Sweden continues to move toward transposing the EU Pay Transparency Directive (EUPTD), even as major employer organizations call for a postponement of implementation beyond the EU Commission’s June 2026 deadline.
In May 2024, Sweden’s Inquiry into the implementation of the EUPTD submitted its report (SOU 2024:40) to the Minister for Gender Equality and Deputy Minister for Employment. Since then, the proposals have been under preparation within the Swedish government.
At a press conference on January 15, 2026, the Swedish Minister for Gender Equality, Nina Larsson, presented the government’s proposal to implement the EUPTD into Swedish legislation through amendments to the existing Discrimination Act (2008:567). The government has referred the matter to the Council on Legislation and proposed that the legislative amendments enter into force on July 1, 2026, just behind the EU’s required transposition deadline of June 7, 2026. Questions and answers on the proposal for new rules may be found here.
Sweden’s Approach: Going Beyond the Directive’s Minimum Requirements
As outlined in Sweden’s earlier proposals, the country intends to incorporate the EUPTD’s requirements within its existing pay transparency framework, which already imposes certain requirements on employers beyond the minimum requirements of the EUPTD.
Below is a refresher on Sweden’s current obligations and the proposed EUPTD-driven changes employers should prepare for.
Proposed Changes
- Employers must disclose the starting salary or starting salary range to job applicants in such a time and in such a way that the applicant can conduct an informed salary negotiation.
- Any applicable collective agreement provisions must be shared during recruitment.
- Salary history questions will be banned, preventing employers from asking about prior pay.
EUPTD Article 6 Requirements: Gender-Neutral Pay Systems and Progression
Current Requirements
- Employers must analyze provisions and practices regarding the criteria for pay, pay levels, and pay progression in collaboration with worker representatives.
- Employers must analyze pay structures for equal or equivalent work.
Proposed Changes
- Information as to the criteria used to determine workers’ pay, pay levels, and pay progression (such as merit increases or tenure-based adjustments) shall be easily accessible to all workers, except that employers with fewer than 50 workers do not need to provide criteria for pay progression.
Right to Information
Proposed New Rights for Workers
- Employees may request, in writing:
- Their own pay information, and
- A comparison to the average pay by gender for comparable roles.
- Employers must respond as soon as possible, but no later than within two months.
- Employees must be notified annually of their right to request pay information.
- Pay secrecy clauses will be prohibited. Employees may share their own pay, while use of others’ data is limited to enforcing equal pay rights.
Gender Pay Gap Reporting
Under existing provisions of the Swedish Discrimination Act (2008:567), all employers must annually survey pay differences between women and men who perform work that is to be considered equal or equivalent.
Employers who employ 10 or more employees must document the work in writing and, for employers with 25 or more employees, that documentation must include the remedial active measures to be carried out in collaboration with employees.
However, existing salary survey requirements do not include the same detailed reporting information required under the Directive so Sweden has proposed adding separate reporting requirements for employers with 100 or more employees.
Alongside those reports, employers must:
-
submit their justifications for any pay gaps of 5% or more, or their plans for remediation.
-
If not remediated within six (6) months, the employer must submit the most recently prepared written salary survey to the Equality Ombudsman within seven (7) months of the initial salary report.
-
The requirements of the salary survey are proposed to be amended to align with those of joint pay assessments (JPAs) under the EUPTD, with certain requirements in place only for employers with 100 or more employees.
-
Employers with 10 to 24 employers no longer are required to document their pay surveys.
Current Requirements
- All employers must conduct annual pay surveys analyzing pay differences between women and men performing equal or equivalent work. Employers with 10+ employees must document their work on pay surveys.
- Employers with 25+ employees must document their work on pay surveys as well as active measures aimed at preventing discrimination.
Proposed Changes
- All employers must continue to conduct annual pay surveys, but only employers with 25+ employees must document their pay surveys.
- Employers with 100+ employees must submit a salary report with certain key information on the pay gap between women and men, along with their justifications for any pay gaps of 5% or more, or their plans for remediation.
- If an unexplained pay gap of 5% or more is identified and is not remediated within six months, an employer must submit its most recently prepared written pay survey to the Equality Ombudsman within seven (7) months of the initial salary report.
What This Means for Employers
Sweden is proceeding toward legislation to be effective July 1, 2026.
For employers operating in Sweden, this means preparation should already be underway, including:
- Reviewing job architectures and worker categories
- Formalizing gender-neutral pay systems
- Expanding pay analyses beyond base pay
- Preparing for enhanced reporting and employee information rights
Waiting for final legislation may leave organizations exposed as enforcement expectations approach.
How Trusaic Can Help
At Trusaic, we provide employers across the EU with solutions to comply confidently with the directive.
Our Complete EU Pay Transparency Solution enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep you one step ahead of EU pay transparency enforcement.
- PayParity® analyzes your rewards data (compensation/benefits in kind) and quickly identifies inequities to determine if your adjusted gender pay gap is above 5%. It enables you to easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to find the most cost-effective way to close nominal pay gaps above 5% to ensure compliance.
- Salary Range Finder ensures equitable pay at the point of hire to prevent your pay gap from rising above 5% and enables you to easily comply with the Directive’s salary range disclosure and salary history ban requirements.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
- Regulatory Pay Transparency Reporting™ captures your pay equity findings and generates compliant, one-click reports across all EU jurisdictions.
- Our Pay Transparency Agent answers all your pay transparency reporting questions instantly.
- Our Communications Agent crafts perfect contextual narratives in any EU language to support your annual pay reports.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.
Visit our always updated Member State Transposition Monitor to stay on top of the latest EU Pay Transparency Directive developments.
