The overall purpose of the new rules is to ensure equal pay between men and women for the same work or work of equal value. To meet this requirement, it is essential to understand the definition of pay.
Pay is already broadly defined and includes salary and all other benefits that employees receive directly or indirectly from the company. This applies regardless of whether the pay is paid in cash or in kind, or whether it is complementary or a variable component. The new rules do not propose to change the definition of pay as we know it today, and will, for example, include:
- Bonus
- Overtime pay
- Travel, house and meal allowance
- Compensation for attending training
- Severance pay
- Pension
- Stock options
The list is not exhaustive and may therefore include other benefits that companies pay to their employees.
iuno's opinion
Although the definition of pay remains unchanged, companies are now required to report it in much greater detail. It is important that companies include the correct amounts, but the draft bill raises more questions than it answers in this respect. For example, it is unclear how companies assess the value of employee stock options or tax-free benefits.
iuno recommends that companies prepare detailed overviews of all employees’ salaries and benefits to identify and assess any differences that need adjustment. Ultimately, it is the companies that are responsible for ensuring that employees are paid equal pay for equal work or work of equal value.
[Draft bill to amend the Danish Act on Equal Pay of 26 February 2026]