Certified company for the pay limit scheme: the 9 conditions
To use Denmark's new collective-agreement-based pay limit scheme from 1 January 2027, the employer must be certified by SIRI. These are the conditions in section 9 a(21) of the Aliens Act.
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Three declarations on your honour
- You only hire foreign nationals in positions under an approved agreement that covers you.section 9 a(21)(1)(a)
- You give the union ongoing access to check that the agreement is complied with.section 9 a(21)(1)(b) and (42)
- You have not been fined for underpaying foreign workers within 2 years.section 9 a(21)(1)(c)
Requirements for the business
- The fee is paid no later than with the application. DKK 6,810 in 2026; the 2027 rate has not been published.section 9 a(21)(2); executive order 1612/2025
- At least 10 permanent full-time employees in Denmark. Agency, part-time and fixed-term staff do not count.section 9 a(21)(3)
- No lawful industrial dispute and no outstanding enforcement notice from the Working Environment Authority.section 9 a(21)(4) and (5)
- No more than 2 convictions within the last year for illegal employment of foreign nationals, and no fine of DKK 60,000 or more (DKK 100,000 with 250 or more full-time employees).section 9 a(21)(6)
- A member of management has attended SIRI's guidance meeting.section 9 a(21)(7)
- A comprehensive service certificate without remarks, no more than 3 months old. It shows e.g. public debt and bankruptcy.section 9 a(21)(8)
- Operating and filed annual reports or accounts within the last 2 years.section 9 a(21)(9)
After certification
- Certification is valid for 3 years the first time and 4 years at a time when extended.section 9 a(23)
- The union receives your declaration and has 10 working days to object.section 44 a(26)
- If certification is withdrawn, you cannot be certified again for 1 year.section 9 a(25)
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Answer 18 questions and see which conditions you meet and what is missing, with legal references.
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Who needs to be certified?
The employer that wants to hire foreign workers under the new collective-agreement-based pay limit scheme. Certification applies to the CVR number that applies. A fast-track certification does not give access to the new scheme.
When can we apply?
The act enters into force on 1 January 2027. As of 7 October 2026, SIRI has not published the application form. You can prepare everything now.
What does SIRI charge?
The certification fee is DKK 6,810 in 2026 (executive order 1612/2025). The 2027 rate has not been published. The fee is paid no later than with the application.
How long is certification valid?
3 years the first time and then 4 years at a time when extended (section 9 a(23) of the Aliens Act).