A Danish regional railway whose own policy promises to “systematically prevent work-related stress” is now accused of sending an illegal email to sick-listed staff, with staff representatives blaming the message for contributing to a mass sick leave that led to suspended services and rail-replacement buses in North Zealand.
Lokaltog A/S, the publicly owned operator that carries 9.4 million passengers a year on nine lines in eastern Denmark, faces sharp criticism after labour law experts labelled an internal message as unlawful pressure. According to TV 2, the email was sent to employees on sick leave (sygemeldte). Staff representatives and union officials say the message contributed to a mass sick leave in Lokaltog’s operations centre in Hillerød, which led to all North Zealand services being suspended and rail-replacement buses being deployed, according to CPH Post.
The controversy turns on a detail buried in Lokaltog’s own work environment policy. The document commits the company to ensuring that all employees can perform their work without risk of deterioration of physical or mental health. It goes further, stating that management must systematically prevent work-related stress and that the psychological work environment is part of routine safety efforts. Some labour law experts told TV 2 that Lokaltog’s own work environment policy could be used as evidence in a potential arbejdsmiljø case if employees view internal mails as psychological pressure.
Why the illegal email crossed a legal line
Danish law and collective agreements place significant limits on employers’ ability to discipline or pressure employees on legitimate sick leave, and case law has found certain types of pressure unlawful. Lokaltog staff are covered by the OK21 agreement negotiated between Dansk Jernbaneforbund and KL, which includes detailed provisions on sickness and dismissal. Under OK21, any employee with at least eight months’ continuous service whose employment is terminated can have their case formally taken up by the union, which can demand negotiations and have a dismissal reviewed under OK21’s procedures, which can delay or lead to changes in the employer’s decision.
Experts quoted in national media by TV 2 have called the Lokaltog message ulovlig, arguing that contacting sick-listed employees in a way that links their absence to disciplinary consequences violates, according to the experts, both the Working Environment Act and obligations under the collective agreements. The line between lawful information and unlawful pressure is often determined case-by-case by Arbejdsretten or the Danish Working Environment Authority, known as Arbejdstilsynet.
A troubled employer with a history
This is not the first time Lokaltog has clashed with its workforce over conditions. In 2018, the company confirmed it owed a large sum in unpaid overtime to locomotive drivers, a dispute that ran for months and left employees owed millions of kroner. Those earlier tensions over workload and compensation may explain why staff interpreted the recent email as a threat rather than an attempt at dialogue.
Lokaltog employs over 600 people and operates lines that serve many smaller towns on Zealand and Lolland-Falster, where alternatives can be limited, especially outside peak bus routes. For comparison, DSB carried about 196 million passengers in 2022, according to DSB’s annual report. On that basis, Lokaltog’s roughly 9.4 million annual passengers correspond to around 4 to 5 percent of the combined DSB and Lokaltog passenger volume, though the exact share of total Danish rail traffic is not published.
The expat angle: navigating Danish labour law without Danish fluency
The Lokaltog case sits at the intersection of collective agreements, statutory protections, and expectations around sick leave, a system that can be opaque for foreign workers who are not unionised or fluent in Danish. According to Statistics Denmark’s StatBank HFUD10, 16.9 percent of employees in the transport and storage sector were of non-Danish origin in 2023, up from 12.6 percent a decade earlier. Eurostat Labour Force Survey data suggest that migrant workers are similarly over-represented in transportation across the EU, with around 20 to 25 percent of the sector foreign-born in several countries. Neither Lokaltog nor Statistics Denmark publish firm-specific nationality breakdowns, so the share of foreign employees at the company is unknown. The sector-wide trend suggests a non-trivial number of internationals may be affected by the dispute.
For those affected, concrete avenues exist. Dansk Jernbaneforbund can formally take up cases under OK21, demanding negotiations or bringing a matter to labour arbitration. Any employee, including foreigners, can anonymously contact Arbejdstilsynet if they believe employer behaviour breaches work environment rules. The authority’s website has English information and allows workers to report psychosocial risks.
Public ownership means public accountability
Lokaltog is indirectly owned by Region Hovedstaden and Region Sjælland through Movia and the local rail structure. That means local politicians can be held accountable for both service disruptions and employer behaviour, unlike purely private companies. Critics argue that Nordic welfare-state protections do not automatically translate into everyday safety unless employees understand and use the mechanisms that make those rights enforceable: unions, Arbejdstilsynet, and careful documentation of communications.
Denmark’s Working Environment Act states, in accordance with Arbejdsmiljøloven LBK nr 2062, that its purpose is to ensure a safe and healthy work environment that is at all times in accordance with the technical and social development of society. Section 15 obliges employers to plan and arrange work to protect employees from health risks, including psychological ones. Lokaltog’s own policy promises clear demands and expectations to prevent stress. The question now is whether an email to sick-listed staff met that standard, or violated it entirely.
