for consultation earlier this year, but there are a few differences. For example:
- The rules are now to enter into force on 1 March 2027. Previously, it was 1 January 2027.
- It has now been clarified that a job applicant may be entitled to compensation if a company asks about the applicant’s pay history. This was not explicitly stated before.
- If a company does not comply with the obligation to report pay information to Statistics Denmark, the company must now prepare the pay report no later than the same deadlines as if the company had complied with the obligation. Previously, the company had until 31 December to prepare the pay report.
- If a company does not provide the pay report to the Danish Institute for Equal Pay, this will constitute factual circumstances indicating that an employee has not received equal pay. The company must therefore specifically prove that it has not discriminated against an employee. Previously, the reverse burden of proof applied only if the company had not consulted the employee representatives before the pay report was provided, or if the company did not provide it to the employees when they asked for it.
The next step is that the Danish Parliament will consider the bill for the first time on 22 October 2026. We are closely monitoring developments.
iuno’s opinion
Companies will now most likely have until 1 March 2027 to complete their internal preparations, so they are ready to comply with the new rules. We have previously written about how you can approach the project here.
iuno recommends that companies closely follow the developments. Although changes may still occur before the law is finally adopted, there are some requirements that will not change significantly in relation to the directive's framework. Members of iuno+ can also rewatch our latest morning meeting on pay transparency here.
[Proposal for a law amending the Equal Pay Act of 8 October 2026]