Current Status Overview
Sweden took a significant step towards transposing the EU Pay Transparency Directive (EU) 2023/970 by publishing its comprehensive governmental inquiry report, SOU 2024:40 ("Genomförande av lönetransparensdirektivet"), on 29 May 2024. Rather than formulating entirely new legislation, the Swedish proposal involves amending the existing Discrimination Act (Diskrimineringslagen 2008:567).
This approach integrates new EU-mandated transparency requirements into a familiar legal framework, building on Sweden's advanced pay equity practices, including annual pay surveys (lönekartläggning) for employers with 10 or more employees. The consultation period concluded on 4 October 2024, with final legislation anticipated by Q3 2025. Proposed amendments will enter into force on 1 June 2026, meeting the EU's full implementation deadline of 7 June 2026.
Timeline & Key Dates
6 June 2023 — EU Directive Entered into Force
29 May 2024 — Swedish Draft Legislation (SOU 2024:40) Published
4 October 2024 — Swedish Consultation Period (Remiss) Concluded
Q3 2025 — Expected Final Swedish Legislation
1 June 2026 — Proposed Swedish Law Enters into Force
7 June 2027 — First gender pay gap reports due (≥150 employees (Annual reporting for ≥250 employees; triennial for 150–249 employees)
7 June 2031 — First gender pay gap reports due (100–149 employees) (Triennial reporting)
National Interpretation of Key Articles
Art. 5 – Recruitment Transparency: Employers must inform applicants of salary range and relevant collective agreements before a salary agreement, explicitly banning inquiries about candidates' pay history. Gender-neutral job titles and processes are reinforced.
Art. 6 – Pay-setting Transparency: Employers must disclose objective, gender-neutral criteria for pay determination and progression. The potential absence of an exemption for employers <50 employees suggests stricter standards for smaller entities.
Art. 7 – Right to Information: Employees can request their own pay level and median pay data for comparable roles, gender-disaggregated, with a required response within two months. Annual notification of this right is mandatory, and pay secrecy clauses are prohibited.
Art. 9 – Pay-gap Reporting: Aligns with EU thresholds and frequency but includes enhanced annual pay surveys for employers with ≥10 employees, requiring analysis of parental leave impacts on pay progression.
Art. 10 – Joint Pay Assessment: Triggered by unexplained pay gaps ≥5%. Conducted with employee representatives and covering the entire workforce, including analysis of pay after parental leave.
