Denmark is moving closer to introducing a new route for companies seeking to recruit workers from outside the EU and EEA.
The proposed scheme could give certified businesses access to international employees at a significantly lower salary threshold than Denmark’s existing Pay Limit schemes. Under the proposal, qualifying foreign employees would need to earn at least DKK 322,000 per year at the 2026 level, provided several other conditions are met.
The proposal is particularly relevant for businesses that struggle to recruit workers for positions that do not meet the salary thresholds of Denmark’s existing immigration schemes.
For companies following Danish employment and immigration developments through Lead Roedl, the proposal is worth watching closely. It could expand recruitment opportunities, but it would also introduce important requirements concerning collective agreements, certification, salary conditions and employer compliance.
What Is Denmark Proposing?
The Danish government introduced Bill L 16 on 25 June 2026. The proposal would amend the Danish Aliens Act and establish a new collective-agreement-based Pay Limit Scheme for certified companies.
The proposal was considered at its first parliamentary reading on 13 August, and the Immigration and Integration Committee issued its report on 27 August.
As of 1 September, the bill is scheduled for its second reading on 1 September and third reading on 3 September.
If adopted according to the proposed timetable, the new rules are expected to enter into force on 1 January 2027.
The aim is to make it easier for qualifying businesses to recruit international workers while protecting Danish salary and employment standards.
A DKK 322,000 Minimum Salary Is Central to the Proposal
One of the most important elements is the proposed salary threshold.
A foreign worker applying under the new scheme would need to be offered annual remuneration of at least:
DKK 322,000 at the 2026 level.
This is considerably below Denmark’s current standard Pay Limit thresholds.
For comparison, the current 2026 Pay Limit Scheme requires annual pay of at least DKK 552,000. The Supplementary Pay Limit Scheme has a threshold of DKK 446,000.
The proposed scheme could therefore open a work permit route for jobs that would not qualify under these existing salary-based schemes.
However, simply offering DKK 322,000 would not automatically make an employee eligible. Several additional requirements would need to be satisfied.
Collective Agreements Would Play a Major Role
A defining feature of the proposed system is its connection to Denmark’s collective bargaining model.
Foreign employees could only be hired into positions covered by collective agreements that qualify under the scheme and to which the employer itself is bound.
This is important because Denmark’s labour market differs from those of many other countries.
Employment conditions such as salary, working hours and notice periods are frequently governed through collective agreements between trade unions and employer organisations rather than through detailed statutory minimum requirements.
The proposed immigration scheme effectively connects access to international labour with this established Danish labour-market structure.
Companies Would Need Certification
The new route would not be available to every Danish employer.
Businesses would need to obtain certification before using it.
Many of the certification conditions would build on requirements already used under Denmark’s Fast-track Scheme. However, the proposal introduces additional safeguards because the new salary threshold is substantially lower.
Among other requirements, a company seeking certification would generally need to demonstrate that:
- It has been operating for the required period
- It has submitted annual reports or accounts for the previous two years
- It can provide the required service certificate from the Danish Business Authority
- It meets relevant certification requirements
- It has not recently been penalised for underpaying foreign workers
- Relevant employee organisations are given access to monitor compliance with applicable collective agreements
The proposal states that a company must not have been penalised for underpayment of foreign labour during the two years before applying for certification.
For employers, this means the scheme is designed as more than a simple lower salary threshold. Access depends on demonstrating a record of responsible employment practices.
The Scheme Would Be Limited to Workers From Certain Countries
Another important restriction concerns nationality.
The proposed arrangement would not provide an unrestricted recruitment route for workers from every country outside the EU.
Instead, it is intended to cover citizens of specified countries with which Denmark already has economic and trade relationships that the country wishes to strengthen.
Businesses planning international recruitment would therefore need to check both the employee’s nationality and the other eligibility requirements before assuming the new route is available.
The nationality requirement makes workforce planning especially important for employers recruiting across several international markets.
Low Unemployment Is Another Condition
The proposed scheme also contains an unusual economic safeguard.
It is intended to operate only while unemployment in Denmark remains low.
This reflects an attempt to balance two competing considerations: giving employers better access to international labour while protecting opportunities and employment conditions within the Danish labour market.
As a result, businesses should not necessarily view the proposed route as a permanently available immigration channel.
Its availability would depend partly on conditions in the Danish labour market.
Faster Recruitment Could Be a Significant Advantage
Certification may provide another important benefit: speed.
The proposal draws partly on Denmark’s existing Fast-track system and could allow qualifying foreign workers, under certain conditions, to begin employment shortly after entering Denmark once the necessary application has been submitted.
This could be valuable for companies facing immediate recruitment needs.
Waiting for immigration processing can complicate workforce planning, particularly where an employer needs specialist or skilled employees quickly.
A properly certified employer could therefore gain both broader access to international workers and greater flexibility in bringing eligible employees into the business.
Salary Calculations Require Care
Employers should also pay close attention to what actually counts toward the DKK 322,000 threshold.
According to the legislative proposal, the calculation would broadly follow principles already used for Denmark’s existing Pay Limit schemes.
Certain forms of actual remuneration can count toward the threshold, and qualifying pension contributions may also be included.
Employers should therefore avoid looking only at the headline number when preparing an employment package.
The structure of salary, pension and other compensation can matter when determining whether the legal threshold has actually been satisfied.
This is one area where international employers can encounter difficulties because compensation packages common in another country may not necessarily fit Danish immigration requirements in the same way.
What Should Companies Do Before 2027?
The bill is still moving through the parliamentary process, so companies should follow its final adoption and any accompanying administrative guidance before relying on the new route.
Businesses that expect to use the scheme can nevertheless start reviewing their position.
Useful questions include:
- Is the company already certified under Denmark’s Fast-track Scheme?
- Are the relevant positions covered by qualifying collective agreements?
- Does the company meet the proposed certification conditions?
- Have salary packages been structured correctly?
- Which nationalities would be eligible?
- Are internal HR teams familiar with Danish work permit requirements?
- Does the company’s compliance history create any potential certification issues?
For international companies with Danish operations, early coordination between HR, management and legal advisers may be particularly useful.
Existing Work Permit Routes Will Remain Important
The proposed scheme should not be confused with a replacement for Denmark’s existing immigration routes.
Denmark currently offers several ways for qualifying foreign employees to obtain residence and work permits.
For example, the existing Pay Limit Scheme has a DKK 552,000 annual threshold in 2026, while the Supplementary Pay Limit Scheme has a DKK 446,000 threshold.
The Fast-track Scheme also remains important for companies certified by the Danish Agency for International Recruitment and Integration, commonly known as SIRI.
Which route is most appropriate can depend on the position, salary, employer, employee qualifications and other circumstances.
A Potentially Important Change for Danish Recruitment
Denmark’s proposed collective-agreement-based Pay Limit Scheme could become an important development for companies that depend on international recruitment.
The DKK 322,000 salary threshold attracts attention because it is considerably lower than existing Pay Limit thresholds. Yet the broader conditions are just as important.
Collective agreement coverage, company certification, compliance history, employee nationality and Danish labour-market conditions could all determine whether the route is available.
For companies monitoring employment and international workforce issues through Lead Roedl, the proposal highlights a wider trend in Danish business law: making international recruitment more flexible while maintaining the employment protections associated with the Danish labour-market model.
If Parliament adopts the bill as planned, businesses will have several months before the proposed 1 January 2027 start date to understand the final rules and prepare.
For employers considering the scheme, the key question is therefore not simply whether a candidate earns more than DKK 322,000. It is whether the company, position and employee together satisfy the complete set of requirements.
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