Reporting duty per legal employer (EU/Denmark)

Where is it? Salary Mapping ▸ EU Pay Transparency, the Reporting duty per legal employer card. The card shows when the feature is enabled for the organisation (it is on in the Salary Mapping product mode) and needs the same permission as the EU report: Exports, read, not limited to an access area.

The reporting duty belongs to the legal employer, not the group. The gender pay gap report (Directive (EU) 2023/970, article 9) is made by each legal employer on its own. A Danish ApS with 160 employees and a Swedish AB with 120 employees are two employers in the 150–249 and 100–149 groups, not one employer with 280. The card therefore shows one row per legal entity: country, the number of employees and the date they are counted on, size group, how often the report is due and the next date it is due by. Each entity is assessed on its own jurisdiction profile (the entity’s country, or the profile an admin chose for it) and its own headcount. An organisation without legal entities counts as one employer. Pick a legal employer under Report for to see and export that employer’s report.

The headcount is counted from the employee register on the profile’s reference date (Denmark: 31 December of the previous year), without external consultants and without people who left before or start after that date. It is an estimate until the employer confirms it, for example in the annual evidence.

Denmark — preliminary, awaiting Danish law. For Danish entities the size groups and dates follow the Danish bill implementing the directive (consultation on hoeringsportalen.dk until 27 March 2026, planned start 1 January 2027). The bill has not been adopted, so everything is marked Preliminary — awaiting Danish law with a link to the source. Under the bill the report goes through Danmarks Statistik or the employer organisation:

250 or more employees: every year, first by 1 September 2028.
150–249 employees: every three years, first by 1 September 2028.
100–149 employees: every three years, first by 1 September 2031.
50–99 employees: a partial duty from 2031. This comes from secondary sources only and the frequency is not settled, so the row is marked “check with a lawyer”.

Below 50 employees the card shows that no report is required. An unknown headcount is shown as unknown, never as an exemption.

Other countries. Finland, Poland and the other EU/EEA countries follow the directive’s tiers (250+ every year and 150–249 every three years from 7 June 2027, 100–149 every three years from 7 June 2031) until national law exists. No reporting rules are registered for Sweden and Norway yet; the card says so.

Gross annual pay in the employer’s currency. The EU report also shows the Gross annual pay card: mean and median gross annual pay for women and men and the gap between them. Annual pay is monthly pay plus variable pay and allowances × 12, actual pay that is not adjusted to full time. Hourly pay (annual pay divided by contracted hours) stays in the Hourly pay card. Both are shown in the report’s currency, which is the legal entity’s: a Danish entity’s report is in DKK. The figures are hidden when too few women or men are included, and in an entity’s report also by the same differencing rule as the quartiles and hourly pay.

Export for Danmarks Statistik or the employer organisation. The Authority format card has the profile Denmark — Danmarks Statistik / employer organisation (provisional, awaiting Danish law). It gives the same article 9 figures as the Danish profile, with Danish column headers, semicolons and a decimal comma, and adds: the entity’s CVR number, status provisional_pending_national_law, the channel, headcount with its date, size group, frequency and next due date, and gross annual and hourly pay by gender (mean and median) in DKK. No official file format has been published, so the format is marked provisional. The export is recorded in the audit log like every authority format. Pick a legal entity under Report for before exporting: an organisation-wide file for several employers has no single size group.

Recruitment and the right to information for Danish entities. The Recruitment – pay transparency page uses the legal entity’s currency (DKK), and when you pick a Danish entity for a new position the ad text switches to Danish, unless you already chose the language yourself. The right to information (article 7) answers with figures in the employee’s own currency.