What is Pay Transparency?

A module in Zenegy Payroll that finds the gender pay gaps in the payroll you already run. It shows where the gaps arise and documents why: unadjusted and adjusted pay gap, pay bands, alerts at 5% and the Article 9 report as a PDF.

It is free until 1 January 2027. After that it costs DKK 10 per active employee per month. No setup fee and no technical implementation. The module is switched on inside your existing agreement when it is ready.

Can we switch the module on today?

Not yet. The module is on its way in Payroll. Sign up for the newsletter to hear when it is ready, or book a demo to hear more.

Does it require Zenegy Payroll?

Yes. The module works directly on the payroll data in Payroll, so there is nothing to import. If you run payroll elsewhere, you would move to Zenegy first.

When does the law take effect?

That is not settled. The EU deadline passed on 7 June 2026. Bill L 68 was introduced on 8 October 2026 and proposes entry into force on 1 March 2027, but it has not been passed yet and may change during its passage through the Folketing. We update the module when the rules are final.

What do we need in place before the law arrives?

Job families, job levels, pay bands and an evaluation scheme. That is the part that takes time, and you can do it today. If you need help with job architecture or pay policy, we put you in touch with a certified partner.

Pay Transparency

Status October 2026 · the bill has been introduced but not passed

Find the pay gaps in your own payroll data.

Pay Transparency is a module in Zenegy Payroll. It finds the gender pay gaps in the payroll you already run. Shows where they arise. Documents why.

Free until 1 January 2027, then DKK 10 per active employee/month
No setup fee
Built into Payroll

Book a demo How it works

My account
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Pay Transparency
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Nordlys Studio ApS

Welcome to your,Dashboard overviewGetting started5 of 5

EmployeesAcross 18 job titles and 6 job levels

30Men16Women14

Unadjusted pay gapAll employees, same hours

+5.3%Median gap−0.5 ppvs. last yearMenDKK 61,000/monthWomenDKK 57,750/month

Average gap+14.1%

Adjusted pay gapSame job level, same hours

+1.6%comparable

Overall gap+14.1%

Same job title+0.9%

Same job level+1.6%

Largest pay gapsLargest gap by job level firstJob levelJob title

+24.5%

5Job levels above thresholdEU directive Article 10

M3 — Executive+24.5%n = 4IC3 — Senior−20.6%n = 8IC5 — Senior Consultant+11.5%n = 5

Justified deviationsBy reason

Qualifications1 (50%)Performance1 (50%)2 documented deviations in total

Pay band outliersAgainst the policy set by your admin

Outside their job level band5 below · 13 above

Pay gap over timeMedian pay by gender, normalised to full time (37 h / week)MenWomen

DKK 65,000DKK 60,000DKK 55,000DKK 50,000DKK 45,000SepOctNovDecJanFebMarAprMayJunJulAugSep

Pay quartiles by genderDistribution of men and women across pay quartilesMenWomen

Top quartile71%29%Upper-middle quartile50%50%Lower-middle quartile43%57%Bottom quartile50%50%

Find the gaps.
The whole pay gap on one screen. Median and average, as the directive requires. And the adjusted gap that shows where it comes from.
See the dashboard
Understand where they arise.
Down to job level and job title. See who sits outside their pay band, and how the genders are spread across the pay quartiles.
See the pay bands
Document why.
Ready when someone asks. Record a justified deviation, produce the pay information for an individual employee, and export the Article 9 report as a PDF.
See the report

The product

What it looks like in Zenegy.

The module sits in Payroll, right beside your payroll runs. These are the screens you will work in.

Dashboard

The whole pay gap on one screen.

The unadjusted gap is one of the key figures in the report. The adjusted gap shows what remains once job level and job title are accounted for. That tells you whether the gap comes from who you employ, or from how you set pay.

Unadjusted pay gapAll employees · same hours

+5.3%Median gap−0.5 pp vs. last year

MenDKK 61,000/month

WomenDKK 57,750/month

Average gap+14.1%

Adjusted pay gapSame job level, same hourscomparable+1.6%

Overall gap+14.1%

Same job title+0.9%

Same job level+1.6%

Job levels

Work of equal value, not just the same work.

Job levels group roles that score alike on the four factors. That is where the comparison belongs. And it is where a gap becomes something you must be able to explain.

Pay by job levelMedian · both median and average are reported

Job levelCount (W/M)MenWomenGap

IC2Consultant6 3 / 338,14641,896−9.8%

IC3Senior8 4 / 448,14658,067−20.6%

IC5Senior Consultant5 2 / 362,00054,900+11.5%

M2Director/Head of2 1 / 173,29270,000+4.5%

IC4Lead/Principal5 3 / 252,91757,750−9.1%

M3Executive4 1 / 3110,00083,000+24.5%

Pay bands

See who sits outside the band.

Every job level on one axis, so overlaps and outliers stand out. Red rings are employees outside their own band. Those are the ones to look into.

Pay bandsFTE-normalised pay · shared axis DKK 30k–127k

IC2Consultant

IC3Senior

IC4Lead/Principal

M3Executive

40k60k80k100k120k

MenWomenOutside band

Alerts

Warnings you cannot miss.

When a gap reaches 5%, it is flagged straight away, so you can justify it on objective grounds or correct it in good time. The justification is stored in the same place and travels with the employee's request for pay information.

Sara LindbergProject manager · Lead/Principal · Monthly pay

Gender gap above 5%: not justifiedArticle 10: must be justified or corrected within six months

Base pay59,491DKK/month

Position in band79%below band

Gender gap−9.1%median

Job levelIC432 pt

Women (3)Men (2)Gap

Average56,41452,917−6.6%

Median57,75052,917−9.1%

Gap by pay componentBase −9.1% · Variable −20.8%

Job evaluation

Job evaluation on objective, gender-neutral criteria.

Four factors, 1–10 per job level, against an anchored scheme that describes what each score means. Roles with the same overall score can be grouped as work of equal value, whatever the title, department or manager.

M3ExecutiveJob evaluation 1–10 per factor · Article 4

Qualifications10

Complexity10

Responsibility10

Working conditions10

Pay band DKK 70,000 – 80,00040 / 40

Reporting

The report as a PDF, not a spreadsheet.

The directive's seven metrics are calculated for you. Categories with fewer than five employees of one gender are anonymised automatically. Once the Danish format requirements are final, we adapt the report.

Book a demo

Article 9 report30 employees · 12 monthsPDF

1(a)Gender pay gap+14.1%

1(c)Median gap+5.3%

1(f)Distribution by pay quartile4 quartiles

1(g)Gap per category6 job levels

+ 3 more metrics: 1(b), 1(d), 1(e)

Categories with fewer than five of one gender are anonymised<5

From payroll data to finished report.

The payroll data is already there.
Employees
3016 men · 14 women
You already run payroll in Zenegy. The module reads the figures that are already there. Nothing to import.
Set job structure and pay bands.
Pay bands
Job families, job levels, pay bands and the evaluation scheme. That is the part that takes time. And you can start on it today.
See the gaps.
Pay gap
+5.3%
Calculated on a rolling twelve months, with median and average on both job level and job title.
Document and report.
Article 9 report
PDF
Record justifications, answer requests for pay information, and export the Article 9 report.

Work of equal value

Compare by job level, not just by job title.

The directive requires equal pay for work of equal value, not just for the same job. A CSO and a CMO have different titles. If the roles weigh the same, their pay must be comparable. That is what job levels do. Here is the same example seen two ways.

By job titleNo gap to see

CSOSalesDKK 78,000

CMOMarketingDKK 71,000

Finance ManagerFinanceDKK 69,000

Team LeadSupportDKK 74,000

Each title has one person, so there is no one to compare with. Any gap between genders stays invisible.

By job levelA gap of 7.9%

Job level B · 4 people

Men medianDKK 76,000

Women medianDKK 70,000

Over 5%: must be explained

The roles score alike on skills, effort, responsibility and working conditions, so they are compared. The gap is over 5% and must be explained.

ExampleManWoman

No new system to roll out.

No integration, no export. The module works directly on the payroll data you already have in Payroll. No spreadsheet to keep up to date.
No new portal for employees. No training, no user administration. You produce the documents and share them the way you already do: handbook, intranet or email.
We keep up as the requirements change. The law has not been passed yet. We follow the process and adjust the metrics, charts and report format, so you do not have to.
The module is on its way. When it is ready, it is switched on inside your existing agreement. No setup fee and no technical implementation.

A small price for a clear picture.

Coming to Zenegy Payroll
Pay Transparency
A module that uses the payroll you already run. It is switched on inside your existing agreement when it is ready, and the numbers are worked out for you.
Freeuntil 1 January 2027
Book a demo
Then DKK 10 per active employee per month
No setup fee
Requires Zenegy Payroll
- Unadjusted and adjusted pay gap
- Comparison by job level and job title
- Pay bands and outliers
- An alert when a gap reaches 5%
- Built-in job evaluation
- Article 9 report as a PDF
- Pay information for the individual employee
- Updated as the rules change

Implementation partners

Need help with implementation? We will find you a partner.

Pay Transparency gives you the payroll data and the overview. Implementing the directive itself is organisational work: job architecture, evaluating roles and pay policy. Many prefer to do that part with a specialist. We work with certified advisers who use Zenegy themselves, and we will put you in touch with one who fits your business.

Find a partner

What a partner can help with

Job architecture and grouping roles that do work of equal value
Gender-neutral job evaluation based on skills, effort, responsibility and working conditions
Pay policy, pay bands and objective criteria for pay progression
A joint pay assessment if an unexplained gap of 5% or more appears
Communication to managers and employees

Payroll

Not running payroll in Zenegy yet?

Pay Transparency is a module for Payroll and requires that you run payroll in Zenegy. Move to Zenegy and you get it all in one place: payroll system, payroll data and pay transparency.

See pricing

New requirements for how you document pay.

Pay must rest on objective, gender-neutral criteria, so work of equal value can be compared. Employees gain the right to pay information. And you must be able to document that pay does not depend on gender.

What we know

Comparison on work of equal value
Employees gain the right to pay information
Documentation and reporting requirements
Reversed burden of proof: if you do not meet certain duties, you may have to prove there was no discrimination
Pay must be disclosed during recruitment

What we do not know yet

Whether the bill is passed as introduced, and whether it takes effect on 1 March 2027
Which Danish pay basis to use, such as the labour market contribution (AM) basis
The reporting format for authorities and employees
And a good deal more…

Which is why you may as well start now.

Job structure, job levels and pay bands have to be in place whatever the final law says. That is the part that takes time. And you can do it today.

Job families and job levels
Pay bands for every level
An evaluation scheme you can stand behind

Book a demo Sign up for the newsletter

An employee working in the pay transparency dashboard on a laptop

The law has not landed yet.

The EU deadline passed on 7 June 2026. The first Danish bill lapsed at the general election. A new bill, L 68, was introduced on 8 October 2026 and proposes that the rules take effect on 1 March 2027. It has not been passed yet and may change during its passage through the Folketing.

Completed: 26 February 2026
Bill sent to consultation
The Ministry of Employment circulates a bill amending the Equal Pay Act.
Completed: 27 March 2026
Consultation deadline
Completed: 7 June 2026
EU deadline passed
Directive (EU) 2023/970 was to be transposed into Danish law.
Completed: June 2026
The bill lapsed at the general election
Now: 8 October 2026
New bill introduced (L 68)
The Folketing is debating the bill, and it may change along the way.
Upcoming: 1 March 2027
Proposed entry into force
The date is in the bill, which has not been passed. From then on, employees can request pay information, and you must reply in writing no later than two months after the request.
Upcoming: 1 September 2028
Proposed deadline for the first pay gap reports
For businesses with at least 150 employees, covering pay in 2027. Businesses with 100–⁠149 employees, and some with 50–⁠99, by 1 September 2031.

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What is Pay Transparency?
A module in Zenegy Payroll that finds the gender pay gaps in the payroll you already run. It shows where the gaps arise and documents why: unadjusted and adjusted pay gap, pay bands, alerts at 5% and the Article 9 report as a PDF.
What does it cost?
It is free until 1 January 2027. After that it costs DKK 10 per active employee per month. No setup fee and no technical implementation. The module is switched on inside your existing agreement when it is ready.
Can we switch the module on today?
Not yet. The module is on its way in Payroll. Sign up for the newsletter to hear when it is ready, or book a demo to hear more.
Does it require Zenegy Payroll?
Yes. The module works directly on the payroll data in Payroll, so there is nothing to import. If you run payroll elsewhere, you would move to Zenegy first.
When does the law take effect?
That is not settled. The EU deadline passed on 7 June 2026. Bill L 68 was introduced on 8 October 2026 and proposes entry into force on 1 March 2027, but it has not been passed yet and may change during its passage through the Folketing. We update the module when the rules are final.
What do we need in place before the law arrives?
Job families, job levels, pay bands and an evaluation scheme. That is the part that takes time, and you can do it today. If you need help with job architecture or pay policy, we put you in touch with a certified partner.

Newsletter

We will tell you when the rules land.

The law has not been passed yet. We keep watch and update the module, so you do not have to follow the legislative process yourself. Sign up and we will write when there is news.