Under the upcoming rules, medium and large companies will be required to prepare pay reports detailing gender pay gaps. The number of employees determines whether the requirement applies, and when and how often the company must report:
Employees | Draft from SD/EO | First deadline | Frequency |
|---|---|---|---|
50-99* | 1 September 2031 | 1 October or 31 December 2031 | Every three years |
100-149 | 1 September 2031 | 1 October or 31 December 2031 | Every three years |
150-249 | 1 September 2028 | 1 October or 31 December 2028 | Every three years |
250+ | 1 September 2028 | 1 October or 31 December 2028 | Annually |
*If the company has at least eight employees of each gender in the same group.
Companies covered by the rules will receive a draft pay report from Statistics Denmark or their employer organisation. As is the case today, the report will be based on the company's reported salaries. Companies must share the report with both employees and employee representatives. No later than one month after receiving the pay report, companies must send it to the Danish Equal Pay Institute.
Companies that have not reported salary data or have not received a draft pay report must prepare their own pay reports. For these companies, the deadline is 31 December of the relevant year. If employees or the Danish Equal Pay Institute subsequently request clarifications, the company has two months to respond.
iuno’s opinion
Companies should prepare to supplement the draft pay report or prepare their own to ensure it is accurate. The draft reports provided to companies will be based on the existing DISCO codes, which are unlikely to reflect the actual employee categories used within the company.
iuno recommends that companies gain a clear overview of all employees’ salaries and benefits, as well as the information required in the pay report. Ultimately, it is the companies that are responsible for ensuring the pay report is correct, and it is therefore important to include the correct amounts. We have previously written more about the definition of pay here.
[Draft bill to amend the Danish Act on Equal Pay of 26 February 2026]