HR-News: Are you aware of the new requirements for RUT registration?

New changes have been introduced to the Register of Foreign Service Providers (RUT), affecting foreign companies providing temporary services in Denmark. The new rules will bring additional requirements and increased compliance obligations for foreign companies operating in Denmark.

In this article, we will explore the key changes to the RUT register.

1 What is the RUT register?

The RUT register is a Danish database that helps authorities monitor foreign companies and workers providing temporary services in Denmark. Foreign businesses—whether from the EU/EEA or third countries—must be registered in RUT.

Failure to register in RUT or incomplete registrations can lead to fines and other penalties, which is why it is essential for businesses to comply with the registration requirements.

For more information regarding the RUT register including the information which must be registered, please read our previous article regarding the RUT register.

2 What will be the changes?

Additional requirements for posting third country nationals:

In addition to the current information which must be submitted to RUT, foreign companies who will post third country nationals to Denmark, will be required to upload:

  • Copy of the service agreement,
  • Copy of the employment contract, including additional information provided to the employee in connection with the posting, for example in a posting agreement,
  • Copy of work and residence permit for the third country national.

Please note that these additional requirements will only apply for third country nationals.

The changes will enter into force as of 1 January 2026.

Identification requirement to Danish authorities

Foreign companies who are required to submit a RUT registration, shall also ensure that all posted workers can present valid identification to the Danish Working Environment Authority (Arbejdstilsynet). Valid identification can e.g. be a passport, ID-card, residence card etc.

The Danish Working Environment Authority can order companies to rectify the situation within a certain deadline if the service provider or employees cannot present valid identification. If the company does not comply with an order from the Working Environment Authority to present identification, the company can be fined.

The Danish Agency for International Recruitment and Integration (SIRI) will also be able to request posted workers to present valid identification during the Agency’s inspections of companies, if the workers are considered to work for a company subject to the inspection.

The Danish Agency for International Recruitment and Integration may notify relevant authorities, e.g. the Danish Working Environment Authority or the police if valid identification cannot be presented.

Please note that these changes will apply for all posted workers.

These changes will enter into force as of 1 January 2025.

Recommendation

We advise that third country nationals immigration status is assessed prior to the posting in Denmark. Furthermore, we advise our clients to complete the RUT registration and to upload the required documents in advance, and to ensure accuracy of the information submitted. Lastly, we also recommend our clients to ensure that posted workers can present valid identification to the Danish authorities.

If you have any questions about posting, including RUT registration, you are very welcome to contact us.

Your labor law team

Jana Behlendorf
Attorney-at-Law
jana.behlendorf@lead-roedl.dk
T. +45 23 24 60 22

 

Karina Helena Svensson
Attorney-at-Law
karina.svensson@lead-roedl.dk
T: +45 23 84 06 28

 

Navina Jegarubanathan
Assistant Attorney
navina.jegarubanathan@lead-roedl.dk
T. +45 60 52 43 04

 

Julie Støttrup Nielsen
Legal student
julie.nielsen@lead-roedl.dk
T: +45 20 67 67 21

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