Europaudvalget 2024-25
EUU Alm.del Bilag 619
Offentligt
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EUROPEAN
COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 904 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Denmark
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
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EN
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A
BSTRACT
The level of perceived judicial independence in Denmark continues to be very high among
both the general public and companies. Human and financial resources for the justice system
are being progressively increased. Procedural rules aimed at improving the efficiency of the
judiciary are being implemented, while it is too early to assess their impact. An inquiry
committee was appointed to report on the organisation, structure and tasks of the courts.
Work on the review of the legal aid system, started in 2020, will re-commence, as the pre-
legislative committee did not complete its work and a new body has been tasked to present
results by 2026. The trend of increasing average case handling times continues.
Denmark is perceived as one of the least corrupt countries in the world. The anti-corruption
programme adopted in the framework of the implementation of the Recovery and Resilience
Plan remains applicable to EU funded projects. The system used to monitor investigations
and prosecutions of corruption offences allows regular reporting. The reform of the rules on
private financing of political parties is pending in Parliament. There are no plans to introduce
rules on revolving doors for ministers and on lobbying, and to ensure adequate control of
asset declarations submitted by persons entrusted with top executive functions, or to
strengthen integrity rules in Parliament. The implementation of the rules on whistleblowing is
considered to be on the right track by both the authorities and civil society. While there is no
specific process to identify areas with high-risk of corruption, foreign bribery is a focus for
the authorities.
The human resources of the Danish Radio and Television Board and the Danish Press
Council have been strengthened. New rules were adopted to strengthen the transparency
regarding the appointment of the board of directors of Danmarks Radio (DR). Current rules
on media liability and the existing media support mechanisms are being reviewed in light of
technological developments. The work on strengthening the right of access to information
continues. The safety of journalists remains high although there are calls for more
transparency in reporting incidents.
The legislative process is inclusive overall and rules have been amended to give Parliament
more time for the consideration of legislative proposals. The Danish Institute for Human
Rights was reaccredited with ‘A’ Status. Civic space in Denmark continues to be open while
some stakeholders call for a more transparent and foreseeable approach to funding for civil
society.
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R
ECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Denmark has
made:
•
•
Limited progress on completing the review of the legal aid system, taking into account
European standards on legal aid.
No progress on introducing rules on ‘revolving doors’ for ministers and on lobbying and
ensure adequate control of asset declarations submitted by persons entrusted with top
executive functions.
Some further progress on advancing with the process to reform the Access to Public
Administrative Documents Act in order to strengthen the right to access documents, in
particular by limiting the grounds for rejection of disclosure requests, taking into account
the European standards on access to official documents.
•
On this basis, and considering other developments that took place in the period of reference,
it is recommended to Denmark to:
•
•
•
Step up efforts to complete the review of the legal aid system, taking into account
European standards on legal aid.
Introduce rules on ‘revolving doors’ for ministers and on lobbying and ensure adequate
control of asset declarations submitted by persons entrusted with top executive functions.
Continue to advance with the process to reform the Access to Public Administrative
Documents Act in order to strengthen the right to access documents, in particular by
limiting the grounds for rejection of disclosure requests, taking into account the European
standards on access to official documents.
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I.
J
USTICE
S
YSTEM
1
Independence
The level of perceived judicial independence in Denmark continues to be very high
among both the general public and companies.
Overall, 81% of the general population and
82% of companies perceived the level of independence of courts and judges to be ‘fairly or
very good’ in 2025
2
. The level of perceived judicial independence among the general public
has slightly decreased in comparison with 2024 (83%) although it has increased in
comparison with 2021 (75%). The level of perceived judicial independence among
companies has decreased in comparison with 2024 (88%) and has slightly decreased in
comparison with 2021 (83%).
Quality
Human and financial resources for the justice system are being progressively increased.
The multi-year financial agreement for 2024-2027, providing a total of some EUR
308 million (DKK 2.3 billion) additional funds over that period compared to the 2023
financing levels, is designed both to ensure the current level of activity, and to implement
initiatives specified in the agreement
3
. Under the agreement, 12 additional district court
judges and a large number of assistant judges and clerical staff have been recruited in 2024
4
.
These efforts will continue in 2025, when a total of nine new judges will be appointed, as
well as additional assistant judges and clerical staff to strengthen case processing at the
courts
5
. Stakeholders were overall positive about the increase in resources for the judiciary
but noted that it was too early to assess any impact on the case-handling times
6
.
The procedural rules aimed to improve the efficiency of the judiciary are being
implemented, but stakeholders agreed that it was too early to assess their impact.
On 15
June 2024, more than 100 amendments to the Administration of Justice Act, the Criminal
Code and the Execution of Sentences Act entered into force. These amendments are linked to
the multi-year financial agreement for the judiciary and originate from the proposals of the
expert committee chaired by a former Supreme Court President and the Judicial Council in
2023
7
. The amendments aim to reduce case processing times, for example by a transfer of
criminal cases between courts based on agreements between district court presidents. In
October 2024, the court presidents of four district courts agreed to the transfer of 400
criminal cases between their courts, with the aim of reducing backlogs. While stakeholders
agreed that it was too early to assess the impact of the overall reform
8
, they expressed some
1
2
3
4
5
6
7
8
An overview of the institutional framework for all four pillars can be found
here.
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).
Some 43% for ongoing work, the rest for initiatives defined in the agreement.
Country visit Denmark, Danish Court Administration.
Danish Court Administration (2025b), Country visit Denmark, Danish Court Administration.
Country visit Denmark, Danish Court Administration, Judges Association, Bar Association, Justitia.
The amendments concern a wide range of procedural aspects touching upon lay judges’ involvement in
criminal cases, judgements in absentia in criminal cases, conditions for appeals in civil cases, thresholds for
appeals, small claims cases and other issues. Danish Court Administration (2024a).
Country visit Denmark, Bar Association, Judges Association, Danish Court Administration, Justitia.
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concerns as regards the decision on the transfer of cases without the consent of the parties
9
.
While parties must be given the opportunity to comment on such transfers, stakeholders deem
that the lack of explicit consent could give rise to some concern for individuals tried in
criminal cases
10
.
An inquiry committee was appointed to report on the organisation, structure and tasks
of the courts.
In March 2025, an inquiry committee was appointed to address the structural
conditions of courts. This is a follow-up to the multi-year agreement on the financing of the
judiciary for the period 2024-2027. The committee is tasked with examining the structure and
organisation of the courts, their specialisation as well as the courts’ buildings portfolio.
According to the committee’s mandate, any reorganisation and structural changes should take
into account the need to ensure user focus, accessibility throughout the country, short case-
handling times, uniformity and efficient and high-quality solutions. The committee is
expected to report by the end of 2026
11
.
There was limited progress on completing the review of the legal aid system, as the pre-
legislative committee appointed in 2020 did not complete its work and a new body has
been tasked to present results by 2026
12
.
In December 2024, the Ministry of Justice
requested the Judicial Council, a permanent advisory body on civil justice, to review the legal
aid system in Denmark. While a a pre-legislative committee had already been set up for the
same purpose in 2020
13
, according to the Government, it proved difficult for progress under
the initial set-up. A similar mandate was given to the Judicial Council
14
. The Judicial Council
is expected to present its results by summer 2026
15
. As the review of the legal aid system has
been re-initiated, there was limited progress on the recommendation to complete the review
of the legal aid system.
9
10
11
12
13
14
15
Country visit Denmark, Bar Association, Justitia.
The applicable rules provide that if the total number of cases pending before a district court and the
processing times at the district court so warrant, the court may, at the request of a party, on its own initiative
and in agreement with the president of the district court concerned or the president of the High Court, refer
a criminal case to another district court in the jury district or, if circumstances so warrant, to another district
court in the High Court district if a decision at this court can be expected significantly faster. Before the
court decides on the referral, the parties must be given the opportunity to comment on the matter.
According to the Danish authorities, a transfer against the defendant's wishes should not be made if it would
have significant negative effects on the defendant's defense. A decision to transfer the case can be appealed
to the Supreme Court by the defendant and the Prosecution Service. Danish Government (2025), written
contribution. Country visit Denmark, Danish Court Administration.
Danish Court Administration (2025c).
The 2024 Rule of Law Report recommended to Denmark to “complete the review of the legal aid system,
taking into account European standards on legal aid.”
The Ministry of Justice had set up the pre-legislative committee in April 2020 to review the legal aid
system, in response to a number of studies conducted by stakeholders highlighting certain weaknesses in the
functioning of the legal aid system. Criticisms of the system raised by the Bar and Law Society and Justitia,
a think tank working on judicial issues, relate in particular to the access to legal aid offices (including
regional disparities), legal aid in administrative matters, funding as well as the need to clarify the legal
insurance scheme. 2021 Rule of Law Report, Denmark, pp. 4-5, and 2023 Rule of Law Report, Denmark,
pp. 6-7.
Danish Government (2025), written contribution; Country visit, Justitia. Justitia considered that the
mandate of the Judicial Council differs from that of the pre-legislative committee. One significant omission
in the Judicial Council’s mandate is the requirement to assess the possibility of strengthening information
about the Danish legal aid model. Justitia also noted that the Judicial Council’s mandate dos not require it to
incorporate recommendations from previous reports, unlike the pre-legislative committtee. Danish Lawyers,
the Danish Bar and Law Society, and Justitia.
Danish Government (2025), written input, pp. 4-5.
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The level of digitalisation of the justice system is overall good and the multi-year IT
project for processing criminal and probate cases should be completed in 2026.
The use
of digital technology by courts and prosecution services is overall good, with some gaps
remaining on electronic case allocation with automatic distribution based on objective
criteria, or use of blockchain or artificial intelligence applications. Procedural rules allowing
digital technology in courts in civil and commercial cases are fully in place, but some gaps
still exist for administrative and criminal proceedings
16
. In December 2024, a new
digitalisation strategy was adopted, focussing on the courts’ digital agenda and priority areas
for the period 2024-2027, notably shortening case-handling times
17
. The Danish Court
Administration also continues the staggered rolling out of an IT system for processing
criminal and probate cases
18
. Since October 2022, various solutions for handling both estate
and insolvency probate cases and uncontested fine administration has been rolled out. In
January 2025, a system for digitalisation of selected criminal cases was launched in six courts
as a trial run. The system was subsequently implemented in all courts in June 2025. The
stages of all remaining estate, probate, and criminal case administration elements will be
implemented incrementally by late 2026
19
.
Efficiency
The trend of increasing average case handling times continues.
The number of incoming
civil and commercial litigious cases at first instance continued to increase in 2023 (0.9 cases
per 100 000 inhabitants compared to 0.8 in 2022). The estimated time needed to resolve
litigious civil and commercial cases at first instance has remained stable (268 days in 2022
compared to 265 days in 2023), whereas the rate of resolving litigious civil and commercial
cases remained stable at a low level (93% in 2022 and 2023)
20
. According to the Danish
Court Administration, the efforts to reduce the backlog of cases at the district courts in 2024
led to an expected increase in average case processing times in the short term
21
. The average
case processing time for criminal cases at the district courts has increased from 8.6 months in
2023 to 10.7 months in 2024. The average case processing time for ordinary civil cases with a
main hearing at the district courts has increased from 22.5 months in 2023 to 22.9 months in
2024
22
.
II.
A
NTI
-C
ORRUPTION
F
RAMEWORK
The perception among experts, citizens and business executives is that Denmark is one
of the least corrupt countries in the world.
In the 2024 Corruption Perceptions Index by
Transparency International, Denmark scores 90/100 and ranks 1
st
in the European Union and
16
17
18
19
20
21
22
Figures 41, 42 and 43, 2025 EU Justice Scoreboard. A new artificial intelligence solution for court hearing
scheduling has been implemented in an early version at the beginning of 2025. The solution is planned to be
fully implemented and comprise all criminal and civil case hearings by early 2027. Danish Government
(2025a).
Danish Court Administration (2024c).
2024 Rule of Law Report, Denmark, pp. 4-5.
Danish Court Administration (2025a, 2025d).
Figures 2, 5 and 10, 2025 EU Justice Scoreboard.
According to the Danish Court Administration, the case processing time continues to increase while the
number of pending cases decreases because the courts' case backlog contains cases that are older than the
average case processing time.
The data for criminal cases concerns proceedings with a judge and two jurors. Danish Court Administration
(2024b).
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1
st
globally
23
. This perception has been relatively stable over the past five years
24
. The 2025
Special Eurobarometer on Corruption shows that 28% of respondents consider corruption
widespread in their country (EU average 69%) and 4% of respondents feel personally
affected by corruption in their daily lives (EU average 30%). As regards businesses, 18% of
companies consider that corruption is widespread (EU average 63%) and 11% consider that
corruption is a problem when doing business (EU average 35%). Furthermore, 29% of
respondents find that there are enough successful prosecutions to deter people from corrupt
practices (EU average 36%), while 44% of companies believe that people and businesses
caught for bribing a senior official are appropriately punished (EU average 33%)
25
.
The anti-corruption programme adopted in the framework of the implementation of the
Recovery and Resilience Plan remains applicable to the relevant EU funded projects.
The anti-corruption programme adopted in the framework of the implementation of the
Recovery and Resilience Plan
26
remains applicable to the relevant EU funded projects.
Reflections on the potential usefulness of a strategic framework in the national context have
taken place, and authorities continue to consider an overarching anti-corruption strategy or a
specialised agency dealing with anti-corruption issues unnecessary in the national situation
27
.
Coordination of the anti-corruption matters continues to be carried out on a case-by-case
basis by the Ministry of Justice. The anti-corruption forum created in 2014 did not meet in
the last two years. The lack of strategic framework is continues to be challenged by civil
society and academia
28
. Overall, the Danish anti-corruption system is considered by GRECO
as lacking focus on integrity-related risks
29
.
The system set up for collecting data on investigations and prosecutions of corruption
offences allows regular reporting.
After a first reporting in 2023, the authorities provided
data from all 13 police districts for 2024 on the number of reports, charges and judgments
regarding corruption offences. While the reported number of ongoing investigations into
complex or cross-border cases, which are handled by the National Special Crime Unit (SCU)
and the State Prosecutor for Special Crime Unit (SPSCU) at the central level continues to be
23
24
25
26
27
28
29
Transparency International (2025). The level of perceived corruption is categorised as follows: low (the
perception among experts and business executives of public sector corruption scores above 79); relatively
low (scores between 79-60), relatively high (scores between 59-50), high (scores below 50).
In 2020 the score was 88, while, in 2024, the score is 90. The score significantly increases/decreases when
it changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively stable
(changes from 1-3 points) in the last five years.
Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
2024 Rule of Law Report, Denmark, pp. 9-10.
Country visit Denmark, Ministry of Justice. See also the UN Convention Against Corruption, Articles 5, 6
and 36. International standards (such as UNODC/UNDP (2013) and UNODC (2015)) recommend the
implementation of effective, coordinated anticorruption policies that promote the participation of society
and reflect the principles of the rule of law, with robust anticorruption strategies identified as good practice.
Country visit Denmark, Transparency International and Magtudredningen 2.0. Under the relevant OECD
public integrity indicators, Denmark scores below the EU average on the coverage of strategic framework
(1 out of 7).
GRECO (2023) recommendation i and xii. Denmark’s reputation as a country with a low level of corruption
may contribute to limited attention being paid to corruption. The fact that corruption is not directly
addressed in the Criminal Code may also reflect limited awareness in Denmark. Danish Financial
Intelligence Unit (2022), p. 78.
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low in 2024
30
, data from the police districts allows a broader picture over investigative
activity, indictments and adjudications
31
.
A reform of the rules on private financing of political parties is pending in Parliament.
The revised law on public financing of political parties, adopted in 2023, entered into force in
January 2024. As regards the rules on private financing of political parties, a revision of the
law has been pending in Parliament since June 2023
32
, which raised criticism from civil
society
33
. Negotiations of a draft bill aim to address the issue of multiple and anonymous
donations, and to introduce sanctions for breaching the rules on the political parties’
framework which are considered necessary by some organisations
34
.
There are no plans to introduce rules on revolving doors for ministers and on lobbying,
and to ensure adequate control of asset declarations submitted by persons entrusted
with top executive functions
35
.
Concerns related to the lack of rules on integrity for
ministers and top executive functions, and on lobbying and revolving doors have not been
addressed and the authorities have no plans in this area
36
. Civil society continues to argue for
the need to regulate revolving doors, given the complexity of various interest groups and the
professionalisation of lobbying, which could increase the opacity of contacts between the
public and private sectors
37
. This lack of progress was also noted by GRECO
38
. The Danish
authorities continue to consider that the current system works well, whilst also confirming
that no specific monitoring mechanism is in place
39
. Recent cases of revolving doors
continued to raise concerns on how appropriate ethical standards can be ensured in the
absence of clear rules. Integrity rules are also lacking for Parliament, as no code of conduct is
in place and no system to register external activities and financial interest of Members of
Parliament is available
40
. There was no progress on this recommendation.
The implementation of the rules on whistleblowing is considered to be on the right track
by both the authorities and civil society.
The authorities report that the rules on
30
31
32
33
34
35
36
37
38
39
40
No corruption offence beyond foreign bribery is currently ongoing. Country visit Denmark, SCU.
In 2024, the police registered 42 reports of bribery (including both private and public sector), compared to
156 in 2023. There were 129 judgments on bribery-related charges in 2024 compared to 13 in 2023. State of
play for January 2025. Danish Government (2025), written input, pp. 14-15.
The Minister of the Interior and Health (2023).
Country visit Denmark, Transparency International.
2024 Rule of Law Report, Denmark, p. 11.
The 2024 Rule of Law Report recommended to Denmark to ‘introduce rules on “revolving doors” for
ministers and on lobbying, and ensure adequate control of asset declarations submitted by persons entrusted
with top executive functions’.
Danish Government (2025), written input.
Country visit Denmark, Magtudredningen 2.0. It is a project, launched by the Danish Government and
Parliament, that examines how Denmark is governed, how entrusted power is handled, and who has
influence. See
https://ps.au.dk/forskning/forskningsprojekter/magtudredningen2.
Those recommendations include, among others, the need for a code of conduct for persons with top
executive functions, increased transparency of lobbying and rules introduced on how to deal with the
employment of for persons with top executive functions following the termination of their public service,
more data should be included in the financial declarations of ministers and these declarations must be
subject to substantive control. GRECO (2023), recommendation i, ii, iii, v, vi, vii, viii.
Country visit Denmark, Ministry of Justice.
Politik (2025). Due to lack of progress regarding rules on integrity in the Parliament, GRECO noted that the
level of compliance with their recommendations, put forward in 2018, remains unsatisfactory. GRECO
(2024).
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whistleblowing have been implemented well
41
. This view is shared by Transparency
International Denmark in a report on evaluation of the functioning in practice of the
whistleblowing framework published in 2025. According to the report, the number of reports
has been on the rise since 2022 (increase of 50% from 2022 to 2023 and then of 23% from
2023 to 2024) and this trend is likely to continue. In parallel, the report concludes that up to
60% of reports are rejected mostly to being outside of the scope of the whistleblowing
legislation
42
.
While there is no specific process to identify areas with high-risk of corruption, foreign
bribery is a focus for the authorities.
Businesses’ attitudes towards corruption in the EU
show that 11% of companies in Denmark (EU average 25%) think that corruption has
prevented them from winning a public tender or a public procurement contract in practice in
the last three years
43
. 44% of companies perceive the level of independence of the public
procurement review body (the Complaints Board for Public Procurement) as very or fairly
good
44
. The Single Market and Competitiveness Scoreboard on access to public procurement
in Denmark reports 17% of single bids for 2023 (29% EU average). In relation to foreign
bribery
45
, identified in 2023 by OECD as a risk area in Denmark
46
, the authorities are
considering the relevant follow-up to the recommendations. Overall, the authorities do not
consider corruption a major risk and do not have any dedicated monitoring mechanism in this
regard, a view which is challenged by some stakeholders
47
, also as risks in some areas, such
the pharmaceutical industry, and the energy sector have attracted public attention
48
.
Nevertheless, a general risk assessment under the money-laundering rules is expected in 2026
and may cover corruption as well
49
.
III.
M
EDIA
P
LURALISM AND
M
EDIA
F
REEDOM
The human resources of the Danish Radio and Television Board and the Danish Press
Council have been strengthened.
The national media regulatory authority, the Danish Radio
and Television Board, has received an increase in human resources to deal with new tasks
deriving from the implementation of the Regulation on the transparency and targeting of
political advertising and the European Media Freedom Act
50
. The Media Pluralism Monitor
(MPM) 2025 notes that eight out of eleven members of the media authority are appointed by
the Minister of Culture, although there is no evidence of government interference in the
authority’s decisions. The risk regarding the media authority’s independence is considered to
41
42
43
44
45
46
47
48
49
50
Country visit Denmark, Ministry of Justice.
Transparency International noted that awareness raising could be used to address this (2024 Whistleblowing
in Denmark).
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 14
percentage points below the EU average.
Figure 59, 2025 EU Justice Scoreboard.
There are currently three ongoing investigations on foreign bribery. Country visit Denmark, SPSCU and
SCU.
OECD (2023).
Country visit Denmark, Transparency International and Magtudredning 2.0.
2024 Rule of Law Report, Denmark, p. 12.
Danish Government (2025), written input. According to the last threat risk assessment, the level of
corruption, including bribery in the private and public sectors, is low in Denmark and there are no
indications that the scale and proceeds would increase in the coming years. Danish Financial Intelligence
Unit (2022), p. 78.
This includes six additional employees. Country visit, Danish Radio and Television Board.
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be very low
51
. The Press Council has also received one new employee to deal with an
increasing number of complaints. In 2024, the Press Council made the highest number of
decisions since its establishment, although the share of cases where it found issues with press
ethics was lower than in the last couple of years
52
.
New rules were adopted to strengthen the transparency regarding the appointment of
the board of directors of Danmarks Radio (DR).
The public service media in Denmark –
primarily
Danmarks Radio
(DR) and TV 2 Danmark - are considered to be independent
53
.
The MPM 2025 finds a low risk for the independence of the public service media with no
documented instances of direct political interference in editorial policies or leadership
appointments. Together, they hold about 80% of audience share in the country
54
. To
strengthen transparency, a new act amending the Radio and Television Broadcasting Act has
been adopted. It sets out new competence-based criteria for the appointment of the board of
directors of DR. The law will enter into force in 2027
55
.
Current rules on media liability and the existing media support mechanisms are being
reviewed in light of technological developments.
The Media Liability Committee set up in
2022 has delivered a report in January 2025 regarding possibilities to update the current
framework for media liability in view of the digital media reality. The committee was
composed of a number of experts and representatives from the media industry, civil society
and governmental authorities. The report sets out recommendations as a basis for subsequent
discussions at political level. One of the recommendations concerns setting up a publicly
funded independent media Ombudsperson. The institution could have competences both
regarding new media actors and traditional media, for example by proactively bringing cases
to the Press Council
56
. Stakeholders have generally welcomed the proposal, but consider that
the future media Ombudsperson should be appointed by the media sector and not be able to
bring cases to court
57
. The recommendations of the Media Liability Committee also include a
quality label scheme for responsible media and a simplified judicial procedure for defamation
on social media. The Government is expected to decide on the next steps in autumn 2025. In
parallel, work is ongoing to potentially reform the current media support mechanisms to be
more neutral regarding its distribution
58
. Direct subsidies are currently available for text-
based news media in print and online
59
. The MPM 2025 finds a very high level of market
concentration of audiovisual media services. The newspaper market is more diverse
60
.
Some further progress has been made on the recommendation to strengthen the right of
access to information
61
.
The committee examining possible amendments to the Access to
51
52
53
54
55
56
57
58
59
60
61
Centre for Media Pluralism and Media Freedom (2025), pp. 15-16.
Press Council (2025).
Country visit Denmark, Danish Union of Journalists and Danish Media Association.
Centre for Media Pluralism and Media Freedom (2025), pp. 20, 29; European Audiovisual Observatory
(2024).
Danish Parliament (2025); Country visit Denmark, Ministry of Culture.
Ministry of Culture (2025); Country visit Denmark, Ministry of Culture.
Danish Union of Journalists (2025); Country visit Denmark, Danish Union of Journalists and Danish Media
Association.
Country visit Denmark, Ministry of Culture.
Nordicom (2022).
Centre for Media Pluralism and Media Freedom (2025), p. 20.
The 2024 Rule of Law Report recommended to Denmark to ‘Advance with the process to reform the
Access to Public Administrative Documents Act in order to strengthen the right to access documents, in
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Public Administrative Documents Act, aimed at enabling wider access to the political
decision-making process, is expected to conclude its work and publish a report by autumn
2025. The Ministry of Justice set up the committee in February 2024
62
. After the committee’s
report, political negotiations will commence concerning revising the Act
63
. Stakeholders
noted progress at committee level and the need for political willingness to proceed with
relevant reforms and to limit the grounds for rejection of disclosure requests
64
. In 2024,
complaints about access to documents under the Access to Public Administrative Documents
Act mainly concerned the refusal of authorities - particularly the central administration - to
grant access to documents or the length of the proceedings
65
. Given that the work in the
committee is ongoing and its report is to be published by autumn 2025, there has been some
further progress on last year’s recommendation.
The safety of journalists remains high although there are calls for more transparency in
reporting incidents.
Apart from one instance of a Russian law firm threatening to sue a
Danish investigative news outlet, no cases potentially classified as strategic lawsuits against
public participation (SLAPPs) have been identified in Denmark since the previous Rule of
Law Report. Besides this alert, the Council of Europe’s Platform to promote the protection of
journalism and safety of journalists registered another alert concerning a surge in deepfake
advertising campaigns on Meta platforms targeting Danish journalists
66
. Ten alerts have been
registered in the Media Freedom Rapid Response, including the above-mentioned legal
warning to the Danish investigative news outlet and a few instances of threatening of
journalists, among others
67
. Denmark is not subject to the application of the EU Anti-SLAPP
Directive due to an opt-out
68
. The MPM 2025 notes tensions between national legislation on
mistreatment of religious texts, essentially constituting blasphemy, and the right for political
and artistic expression
69
. However, journalists generally benefit from favourable working
conditions, including a comprehensive social security system
70
. The Danish Ministry of
Foreign Affairs also supports projects to create safer media environments and to promote
freedom of the press outside of Denmark
71
. Recommendations by a dedicated committee
regarding future financial support to be given to Danish media are expected to be published
in autumn 2025
72
. The Danish Union of Journalists encourages more transparency in
reporting incidents in line with the action plan on the safety of journalists, which was adopted
in 2022 and was meant to facilitate journalists’ reporting of any harassment or threats
73
.
62
63
64
65
66
67
68
69
70
71
72
73
particular by limiting the grounds for rejection of disclosure requests, taking into account the European
standards on access to official documents.’
2024 Rule of Law Report, Denmark, p. 16.
Danish Government (2025), written input, p. 18; Country visit Denmark, Ministry of Culture.
Country visit Denmark, Danish Media Association and Danish Union of Journalists.
Danish Parliamentary Ombudsman (2025).
Council of Europe, Platform to promote the protection of journalism and safety of journalists. Denmark has
responded to one of the two alerts.
European Centre for Press and Media Freedom, Media Freedom Rapid Response.
Articles 1 and 2 of Protocol No 22 on the position of Denmark.
Centre for Media Pluralism and Media Freedom (2025), p. 12-13.
Centre for Media Pluralism and Media Freedom (2025), p. 15.
See International Media Support (2025).
Country visit Denmark, Ministry of Culture.
Country visit Denmark, Danish Union of Journalists; 2022 Rule of Law Report, Denmark, p. 14.
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3051236_0012.png
IV.
O
THER
I
NSTITUTIONAL
I
SSUES RELATED TO
C
HECKS AND
B
ALANCES
The legislative process is inclusive overall and rules have been amended to give
Parliament more time for consideration of legislative proposals.
In June 2024, the rules
for Parliament’s examination of legislative proposals were amended in order to allow
Parliament a more thorough consideration
74
. The third and final reading shall now take place
no earlier than 40 days after submission to Parliament and no earlier than two days after the
second reading. There were no fast-track legislative procedures used in the parliamentary
year 2024-2025
75
. In terms of public consultations, stakeholders considered them to be
inclusive and the deadlines largely acceptable, with some stakeholders noting too short
consultation periods. Since the last report, 151 public consultations have taken place and 41
of these (27%) were shorter than the recommended four weeks
76
.
The Danish Institute for Human Rights was re-accredited in October 2024 with ‘A’
status.
It was reaccredited with ‘A’status in October 2024 by the Global Alliance of National
Human Rights Institutions (GANHRI) and its Sub-committee on Accreditation (SCA). In this
context, the SCA made recommendations to the Institute, including on introducing guidance
on conflict of interests of its Board Members and outlining in its bylaws an objective and
independent procedure for their removal. The Institute is in the process of deciding on the
best follow up. The SCA stressed that the Institute must be provided with sufficient resources
to effectively fulfil newly assigned responsibilities
77
. As of 1 January 2025, the Institute is
also tasked with promoting, analysing and monitoring and supporting gender balance in
corporate bodies of listed companies
78
. In March 2025, Parliament elected a new
Parliamentary Ombudsman
79
. The post was advertised publicly following a recommendation
from the Danish Institute for Human Rights. While a vacancy and Parliament’s consideration
of candidates are usually not public, Parliament published a call for the vacant position this
time, following the suggestion by the Institute to that effect. Both the Danish Institute for
Human Rights and the Parliamentary Ombudsman consider that they have adequate resources
for their operations in Denmark.
Over two thirds of the companies surveyed in Denmark express confidence in the
effectiveness of investment protection.
76% of companies are very or fairly confident that
investments are protected by law and courts
80
. As regards authorities relevant for economic
74
75
76
77
78
79
80
A bill must be read three times in Parliament before it can be adopted. Before the amendment, the final
reading was not supposed to be earlier than 30 days after the submission. However, Parliament can allow a
shorter period than 40 days by simple majority (but not shorter than 30 days). Danish Government (2025),
written input, p. 19.
Between October 2024 when the parliamentary year commenced and 28 May 2025. In a fast-track
procedure, the period between submission to Parliament and the final reading would be less than 40 days.
Danish Government (2025), written input, p. 20. Secretariat of the Standing Orders Committee of the
Parliament, written contribution.
Out of these 41 proposals, 25 were subject to a consultation period shorter than 21 days, and 16 proposals
were subject to a consultation period shorter than 14 days. Period between 24 July 2024 and 20 March
2025. Danish Government (2025), written contribution. The Danish parliamentary period stretches from
October to July the following year.
Global Alliance of Human Rights Institutions (2024).
ENNHRI (2025).
Danish Parliamentary Ombudsman (2025).
Figure 54, 2025 EU Justice Scoreboard. Only 7% and 7% of the surveyed investors respectively perceive
the frequent changes in legislation or concerns about the quality of the law-making process, and the quality,
efficiency or independence of justice, respectively, as a reason for the lack of confidence in investment
protection.
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operators, 60% of companies perceive the level of independence of the national competition
authority (Danish Competition and Consumer Authority) as very or fairly good
81
. There are
no judicial mechanisms in place at the level of the Supreme Court to ensure the
implementation of administrative court judgments
82
.
On 1 January 2025, Denmark had 3 leading judgments of the European Court of
Human Rights pending implementation, the same number as the previous year
83
.
At that
time, Denmark’s rate of leading judgments from the past 10 years that had been implemented
was at 57% (compared to 50% in 2024; 43% remained pending), and the average time that
the judgments had been pending implementation was 2 years and 3 months (compared to 2
years in 2024)
84
. The oldest leading judgment, pending implementation for 4 years, concerns
inhuman or degrading treatment
85
. As regards the respect of payment deadlines, on 31
December 2024 there was no case awaiting confirmation of payments (the same as in
2023)
86
. On 15 June 2025, the number of leading judgments pending implementation had
increased to 4
87
. In June 2024, the Danish Administration of Justice Act was amended to
allow the Director of Public Prosecutions or a convicted person to request reopening of a case
dealt with in the criminal justice system in order to comply with a final judgement from the
European Court of Human Rights
88
. From a broader perspective, in April 2025, the
Government tasked two experts to report on Denmark's obligations under the European
Convention on Human Rights, which will help to clarify the limits of the Member States'
margin of appreciation within the scope of the Convention
89
.
Civic space in Denmark continues to be open, while some stakeholders call for a more
transparent and foreseeable approach to funding of civil society.
The civic space in
Denmark continues to be considered as open
90
and the legal framework for civil society
organisations is an enabling factor, even though some organisations may experience
administrative burdens, for instance when dealing with banks or in their cooperation with
municipalities
91
. The operating environment is safe overall, although some level of refraining
to engage in public discussion was noted by the Danish Institute for Human Rights
92
. The
current civil society funding scheme is based on a Financial Bill proposed by the Government
to Parliament, which lists the civil society organisations annually selected for public funding
81
82
83
84
85
86
87
88
89
90
91
92
Figure 60, 2025 EU Justice Scoreboard.
Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower
instance administrative courts.
For an explanation of the supervision process, see the
website
of the Council of Europe.
All figures calculated by the European Implementation Network (EIN) and based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 3.
Judgment of the ECtHR, 45439/18,
Aggerholm v. Denmark,
pending implementation since 2020.
Council of Europe (2025), p. 156.
Data according to the online database of the Council of Europe (HUDOC).
ENNHRI (2025).
Ministry of Justice (2025b).
Rating given by CIVICUS, ratings are on a five-category scale defined as: open, narrowed, obstructed,
repressed and closed.
See also 2024 Rule of Law Report, Denmark, p. 21.
In June 2024, the Danish Institute for Human Rights published a report on the right to freedom of speech
and self-censorship, which found that 10 % of surveyed individuals in 2024 have refrained from
participating in public debate in the physical public space through demonstrations or public meetings due to
fear of negative reactions. Fear of violence and threats is the reason for self-censorship for 31 % of those
who have refrained from participating in public debate in a physical space in 2024. Danish Institute for
Human Rights (2024), p. 10.
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3051236_0014.png
and the amounts awarded to them
93
. The Government also provides funding to civil society
organisations through a wide range of thematic open calls. On a local level, municipalities are
obliged to cooperate with civil society organisations and disburse funding to support
voluntary social work by civil society organisations. Some stakeholders consider that the
current financing scheme with the Financial Bill entails risks leading to self-censorship, and
should be more transparent and foreseeable. The Government announced the intention to put
a new funding model in place for 2026
94
. To this end, the Minister for Social Affairs and
Housing held a meeting with around 200 participants from a wide range of civil society
organisations and representatives of the political system about a new funding model for civil
society organisations on 17 December 2024, as well a series of bilateral discussions with
representatives from civil society organisations
95
.
93
94
95
Stakeholders referred to example of civil society organisations having experienced pressure and negative
statements from politicians about their activities or advocacy work and calling for cutting their funding,
ahead of the parliamentary vote on the Financial Bill 2025. They considered this as having a particularly
negative effect on the freedom of speech of civil society organisations, leading to self-censorship. Nyt
Europa, Globalt Fokus. Berlingske (2024a, 2024b), Radio IIII (2024). Similar examples were reported in
the past. See also 2024 Rule of Law Report, Denmark, p. 20.
Danish Parliament (2024).
Danish Government (2025), written input.
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 EUU, Alm.del - 2024-25 - Bilag 619: Kommissionens årlige rapport om retsstatssituationen i EU
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2024 Rule of Law report
can be found at at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en.
Berlingske (2024a), Berlingske believes: The case of Mellemfolkeligt Samvirke points to a general
problem – your tax krones are spent on left-wing propaganda (Berlingske
mener: Sagen om
Mellemfolkeligt Samvirke peger på et generelt problem – dine skattekroner bruges på
venstreorienteret
propaganda),
https://www.berlingske.dk/ledere/berlingske-mener-sagen-om-
mellemfolkeligt-samvirke-peger-paa-et-generelt.
Berlingske (2024b), Blue parties: Stop the grant to Mellemfolkeligt Samvirke (Blå
partier: Stop
bevillingen til Mellemfolkeligt Samvirke),
https://www.berlingske.dk/politik/blaa-partier-stop-
bevillingen-til-mellemfolkeligt-samvirke.
Centre for Media Pluralism and Media Freedom (2025), Monitoring Media Pluralism in the Digital
Era in the year 2024 , Country report: Denmark, https://cmpf.eui.eu/projects/media-pluralism-
monitor/.
Council of Europe Platform to promote the protection of journalism and safety of journalists (2025),
https://fom.coe.int/en/pays/detail/11709504.
Danish Bar Association (2024), Lawyers seen from the outside: Lawyers are particularly obligated
(Advokater
set udefra: Advokater er særligt forpligtede),
https://www.advokatsamfundet.dk/nyheder-
medier/tidligere-artikler/2024/advokaten-3/2024-advokaten-3-advokater-set-udefra-advokater-er-
saerligt-forpligtede/.
Danish Financial Intelligence Unit (2022),
The National risk assessment of money laundering,
https://hvidvask.dk/en/-/media/mediefiler/hvidvask/hvidvask-en/publications/nrv/national-risk-
assessment-2022.pdf.
Danish
Parliament
16/forhandling.htm .
(2024),
https://www.ft.dk/samling/20241/forespoergsel/F5/BEH1-
Danish Government (2025),
Input for the 2025 Rule of Law Report.
Danish Government (2025a), additional written contribution for the 2025 Rule of Law Report.
Danish Institute for Human Rights (Institut for Menneske Rettigheder) (2024), Freedom of Expression
and
Self-Censorship
(Ytringsfrihed
og
selvcensur),
https://menneskeret.dk/files/media/document/Ytringsfrihed-og-selvcensur_DK_juni2024.pdf.
ENNHRI (2025), https://rule-of-law.ennhri.org/?country%5B0%5D=15&year%5B0%5D=2025&
Danish Parliament (Folketinget) (2025), L 161 Proposal for an Act amending the Act on Radio and
Television Activities, etc. (L
161 Forslag til lov om ændring af lov om radio- og fjernsynsvirksomhed
m.v.),https://www.ft.dk/samling/20241/lovforslag/L161/som_vedtaget.htm.
Danish
Parliamentary
Ombudsman
(2025),
2024
Report
(Beretning
https://www.ombudsmanden.dk/Media/638790845705040412/Beretning%202024_web.pdf.
2024)
Danish Parliamentary Ombudsman (2025), Christina Britten Lundblad chosen as the new ombudsman
(Christian
Britten Lundblad valgt som ny ombudsmand),
https://www.ombudsmanden.dk/find-
viden/nyheder/2025/christian-britten-lundblad-valgt-som-ny-ombudsmand.
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Danish Union of Journalists (2025), DJ and Danish Media: Parts of the Media Responsibility
Committee's proposal for a publicly funded ombudsman go too far (DJ
og Danske Medier: Dele af
Medieansvarsudvalgets forslag om en offentligt finansieret ombudsmand går for vidt)
https://journalistforbundet.dk/nyhed/dj-og-danske-medier-dele-af-medieansvarsudvalgets-forslag-om-
en.
Danish Union of Journalists (2025),
Input for the 2025 Rule of Law Report.
European
Audiovisual
Observatory
(2024),
Yearbook
2023/2024,
https://www.obs.coe.int/en/web/observatoire/-/key-trends-2023/2024-report-just-published.
European Centre for Press and Media Freedom, Media Freedom Rapid Response – Denmark.
European Commission (2021),
2021 Rule of Law Report, Country Chapter on the rule of law situation
in Denmark.
European Commission (2023),
2023 Rule of Law Report, Country Chapter on the rule of law situation
in Denmark.
European Commission (2023),
2023 EU Justice Scoreboard.
European Commission (2024),
2024 Rule of Law Report, Country Chapter on the rule of law situation
in Denmark.
European Commission (2025),
2025 EU Justice Scoreboard.
European Commission (2025),
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption
in the EU.
European Commission (2025),
Special Eurobarometer 561 on Corruption.
Global Alliance of Human Rights Institutions (2024),
Sub-Committee on Accreditation Report –
October 2024,
https://www.ohchr.org/sites/default/files/documents/countries/nhri/report-sca-second-
session-2024-en.pdf.
GRECO (2023),
Fifth evaluation round, Compliance report on Preventing corruption and promoting
integrity in central governments (top executive functions) and law enforcement agencies.
GRECO (2024),
Fourth evaluation round, fourth interim compliance report on Denmark, Corruption
prevention in respect of members of parliament, judges and prosecutors.
International Media Support (2025), https://www.mediasupport.org/about/.
The Minister of the Interior and Health (2023),
Statement in
https://www.ft.dk/samling/20222/beslutningsforslag/B28/BEH1-36/forhandling.htm.
parliament,
Ministry of Culture (2025), The Media Responsibility Committee has submitted its recommendations
(Medieansvarsudvalget
har
afleveret
sine
anbefalinger),
https://kum.dk/aktuelt/nyheder/medieansvarsudvalget-har-afleveret-sine-anbefalinger.
Ministry of Justice (2025a), New proposal from the government will create a safe Denmark for
everyone (Nyt
udspil fra regeringen skal skabe et trygt Danmark for alle),
https://www.justitsministeriet.dk/pressemeddelelse/nyt-udspil-fra-regeringen-skal-skabe-et-trygt-
danmark-for-alle/.
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3051236_0017.png
Ministry of Justice (2025b), The Minister of Justice appoints experts for an inquiry on the European
Convention on Human Rights (Justitsministeren
udpeger eksperter til udredning om Den Europæiske
Menneskerettighedskonvention),
https://www.justitsministeriet.dk/pressemeddelelse/justitsministeren-
udpeger-eksperter-til-udredning-om-den-europaeiske-menneskerettighedskonvention/.
Danish Court Administration (Danmarks Domstole) (2024a), New rules simplify the administration of
justice
(Nye
regler forenkler retsplejen),
https://www.domstol.dk/aktuelt/2024/6/nye-regler-
forenkler-retsplejen/.
Danish
Court
Administration
(2024b),
Magistrate
https://www.domstol.dk/alle-emner/straffesag/domsmandssager/.
Cases
(Domsmandssager),
Danish Court Administration (2024c), New digitalisation strategy to promote case processing (Ny
digitaliseringsstrategi skal fremme sagsbehandling),
https://www.domstol.dk/aktuelt/2024/12/ny-
digitaliseringsstrategi-skal-fremme-sagsbehandling/.
Danish Court Administration (2025a), The Danish Court Administration extends the pilot period for
the criminal case system (Domstolsstyrelsen
udvider pilotperiode for straffesagssystem),
https://www.domstol.dk/aktuelt/2025/3/domstolsstyrelsen-udvider-pilotperiode-for-
straffesagssystem/.
Danish Court Administration (2025b), Special efforts for pile control in 2024 (Særlig
indsats for
bunkebekæmpelse
i
2024),
https://www.domstol.dk/aktuelt/2025/3/saerlig-indsats-for-
bunkebekaempelse-i-2024/
Danish Court Administration (2025c), Terms of Reference for the Structural Committee for the
Courts
(Kommissorium
for
strukturudvalg
for
domstolene),
https://www.domstol.dk/media/3wlf0qjz/kommissorium-for-strukturudvalg-for-domstolene_april-
2025.pdf.
Danish Court Administration (2025d), The Criminal and Probate Programme (Straffe-
og
skifteprogrammet),
https://www.domstol.dk/om-os/digitalisering/straffe-og-skifteprogrammet/.
Nordicom (2022),
Direct media subsidies to news media – a Nordic overview,
https://www.nordicom.gu.se/en/facts-analysis/nordic/factsheets/direct-media-subsidies-news-media-
nordic-overview.
OECD (2023),
Working Group on Bribery in international business transactions, Phase 4 evaluation
of Denmark: Final report,
https://one.oecd.org/document/DAF/WGB(2023)4/FINAL/en/pdf.
Politik (2025), Søren Gade defends himself against criticism of board position in Esbjerg (Søren
Gade
defends
himself
against
criticism
of
board
position
in
Esbjerg),
https://www.dr.dk/nyheder/politik/soeren-gade-forsvarer-sig-mod-kritik-af-bestyrelsespost-i-esbjerg.
Press
Council
(2025),
Annual
report
for
2024
(Årsberetning
for
2024),
https://www.pressenaevnet.dk/uncategorized/aarsberetning-for-2024/.Radio IIII (2024), Lars Løkke
flatly refuses to draw support from NGOs (Lars
Løkke afviser blankt at trække NGO i støtte),
https://radio4.dk/nyheder/lars-loekke-afviser-blankt-at-traekke-ngo-i-stoette-
q2RJlOSCuqLcabTfNoJN.
Transparency
International
(2025),
https://www.transparency.org/en/cpi/2024.
Corruption
Perceptions
Index
2024,
Transparency
International
(2025),
https://transparency.dk/whistleblowers/
2024
16
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in
Denmark
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UNODC (2015),
National Anti-Corruption Strategies: A Practical Guide for Development and
Implementation,
https://www.unodc.org/documents/corruption/Publications/2015/National_Anti-
Corruption_Strategies_-_A_Practical_Guide_for_Development_and_Implementation_E.pdf
UNODC/UNDP (2013),
Kuala Lumpur Statement on Anti-Corruption Strategies,
https://www.unodc.org/roseap/uploads/archive/documents/2013/10/corruption/Kuala_Lumpur_Statem
ent_on_Anti-Corruption_Strategies_Final_21-22_October_2013.pdf.
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Annex II: Country visit to Denmark
The Commission services held virtual meetings in April 2025 with:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Agency for Culture and Palaces
Danish Bar and Law Society
Danish Media Association
Danish Union of Journalists
Danish Press Council
Danish Institute for Human Rights
Globalt Fokus
Danish Judges Association
Justitia
Magtutredning 2.0 project
Ministry of Business
Ministry of Culture
Ministry of Justice
National Audit Office
Danish Courts Administration
Nyt Europa
Parliamentary Ombudsman
Prosecution Service, including the National Special Crime Unit and the State
Prosecutor for Special Crime Unit
Secretariat of the Standing Orders Committee of the Parliament
Supreme Court
Transparency International Denmark
The Confederation of Danish Industry
* The Commission also met the following organisations in a number of horizontal meetings:
•
•
•
•
•
•
•
•
•
•
•
•
Amnesty International
Araminta
Civil Liberties Union for Europe
Civil Society Europe
European Civic Forum
European Partnership for Democracy
European Youth Forum,
International Commission of Jurists
International Federation for Human Rights (FIDH)
JEF Europe
Philea – Philanthropy Europe Association.
Transparency International
18