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      Denmark adopted legislation establishing a new collective agreement-based business scheme through which qualifying certified companies may recruit eligible foreign nationals from specified countries. The scheme is scheduled to take effect on 1 January 2027.

      Separate legislation introduces mandatory personal identification cards for employees working on construction and civil engineering projects with a total value exceeding DKK 100 million. The requirements are scheduled to take effect on 1 January 2028 or 1 January 2030, depending on the implementation timetable for the ID-card system.


      WHY THIS MATTERS

      The new business scheme offers certified Danish companies that meet fair pay and labour standards an additional route to recruit eligible foreign workers, but companies using the scheme will face extra certification, documentation, and ongoing compliance responsibilities.

      For large construction projects, the ID-card rules introduce new site-administration and reporting obligations, including employer reporting of cardholder employment and salary information. Overall, both bills increase employers’ administrative and compliance obligations.


      New Collective Agreement–Based Business Scheme (Erhvervsordning)1,2

      The new business scheme has now been formally adopted. It is intended for certified companies that provide fair pay and proper working conditions and are covered by a relevant collective agreement, enabling them to recruit foreign workers to Denmark. The aim is to make it easier to hire certain foreign nationals while maintaining Danish labour standards.

      How a Danish company can become certified

      Danish companies wishing to use the scheme are required to first obtain a certification with the Danish immigration authorities. The conditions for obtaining this certification are the following, the company:

      • Must have at least 10 full-time employees employed on a permanent basis working for the Danish company at the time of the certification.
      • Comply with the Danish Aliens Act.
      • Not be involved in a legal labour dispute nor have any enforcement notices from the Danish Working Environment Authority.
      • Be covered by a collective agreement and may only employ foreign workers under the scheme in positions that fall within such agreements.
      • Have elected employee representatives or entered into a separate agreement with the relevant employee organization granting access for control.
      • Not, within the past two years, have been ordered by the Labour Court or by industrial arbitration to pay a penalty for underpaying foreign workers.
      • Submit a service certificate issued by the Danish Business Authority (Erhvervsstyrelsen) or equivalent documentation.
      • Have been in operation for a minimum period of two years and have submitted an annual report.

      Who can be hired under the scheme?

      The scheme can be used for foreign employees who:

      • Are offered a position with an annual salary of at least DKK 322,000 (2026 level),
      • Are employed in a position covered by a recognized collective agreement, and
      • Come from specific third countries with which Denmark has an economic and trade partnership.

      The employee is required to be a citizen of one of the following countries: 

      Americas

      Europe

      Asia-Pacific

      United States

      United Kingdom

      Singapore

      Canada

      Montenegro

      China

      Brazil

      Serbia

      Japan

       

      North Macedonia

      Australia

       

      Albania

      Malaysia

       

      Ukraine

       

       

      Moldova

       

      Effective from: 1 January 2027

      Mandatory ID Cards on Large Construction Sites

      The new requirement for ID cards on large construction sites has now been formally adopted. The rules apply to construction and civil engineering projects with a total project value exceeding DKK 100 million. The bill has now been formally adopted.

      Who is required to have an ID card and what must it contain?

      All employees present on covered construction sites are required to carry a personal ID card. As a starting point, the ID card solution will be app-based but final discussions will be held at a later point, now that the proposed bill has been adopted.

      The ID card should include at a minimum:

      • Name
      • Photo
      • Nationality
      • Danish civil registration number (CPR) or equivalent unique ID, if no CPR
      • Residential address, where the employer provides accommodation under the Act on Housing of Employees
      • Job function
      • Mandatory training under health and safety legislation, or equivalent qualifications recognized by the Danish Working Environment Authority
      • Employer information: name, CVR number and, if applicable, RUT number
      • In the case of hiring-out/agency work: information about the company that has engaged the cardholder
      • Date of issue of the ID card

      Responsibility of the project owner

      The rules adopted make the project owner (bygherre) responsible for:

      • Administering ID cards on the construction site, and
      • Reporting ID card data to the Danish Working Environment Authority.

      Regarding the monitoring of companies linked to the ID card, the new rules will also allow the Danish Tax Agency to exercise better control over whether a foreign company has activity in Denmark to constitute a permanent establishment. The Tax Agency will also be able to verify whether the company stated on the card as the cardholder’s employer has correctly registered the cardholder as an employee and reported the salary income.

      As a result, it is now more important than ever for employers to help maintain full compliance in all relevant areas, including tax, immigration, permanent establishment, payroll, and social security.

      Effective from: 1 January 2028 or 1 January 2030, depending on how the ID card solution is phased in.


      KPMG INSIGHTS

      Employers, project owners, and other affected stakeholders might wish to consider:

      • Evaluating whether they are likely to satisfy the certification conditions for the new business scheme.
      • Reviewing whether proposed positions, salary levels, collective agreement coverage, and employee nationalities fall within the scope of the new work permit scheme.
      • Determining whether planned construction and civil engineering projects may exceed the DKK 100 million threshold and adopting appropriate information-sharing arrangements with staffing agencies and foreign companies.
      • Assessing whether employee identification, training, payroll, tax, and registration data are sufficiently available and consistent to support the ID-card system, including any registration, tax, social security, or permanent establishment implications for foreign companies.

      If assignees and/or their programme managers have questions about how these developments might affect them, they are advised to contact their usual tax professional or a member of the GMS team (see the Contacts section).


      ENDNOTES:

      1  Danish Ministry of Employment (Beskæftigelsesministeriet) (in Danish), "Faktaark: Overenskomstbaseret erhvervsordning," June 2025.

      2  Danish Ministry of Employment, (in Danish), "Fælles forståelse om en overenskomstbaseret erhvervsordning.


      RELATED RESOURCES

      This article is excerpted, with permission, from "Work permit scheme and ID card requirement bills adopted,”  published on 3 September 2026, a report from the KPMG International member firm in Denmark.

      Contacts

      Emma Juhl

      Manager

      KPMG Acor Tax in Denmark

      Zehra Øzdemir Cömert

      Senior Manager

      KPMG Acor Tax in Denmark

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      * Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

      The information contained in this newsletter was submitted by the KPMG International member firm in Denmark.

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