In February 2026, the Danish Ministry of Employment submitted a draft bill to amend the Danish Equal Pay Act for consultation. We have written more about the draft bill here. In the meantime, the European Commission has provided new answers on which elements of pay companies must include when calculating pay levels and gender pay gaps.
As we have previously written about here, pay is broadly defined. The term covers both salary and all other benefits that employees receive directly or indirectly from the company. This applies to both fixed and variable components of pay, regardless of whether the pay is paid in cash or in kind.
As a general rule, all components of pay must be included. This includes both pension contributions and the value of employee benefits. However, the European Commission does not provide answers on how companies should assess the value of the benefits in practice.
On the other hand, some benefits provided to all employees may be excluded. This applies to benefits that all employees receive on the same terms and without specific conditions. These could include, for example:
- Lunch vouchers
- Phones and computers
- Christmas gift cards
- Courses and training available to all employees
The same may apply to other voluntary benefits that are accessible to all employees, such as a gym membership.
iuno’s opinion
The European Commission provides some answers on what counts as pay and what does not. However, many questions remain unanswered. For example, it remains unclear how companies should assess the value of employee stock options or other benefits such as further education.
iuno recommends that companies prepare detailed overviews of all components of pay and benefits. Companies should also document how benefits are valued and why any benefits are excluded.
[European Commission’s frequently asked questions on the Pay Transparency Directive]