The EU Corporate Sustainability Reporting Directive (CSRD) was transposed into Danish law (L 107 revision of the Annual Accounts Act, Auditors Act and various other acts) on 2 May 2024 and came into force on 1 June 2024. The primary legal amendment was the CSRD reform of the Danish Annual Accounts Act, which made sustainability reporting a similarly binding obligation as financial reporting. The supervisory responsibility for controlling CSRD reporting is split between the Danish Financial Supervisory Authority and the Danish Business Authority, with the former responsible for CSRD reporting of financial companies. The timeline requires the biggest Danish companies to deliver their first CSRD reporting in 2025, the second group of companies in 2026, and listed SMEs must start reporting in 2027.

With the Omnibus proposal, the Danish Business Authority estimates that the proposed reduction in the scope of CSRD will reduce the number of Danish companies required to report by approximately 80%. According to the Ministry’s memo to the Danish Parliament’s subcommittee on EU affairs, the Danish government looks favourably at the proposed delays of the CSRD (and the CSDDD). The Danish Parliament has introduced a bill to transpose the directive and submitted it for public consultation on 26 May 2025.

In Denmark, the Ministry of Industry, Business, and Financial Affairs leads the process of implementing the EU Corporate Sustainability Due Diligence Directive (CSDDD). Denmark was not expected to implement the directive until July 2026, in time for CSDDD to come into force for the first group of Danish companies in July 2027. The Danish Parliament has introduced a bill to transpose the “Stop-the-Clock” directive and submitted it for public consultation on 26 May 2025. This Directive extends the deadline for Member States to transpose the CSDDD by one year to 26 July 2027.

Denmark transposed the EU Whistleblower Protection Directive into national law with the Act No. 1436 Whistleblower Protection Act (Lov om beskyttelse af whistleblowere), effective from 17 December 2021. Denmark was the first EU country to transpose the EU Directive. In line with the Directive, the law requires private sector employers with 250 employees or more, and public sector employers, to implement internal whistleblowing schemes with an extended deadline for companies between 50 and 249 employees until 17 December 2023. In addition to the minimum standards set by the Directive, Danish Law incorporated the following:

• “serious offences and other serious matters” (e.g. sexual harassment, serious interpersonal conflicts and serious harassment) as topics that could be reported through these schemes;

• additional categories of reporters, such as employees, self-employed persons, shareholders and persons belonging to the administrative, management or supervisory body of an undertaking, including non-executive members; volunteers, paid or unpaid trainees, persons working under the supervision and direction of contractors, subcontractors and suppliers; and finally persons who report or make public information that the individual acquired in a work-related context, and the work has since ceased.

Additionally, the scope of the Directive is extended to include reports of violations of Danish law in addition to breaches of EU law.

The EU Directive on Transparent and Predictable Working Conditions was delayed in being transposed into Danish law, passing the transposition deadline of 1 August 2022. The Danish Act on Employment Certificates and Certain Working Conditions, adopted on 11 May 2023, entered into force on 1 July 2023. The Act expands the scope of the EU Directive: it applies to all employees working more than an average of three hours per week, and also to employees having unpredictable working hours.

Denmark, along with Sweden, voted against the adoption of the EU Directive on Adequate Minimum Wages. The main argument is that the Directive could hinder the Danish model of labour relations and is against Article 153(5) of the Treaty on the Functioning of the European Union (TFEU), which limits EU competences on the issue of “pay”. The Danish government brought the case for annulment before the Court of Justice of the European Union, with the support of the Danish employers’ associations and trade unions, and also joined by Sweden, with the following argument: “Those provisions interfere directly with the determination of the level of pay in the Member States and concern the right of association, which is excluded from the competence of the EU legislature pursuant to Article 153(5) TFEU.”

In Denmark, minimum wages are established through collective agreements rather than government legislation. In such cases, the EU Directive does not oblige the Member State to implement the statutory minimum wages. 82% of the Danish workforce is covered by a collective agreement. Even though the Directive does not require Denmark to establish statutory minimum wages, Denmark is expected to report to the European Commission every two years on their collective bargaining coverage, the lowest wage rates established by collective agreements, and the wages of those individuals not included in collective agreements.

On 14 January 2025, the Advocate General recommended that the Court of Justice of the European Union “annul in full Directive (EU) 2022/2041 of the European Parliament and of the Council of 19 October 2022 on adequate minimum wages in the European Union, on the ground that it is incompatible with Article 153(5) TFEU and, thus, with the principle of conferral laid down in Article 5(2) TEU”. The final verdict was expected within the six months following the Advocate General’s opinion.

Denmark transposed the EU Posted Workers Directive with the Danish Act on Posting of Workers, which entered into force in June 2020, effective from January 2021. Through the transposition of the Directive, the following changes were made to the national law: instead of “minimum wage”, the law states “remuneration” in order to reflect and improve equality between local and posted employees, meaning that all posted workers are entitled to the same remuneration as the local employees. Under the new law, companies are allowed to extend the posting period to 18 months. Finally, the change made to the national law concerns the responsibility of temporary employment agencies, that the agency must have the information regarding pay and working conditions of the employee. All information on legislation and the rights of posted workers can be found on the national website.

The EU Energy Performance of Buildings Directive (EPBD) was transposed into national law on 10 March 2020. The Danish Energy Agency, under the Danish Ministry of Climate, Energy and Utilities, is responsible for implementing the EPBD Directive in Denmark. The Danish Authority of Social Services and Housing, under the Danish Ministry of Transport and Housing, is responsible for the building regulations in Denmark. The latest revision of the Directive in 2024 has not been transposed into Danish law yet.

As usual, Member States will have two years until 29 May 2026 to transpose the recast EPBD directive. In Denmark, the public consultation required for the legislative changes has not begun yet. Denmark generally favours investing in renewable energy over energy efficiency. In response to the draft Danish NECP (National Energy and Climate Plan), which includes the National Building Renovation Plan (NBRP), the EU Commission criticised Denmark's insufficient efforts regarding the energy efficiency of buildings. The current Danish government has a stated aim to avoid “over-implementation” of EU legislation. For this reason, the Danish government is expected to implement the EPBD and the EED in a minimal way. For these reasons, a broad group of stakeholders in the Danish construction sector, including the Danish Construction Client Association, are collaborating in demanding an ambitious implementation of the EPBD in Denmark.

As part of the EPBD revision, whole life carbon (WLC) assessments are introduced for assessing the energy performance of buildings. Denmark is one of the few countries that incorporated this principle ahead of the timeline. The test phase started in May 2020, which was followed by the National Strategy for Sustainable Construction, released in April 2021. The roadmap stated that life cycle assessments would become mandatory for all new buildings starting from 1 January 2023, with a limit value of 12 kg CO₂e/m²/year for all new buildings above 1,000 m², while the timeline for buildings below 1,000 m² would be included from January 2025.

Denmark is ahead of the directive regarding lifecycle Global Warming Potential (GWP). The EPBD only requires Member States to calculate lifecycle GWP by 2030. A threshold for lifecycle GWP under the EPBD will only come into force after 2030. Denmark adopted lifecycle GWP thresholds last year, which became a legal requirement for all new buildings from July 2025.

Under the EU Energy Efficiency Directive (EED), Denmark has the following three requirements to follow up:

• Energy saving obligations: Denmark must reduce its energy consumption by approximately 1.5% annually;

• Energy reductions in the public sector: Denmark must ensure that at least 3% of publicly owned buildings larger than 250 m2 are energy renovated each year, with an annual energy reduction of 1.9% for the public sector;

• Contributing to the EU’s common energy savings targets: Denmark must have a maximum final energy consumption of 575 PJ in 2030.

Denmark has transposed the EU Waste Framework Directive into its national law by the deadline. Denmark has the highest rate of waste generation among EU countries and has achieved the 2020 waste targets. The National Plan for Waste Prevention and Management, which covers the period of 2020-2032, constitutes the strategy for a circular economy in Denmark and envisions quantitative waste reduction targets and achieving a climate-neutral waste sector by 2030.

In 2019, the construction sector was responsible for 40% of waste produced in Denmark. In line with the national plan to achieve a circular economy, in March 2021, an agreement was reached on the national strategy for sustainable construction, which included “initiatives targeting climate-friendly building and construction, high-quality and durable buildings, holistic renovation assessments to reduce demolition of high-quality buildings, resource-efficient construction, energy-efficient and healthy buildings, and digitally supported construction”.

The Danish Environmental Agency implemented selective demolition on 1 July 2024 in accordance with the waste and buildings legislation, which requires planning, resource mapping, and specific competencies when demolishing buildings of 250 m² or more. This will allow the recycling and reusing of construction materials, which was not a common practice in the Danish construction sector so far.

The Danish Building Code (Bygningsreglementet, BR18) contains legal demands regarding the energy efficiency of both new buildings and renovations. The four central energy requirements are:

• Energy framework (binding threshold for new buildings' energy requirements)

• Transmission loss (binding threshold for building’s energy loss (W per m² floorspace) 

• Building envelop (sets minimum insulation requirements, U-values, for the buildings’ outer shell)  

• Air tightness (At 50 PA the building must maximum lose 1 litre of air per second per square meter)

For new buildings, all four requirements must be met, with the Energy Framework and the transmission loss thresholds as the determining requirements. To abide by these, materials with better insulation value than the minimum Building Envelope requirements will often be required.

Renovation projects can choose to comply with either the Energy Framework for renovations or the Building Envelope requirements for renovations.

To obtain a building permit for a new building, the construction client must first provide calculations showing that the energy efficiency and Life-cycle assessment (LCA) demands will be met.  For every new building larger than 60 m², the construction client must submit the “Energy Label” of the building to the authorities before the building can be used or declared completed. To get the “Energy Label”, the finished building needs to be inspected by an independent energy consultant, who checks that the building complies with the energy requirements in the building permit. The energy label is valid for ten years. No building can be sold or rented out without a valid energy label.

Except for very small changes no structural, plumbing, or electrical changes), renovation projects also require a building permit. To obtain a permit, the applicant must provide plans and calculations proving that the renovated building complies with either the energy framework for renovations or the Building Envelope requirements for renovations.

In 2021, Denmark agreed on a National Strategy for Sustainable Construction that aimed to limit emission values for construction. In 2024, the climate requirements for new construction were tightened, and from 1 July 2025, the new LCA emission- threshold comes into force. New buildings cannot be classified as completed unless the construction client provides documentation showing that the building’s emissions are below the LCA threshold.

The LCA requirement goes beyond energy efficiency by also counting emissions from materials used. The LCA requirement establishes a binding emission threshold for various building types. The average threshold will in 2025 be 8.6 kg CO₂/m²/year. In the coming years the LCA threshold will gradually be tightened to reach a maximum of 6.9kgCO₂/m²/year in 2029.   

The requirements were adjusted to introduce circular and sustainable practices to promote the reuse and recycling of existing buildings. To promote renovation over demolition of existing buildings, an investigation can be carried out to evaluate the energy requirements. In addition, municipalities may refuse demolition permits if it is decided to preserve the building. Lastly, recycled building materials are assessed as zero-emission for the calculation of the building's climate footprint in that year.