Last updated 2025-08-22
Quick overview
Sweden has one of the oldest traditions of regulating gender pay equity in Europe. Since the mid-1990s, employers have been required to map and analyze pay differences between men and women. The current rules are set out in the Discrimination Act (Diskrimineringslag 2008:567). While Sweden has not historically required external reporting, employers with at least 10 employees must perform annual pay surveys and, depending on company size, document results and take active measures to close unjustified gaps.
Sweden is now preparing to integrate the new EU Pay Transparency Directive into national law. This will raise obligations further, with reporting to the Equality Ombudsman (DO) and new rights for employees and jobseekers.
Reporting requirements
Which companies must report?
All employers must conduct gender pay gap mapping.
Employers with at least 10 employees must document their analysis in writing.
Employers with at least 25 employees must produce a more extensive annual written review that includes measures to close unjustified pay gaps and follow-up from prior years.
What information needs to be reported?
Employers with at least 10 employees must perform and document:
An annual pay survey covering pay levels and other employment terms
An analysis of differences between women and men performing the same or equivalent work
An analysis of whether pay differences are linked to gender
Employers with 25 or more employees must additionally:
Document measures to close identified gaps
Provide cost estimates and a timeline (within three years)
Report on previous measures taken
Document how cooperation with employees has been ensured
When and where to send the data?
There is no regulatory filing requirement today. Employers must document internally and keep the documentation available to the Equality Ombudsman (Diskrimineringsombudsmannen) upon request.
Annual pay surveys must be completed every year, and active measures must be ongoing.
Who can see the results?
Union representatives have access to employers’ gender pay mapping reports.
If bound by a collective bargaining agreement, employers must provide necessary information to union representatives to enable cooperation.
Otherwise, results are not published externally, although the Equality Ombudsman can request them.
Equal pay laws
Sweden does not have an explicit equal pay statute, but employers are prohibited from discriminating based on gender. This includes pay discrimination. Any pay difference must be objectively justified. Employees performing the same work or work of equal value are entitled to equal pay.
Employee rights
Employees can:
Request that unjustified gender-related pay gaps be closed
Ask for information on criteria used in salary setting (especially after the upcoming EU directive is transposed)
Be represented through unions in pay mapping processes
Job applicants may also soon gain rights to salary transparency and protection from questions about previous salary levels, based on the draft EU directive implementation.
Risks of non-compliance
The Equality Ombudsman (DO) oversees compliance. Employers can be ordered to fulfil their obligations and may face financial penalties for failure to:
Conduct annual pay surveys
Document required analyses and measures
Cooperate with employees
Employees who experience discrimination may be awarded damages.
What will change by 2026
New EU-wide rules
By 7 June 2026, Sweden must implement the EU Pay Transparency Directive. Minimum requirements include:
Job applicants’ right to see salary ranges before employment
A ban on asking about previous salary history
Employees’ right to know average pay levels broken down by gender for their role
Mandatory reporting for employers with 100 or more employees, including publication of wage gap data
A shifted burden of proof in disputes: employers must demonstrate compliance
Stronger enforcement powers for the Equality Ombudsman
How Sweden is likely to apply them
Sweden is expected to go further than the EU minimum:
Apply obligations from 10 employees upwards (not 100 as in the directive)
Require employers to prepare salary charts and conduct detailed analyses of wage differences, including salary supplements and variable pay
Introduce transparency rights for employees to request pay comparisons, with a two-month response time
Mandate reporting of median wage differences, gender representation in salary quartiles, and proportions of men and women receiving supplements
Require employers to document timelines and costs for pay adjustments
The government is expected to publish its bill in 2025, with final obligations in force by mid-2026.
FAQ
Do all employers in Sweden need to perform pay surveys?
Yes. All employers must map pay annually. Written documentation is mandatory from 10 employees and up.
Do I need to submit reports to an authority today?
No. Documentation must be kept and made available if requested by the Equality Ombudsman.
Do employees see the results?
Union representatives are entitled to see them. Other employees do not, unless specifically requested under cooperation rules.
How are “equivalent jobs” defined?
Jobs are compared by responsibility, skills, effort, and working conditions. Jobs dominated by women must be compared to equivalent but male-dominated jobs.
What if my analysis shows an unexplained gender gap?
Employers are obliged to take measures to close it within three years.
What are active measures?
Work on preventing discrimination and promoting equality in five areas: working conditions, pay and employment terms, recruitment and promotion, education and training, and reconciliation of work and parenthood.
How does this tie in with collective bargaining agreements (CBAs)?
If bound by a CBA, cooperation with unions is mandatory. If not, employers must cooperate with any employee organisation that requests it.
Can employees claim damages for unequal pay?
Yes, employees may be awarded damages if discrimination is proven.
What changes are expected under the EU directive?
Job applicants will gain transparency rights, pay history questions will be banned, and reporting obligations will expand significantly.
Will reporting be made public in the future?
Yes, for employers with at least 100 employees. Reports will be submitted to and published by the Equality Ombudsman.
Who monitors compliance?
The Equality Ombudsman (DO) and the Board against Discrimination.
What happens if an employer refuses to cooperate?
The DO may impose financial penalties.
Do these rules apply to all types of workers?
Yes. All employees are covered, regardless of contract type.
When will the government present the final law?
The government bill is expected in 2025.
What should employers do now to prepare?
Review internal pay practices, ensure pay surveys are done annually, and be ready to provide transparency to job applicants and employees.
Helpful resources
– Diskrimineringslagen (Discrimination Act, 2008:567)
– Equality Ombudsman (Diskrimineringsombudsmannen, DO) – official website
– Government report on implementation of the EU Pay Transparency Directive (May 2024)
– Sweden’s Gender Equality Agency – guidance on equal pay and discrimination
Contact us
Book a meeting with our country partner for more information of how Sysarb can help your company with Pay Transparency compliance.
