Under the upcoming rules, companies must ensure that their employees have easy access to the objective and gender-neutral criteria used to determine pay. Companies are free to decide how they do this, provided the information is easily accessible. This could, for example, be via the company’s intranet or in an employee handbook. The information must also be accessible to employees with disabilities.
Employees will also have the right to request and receive information about their individual pay level and the average pay levels within their category, broken down by gender. If employees request this information, the company must respond in writing within two months. If the company is unable to provide the information, it must explain why, and if the information is inaccurate, employees may request clarification. In such cases, the company must provide a reasoned response within four weeks.
In addition, companies must inform employees annually of their right to receive information about their individual pay level and the average pay levels within their category. Again, companies are free to decide how they wish to do this.
iuno’s opinion
Companies should consider preparing procedures for handling requests regarding an employee’s individual pay level and the average pay levels for their category, broken down by gender. For example, it will not be possible to provide this information if there is only one gender in the category. Companies may require employees not to use the information for any purpose other than to exercise their right to equal pay. However, employees will still have the right to share information about their own pay or pay level.
iuno recommends that companies decide how they will give employees access to the criteria they use to determine pay. Companies should also decide how they will inform employees annually of their right to receive information about their individual pay level and the average pay levels for their category.
[Draft bill to amend the Danish Act on Equal Pay of 26 February 2026]