Denmark Non-Danish Labour Guide (Foreign Workers, Cross-Border)

EU/EEA Workers

Citizens of EU/EEA countries have the right to work in Denmark without a work permit under the free movement of workers principle (EU Treaty Article 45). However, there are registration and documentation requirements that both the employer and employee must follow.

Registration and documentation: EU/EEA workers staying in Denmark for more than 3 months must register with the Danish Agency for International Recruitment and Integration (SIRI) and obtain an EU registration certificate (EU opholdsdokument). The registration requires a valid passport or national ID card, documentation of employment (employment contract signed within the last 3 months), and proof of address in Denmark. The certificate is valid indefinitely but should be renewed if personal details change. EU/EEA workers also need a CPR number (civil registration number), which they obtain at their local citizens' service centre (borgerservice) after registering with SIRI. Once they have a CPR number, SKAT issues a tax card for A-skat withholding, and AM-bidrag applies at the standard 8% rate (unless under 18). EU/EEA workers have the right to family reunification — their spouse and children can join them in Denmark, and the spouse has the right to work without a separate work permit.

Posted workers directive and A1 certificates: If an EU/EEA worker is posted to Denmark by their employer in another EU country (e.g., a German company sends an employee to work on a project in Denmark for 6 months), the Posted Workers Directive applies. The worker retains their home country social security coverage for up to 24 months (via an A1 certificate issued by the home country's social security authority), but Danish minimum wage and working conditions apply. The foreign employer must register the posting with SIRI and report the workers to SKAT for tax purposes. After 24 months (or if the posting is indefinite), Danish social security rules apply, meaning A-skat and AM-bidrag must be withheld. The A1 certificate must be obtained before the posting starts — without it, the worker may be liable for Danish social security contributions. For cross-border workers living in one EU country and working in another (e.g., living in Sweden and working in Denmark), the Øresund tax treaty provides special commuting rules — see the cross-border commuters section below. For more on general hiring obligations, see our Hiring Employees Guide →.

Non-EU Workers

Hiring non-EU workers requires a work and residence permit obtained before the employee starts work. The Danish immigration system offers several schemes, each with different requirements, salary thresholds, and processing times. The employer often plays an active role in the application process.

Pay Limit scheme: The most commonly used scheme for highly skilled workers. The employee must have a job offer with an annual salary of at least 475,000 DKK (2026 threshold, adjusted annually). The job can be in any field — there is no requirement for the position to be on a shortage list. The permit is tied to the specific employer and job, meaning a new application is needed if the employee changes jobs. Processing time is typically 1–3 months. The Supplementary Pay Limit scheme applies for salaries between approximately 375,000 DKK and 475,000 DKK, but with additional conditions (e.g., the position must be on the Positive List or the employer must be certified under the Fast-track scheme).

Fast-track scheme for certified companies: Companies that are certified by SIRI can use the Fast-track scheme, which offers expedited processing (as little as 10–25 days for some cases). To become certified, the company must meet certain criteria: be registered in Denmark, have stable financial records, comply with Danish tax and labour laws, and have a designated contact person for SIRI. Certified companies can hire foreign employees under three tracks: Track 1 (Pay Limit — salary at least 475,000 DKK), Track 2 (Supplementary Pay Limit — salary at least 375,000 DKK), and Track 3 (Positive List — shortage occupations). Certification is valid for 3 years and can be renewed.

Positive List for shortage occupations: SIRI maintains a Positive List of occupations where there is a shortage of qualified workers in Denmark. If the job offer is on the Positive List (e.g., certain IT roles, engineering, healthcare, teaching), the salary threshold is lower (approximately 375,000 DKK/year for 2026). The employee must meet the education and experience requirements for the listed occupation. The Positive List is updated twice a year (January and July). For researchers, the researcher scheme provides a fast track for PhD-level positions at Danish research institutions — see our Researcher Tax Scheme Guide → for the 27% flat tax option.

Cross-Border Commuters (Pendler)

Cross-border commuters — workers who live in one country but work in Denmark — are subject to special tax and social security rules. The most common cross-border commute is between Denmark and Sweden (the Øresund Region), but commuting from Germany and other neighbouring countries also occurs.

Øresund tax treaty special rules: The Øresund tax treaty between Denmark and Sweden provides special rules for cross-border commuters. Under the treaty, income from employment in Denmark is taxed in Denmark if the employee works physically in Denmark. However, if the employee works from home in Sweden, the salary for those days is taxed in Sweden (under the normal rules — Sweden taxes the home-office days, Denmark taxes the in-office days). This creates a splitting of income between the two countries, which can be complex to administer. The employee must provide their employer with a work schedule showing which days they work in Denmark and which days they work from Sweden. The employer withholds Danish A-skat for Denmark days and the employee declares Swedish tax for Sweden days separately. The treaty also provides for commuting deductions — the employee can deduct transport costs between home and the Danish workplace (distance deduction calculated based on the shortest route). The deduction is available in Denmark if the income is taxed in Denmark (for the days worked in Denmark).

Double taxation treaties: Denmark has double taxation treaties with all EU/EEA countries and many non-EU countries. Under the OECD model treaty, employment income is generally taxed in the country where the work is physically performed (the 183-day rule). If a cross-border commuter works in Denmark for fewer than 183 days in a 12-month period, and the employer is not a Danish resident, and the salary is not borne by a Danish permanent establishment, the income may be taxable only in the employee's home country. However, the Øresund treaty modifies this for Danish-Swedish commuters. For commuting from Germany, the rules are governed by the Denmark-Germany double taxation treaty. German commuters living within the border region (typically within a certain number of kilometres from the border) may have special treatment. The employee should submit a preliminary income assessment (forskudsopgørelse) to SKAT declaring their expected Danish-source income. For more on tax treaty applications, see our Cross-Border Tax Guide →.

Non-Danish Labour Rules (Posted Workers)

Foreign companies posting workers to Denmark must comply with specific registration and withholding obligations. These rules apply whether the foreign company has a Danish branch or provides services from abroad.

Registration obligation for foreign companies: Any foreign company that posts workers to Denmark must register the posting with SIRI and provide information about the employees, the nature and duration of the work, and the employer. The registration must be made before the work starts. The threshold for registration is low — even short-term postings (a few days) require registration. Failure to register can result in fines of up to 20,000 DKK per worker. The registration is done through the Virk portal and requires a CVR number (Danish business registration) or a SE number (supplementary business register for foreign entities). If the foreign company does not have a Danish VAT number, it must obtain a SE number for the posting registration.

A-skat withholding responsibility: The foreign employer posting workers to Denmark may have A-skat withholding obligations. If the posting exceeds 183 days in a 12-month period, the workers become liable for Danish tax on their employment income, and the employer must withhold A-skat and AM-bidrag. If the posting is shorter than 183 days, the workers may still be taxable in Denmark if the employer is Danish or has a permanent establishment in Denmark. The foreign employer must register with SKAT as an employer and report salary through eIndkomst. If the foreign employer does not register, the Danish hirer (the company receiving the services) may become jointly liable for the unpaid A-skat. This means the Danish hirer must ensure that the foreign employer has registered and is withholding correctly, or face potential liability for the taxes. The Danish hirer should request proof of registration and A-skat payment from the foreign supplier before engaging their services.

VAT implications: Cross-border services (including the hiring-out of labour) have VAT implications. The place of supply for B2B services is generally where the customer is established (Denmark), so the foreign supplier would normally not charge VAT. However, if the foreign supplier has a permanent establishment in Denmark, Danish VAT may apply. The Danish hirer must self-account for VAT under the reverse charge mechanism for services received from foreign suppliers (EU and non-EU). The reverse charge means the hirer accounts for Danish VAT on the service value on their VAT return. For more on VAT implications, see our VAT Registration Guide →. For construction-specific posted worker rules — including RUT registration, chain liability under KSL §69, and subcontractor verification — see our construction industry tax guide →.

International Hiring-Out of Labour (Udlejning af Arbejdskraft)

International hiring-out of labour (udlejning af arbejdskraft) occurs when a foreign staffing agency places workers with a Danish company. This is a high-risk area for SKAT, as it involves complex withholding obligations and potential joint liability.

Rules for foreign staffing agencies: A foreign staffing agency that hires out workers to a Danish company is generally subject to Danish withholding tax obligations if the workers work physically in Denmark. The foreign agency must register as a Danish employer, obtain a mothers account, and report and pay A-skat and AM-bidrag through eIndkomst. If the foreign agency does not have a Danish branch, it must either register directly with SKAT or appoint a tax representative in Denmark. The threshold for registration is low — even a single worker hired out for a short period triggers the obligation. The foreign agency must also register the posting with SIRI and comply with Danish minimum wage and working condition requirements (as per the Posted Workers Act).

Withholding obligations of the Danish hirer: If the foreign staffing agency does not register and withhold Danish A-skat, the Danish hirer becomes responsible for withholding and paying the tax. This is a form of joint liability that protects the Danish tax base. The Danish hirer must reverse charge the A-skat — they deduct the tax from the payments to the foreign agency and pay it directly to SKAT. The hirer must also report the workers' salary through eIndkomst using the hirer's own employer registration. This creates an administrative burden for the Danish hirer. To avoid this, the Danish hirer should always verify that the foreign staffing agency is properly registered with SKAT and has a valid mothers account. Request proof of registration and recent eIndkomst reports before engaging their services. If the foreign agency claims exemption under the A1 certificate (meaning the worker remains covered by the home country social security system), the Danish hirer should obtain a copy of the A1 certificate for each worker. Without a valid A1 certificate, Danish social security rules apply, and A-skat/AM-bidrag must be withheld.

Payroll tax if no Danish branch: If the foreign staffing agency does not have a Danish branch and does not register for A-skat, the Danish hirer may be subject to payroll tax (lønsumsafgift) on the payments made to the foreign agency for the hired-out labour. The payroll tax is approximately 8–9% of the payment amount, depending on the industry. This is in addition to any VAT or other taxes. The payroll tax is reported and paid through the Danish hirer's VAT return or a separate payroll tax return. The hirer should include payroll tax in their cost calculations when engaging foreign staffing agencies. For more on the interface between hiring and payroll obligations, see our Hiring Employees Guide →.

Social Security Coordination

Social security coordination for non-Danish workers is governed primarily by EU Regulation 883/2004 (for EU/EEA workers) and bilateral social security agreements (for non-EU workers). Understanding which country's social security system applies is essential for determining AM-bidrag, pension contributions, and health insurance obligations.

EU Regulation 883/2004 and A1 certificates: Under EU Regulation 883/2004, a worker can only be covered by one country's social security system at a time. The general rule is that a worker is covered by the social security system of the country where they work (the lex loci laboris principle). However, there are exceptions: posted workers (sent by their employer to another EU country) can retain their home country coverage for up to 24 months (extendable). The A1 certificate is the proof of coverage and must be obtained from the home country's social security authority before the posting starts. Without an A1 certificate, the worker is covered by Danish social security, meaning AM-bidrag must be withheld and Danish pension contributions (ATP, employer pension) apply. Workers who work in two or more EU countries (e.g., a consultant living in Sweden and working for clients in Denmark and Germany) have special rules — coverage is generally in the country of residence if they work at least 25% of their time there, or in the country of the employer's registered office if they work less than 25% in any member state.

Danish pension system integration: Non-Danish workers who contribute to the Danish ATP pension system may be able to transfer their ATP contributions to their home country's pension system when they leave Denmark (under EU coordination rules or bilateral agreements). The Danish Pension Authority handles cross-border pension coordination. Employer pension contributions (the voluntary/collective agreement-based contributions) are typically locked into Danish pension schemes and may not be transferable — the employee may receive them as a pension payout from Denmark after retirement. Workers from countries with which Denmark has a bilateral social security agreement (e.g., USA, Canada, Australia, certain non-EU countries) may have their Danish social security contributions counted toward their home country's pension eligibility. For a full overview of pension rules, see our Denmark Pension Guide →.

Health insurance and family benefits: Workers covered by Danish social security are entitled to Danish health insurance (the public healthcare system) and family benefits (child benefits, maternity/paternity leave compensation). EU/EEA workers can use their European Health Insurance Card (EHIC) for temporary stays, but once they become resident and register with SKAT, they are covered by the Danish health system. Family benefits (børne- og ungeydelse) are paid to residents with children under 18 — the amount is approximately 4,000–5,000 DKK per quarter per child depending on age. For non-EU workers, health insurance is typically included in the residence permit requirements — private health insurance may be required until the worker is registered in the Danish system. Family benefits are generally available to residents regardless of nationality. For more on personal tax and benefits, see our Personal Tax Guide →.

FAQs

What is the difference between an EU/EEA worker and a non-EU worker in Denmark?

EU/EEA workers have free movement rights and do not need a work permit — they register with SIRI for a certificate and obtain a CPR number. Non-EU workers need a work and residence permit before starting, obtained through schemes like Pay Limit (475,000 DKK/year), Fast-track, or Positive List. Both need a Danish tax card for A-skat withholding.

How does the Øresund treaty affect cross-border commuters?

The Øresund tax treaty between Denmark and Sweden provides special rules: income from days worked in Denmark is taxed in Denmark, income from home-office days in Sweden is taxed in Sweden. The employee provides a work schedule, and the employer withholds A-skat only for Denmark days. Commuting deductions are available for transport costs.

What is an A1 certificate and when is it needed?

An A1 certificate proves that a posted worker remains covered by their home country's social security system while working temporarily in another EU/EEA country. It is valid for up to 24 months. Without a valid A1 certificate, the worker is covered by Danish social security, meaning A-skat and AM-bidrag must be withheld.

What are the withholding obligations for foreign companies posting workers to Denmark?

Foreign companies posting workers to Denmark must register the posting with SIRI and may need to withhold A-skat and AM-bidrag if the posting exceeds 183 days or if the employer has a Danish permanent establishment. If the foreign employer does not register, the Danish hirer may become jointly liable for unpaid taxes. The hirer should verify the foreign employer's registration status.

Can a non-EU worker bring their family to Denmark?

Yes — non-EU workers under most schemes (Pay Limit, Fast-track, Positive List) can bring their spouse and children under family reunification. The spouse receives a separate residence permit allowing them to work in Denmark without a work permit. Family members also qualify for Danish public health insurance and family benefits (child benefits).