Pay transparency – pay structures

Last updated on March 23, 2026

The Danish Ministry of Employment has sent the draft bill to implement the Pay Transparency Directive for consultation. In this newsletter, we take a closer look at one of the requirements under the upcoming rules: the requirement to use pay structures.

Under the upcoming rules, all companies must implement pay structures to ensure that employees are paid equal pay for equal work or work of equal value. The pay structures must enable both employees and companies to assess whether employees perform work of equal value to that of other employees.

The pay structures must be based on objective, gender-neutral criteria and agreed upon with employee representatives, where such representatives exist. Companies must always use the criteria of skills, effort, responsibility and working conditions, as well as any other relevant criteria for the specific job. It is also important that companies do not undervalue soft skills, such as teamwork skills, social and emotional competencies, informal responsibility and knowledge sharing.

iuno’s opinion

All companies, regardless of size, need to use pay structures to ensure that they pay employees equal pay for equal work or work of equal value. However, not all criteria are equally relevant for every position. It is therefore important that companies carefully consider which criteria they use.

iuno recommends that companies identify the criteria that apply to different positions and use this as a basis for developing their pay structures.

[Draft bill to amend the Danish Act on Equal Pay of 26 February 2026]