Sweden
Mutual separation agreements and consultation obligations (case law)
Impact date: 27 May 2026
A recent ruling of the Swedish Labour Court held that an employer breached its obligation to consult under the Co‑Determination in the Workplace Act by entering into mutual separation agreements with employees without conducting trade union consultations in a redundancy situation.
The employer, which was not subject to a collective bargaining agreement (CBA), reduced its workforce as part of a cost saving initiative following a budget decision adopted by the parent company by offering mutual separation agreements to a number of employees. The court concluded that this constituted a redundancy situation and emphasized that the obligation to initiate trade union consultations arises as soon as there is a risk of employees being dismissed due to redundancy. No such consultations had been conducted prior to entering into the mutual separation agreements.
The Court found that the employer was required to initiate trade union consultations when it became apparent that redundancies might be implemented as a result of the adopted budget. The fact that all affected employees were offered and accepted mutual separation agreements did not impact the employer’s obligation to consult.
Employer implications/action needed This ruling confirms that trade union consultations must be conducted in redundancy situations, regardless of whether mutual separation agreements are offered and whether the employer is bound by a CBA.
Employer risk N/A
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New legislation on work permits
Impact date: 1 June 2026
New legislation relating to work permits has entered into force. The legislation aims at increasing certain requirements for work permit applications, while also promoting the immigration of highly qualified labor. The changes include increased wage requirements and health insurance for work permit applicants and increased sanction fees for employers engaging employees who do not have a right to work in Sweden. The legislation further provides that the Government may decide that certain types of workers would no longer be eligible for work permits.
Employer implications/action needed Employers should ensure awareness of and compliance with the new work permit regulations in respect of employees who require a work permit to work in Sweden.
Employer risk N/A
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Swedish proposal to implement the EU Platform Work Directive
Impact date: 2 December 2026 (expected, and may be subject to change).
The EU Platform Work Directive aims to strengthen the protection and working conditions of individuals engaged through digital labour platforms. On 12 January 2026, the Swedish Government published an inquiry report proposing amendments to Swedish law to transpose the Directive.
The inquiry report proposes the introduction of a new Platform Work Act, currently intended to enter into force on 2 December 2026. The proposed legislation would, among other things, regulate when a person engaged through a digital labour platform is to be regarded as an employee of the platform company and introduce rules governing the use of automated decision-making and monitoring systems by platform operators. However, further legislative proposals are expected to be issued during 2026 before a final legislative proposal is presented.
Employer implications/action needed Employers should continue to monitor the progress of the new Swedish Platform Work Act.
Employer risk N/A
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EU Pay Transparency Directive
Impact date: Awaited
At the beginning of 2026, the Swedish government referred a legislative proposal to the Council on Legislation as part of the legislative process to implement the EU Pay Transparency Directive in Sweden. Since the government’s referral, the legislative process in Sweden has been subject to further developments. On 11 March 2026, the government announced its intention to postpone the implementation of the Directive to 1 January 2027, instead of 1 July 2026 as previously proposed. The government has since announced that it is pausing the implementation of the Directive in Sweden and that until further notice, no legislative proposal will be presented. The government instead seeks to renegotiate the Directive, referring to the administrative burden arising from the Directive and the risk that this may undermine the intended gender equality benefits.
Employer implications/action needed The outcome of these developments remains to be seen, and we encourage employers to stay informed of further developments relating to the implementation of the EU Pay Transparency Directive in Sweden.
Employer risk N/A
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