Foreign Labour – New Salary Thresholds under the Pay Limit Schemes and Updated Positive Lists

Contacts

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Mia Boesen

Senior Associate
Denmark

I'm a senior associate in our international HR Services group in Denmark specialising in labour and employment law issues, both nationally and internationally.

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Katrine Marie Bjølbøl Vinding Johnsen

Associate
Denmark

I am a Junior Associate in our Employment Law department at the Danish office in Copenhagen. My work involves advising on all types of practical and theoretical employment law matters.

As of 1 January 2026, the Danish Agency for International Recruitment and Integration (SIRI) updated the salary thresholds under the so-called Pay Limit Schemes as well as the Positive Lists. Both schemes constitute key tools for Danish companies seeking to recruit qualified foreign labour from third countries.

Pay Limit Schemes:

Third-country nationals can obtain work and residence permits in Denmark through two different types of salary schemes, both of which set requirements for the salary level and employment terms.

The ordinary Pay Limit Scheme allows for a permit when the foreign national has received a job offer with a salary exceeding a specified threshold and when certain employment terms are met.

The supplementary Pay Limit Scheme operates with a lower salary threshold than the ordinary scheme but imposes stricter requirements. Among other things, the position must have been publicly advertised, and the gross unemployment rate in Denmark must be below a certain level.

In 2025, the salary threshold was DKK 514,000 for the ordinary salary scheme and DKK 415,000 for the supplementary scheme. From 1 January 2026, the thresholds have increased significantly - by DKK 38,000 to DKK 552,000 for the ordinary scheme and by DKK 31,000 to DKK 446,000 for the supplementary scheme. These salary thresholds also apply to the salary track under the Fast-track Scheme, which enables Danish companies to become certified and obtain faster processing of applications.

When calculating the salary, only the base salary, the employer’s pension contributions, and paid holiday allowances are included. Other benefits such as bonuses and the value of taxable employee benefits are not included in the calculation. The new salary thresholds apply to applications submitted after 1 January 2026.

Positive Lists:
The positive lists are official lists of occupations experiencing shortages of skilled or highly qualified labour in Denmark, and these lists are updated twice a year on 1 July and 1 January.

There are two positive lists:
1) The Positive List for Higher Education
2) The Positive List for Skilled Workers

As of 1 January 2026, the positive list for higher education includes 183 job titles, while the positive list for skilled workers includes 57 job titles. Compared with the positive lists from 1 July 2025, there has been a slight reduction in job functions on both lists. It is important to ensure that the job function is included on the positive lists before submitting an application to SIRI. Incorrect classification of the job function may lead to rejection - even if the foreign worker is otherwise highly qualified. 

 

At Bird & Bird, we advise on all aspects of work and residence permits, including assessing whether e.g. the conditions under the pay limit schemes are met and whether a specific position is covered by the positive lists, and we also assist with submitting applications to SIRI under these and other schemes.

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