Sweden


Implementing the EU Pay Transparency Directive in Sweden

Impact date: 1 July 2026 In Sweden, the rules on gender pay gap analysis in the Swedish Discrimination Act, along with rules in most central collective bargaining agreements, already fulfil most of the requirements set forth in the EU Pay Transparency Directive. However, there are additional requirements in the Directive which do not yet apply under Swedish law.

On 15 January 2026, the Swedish Government referred a legislative proposal to the Council on Legislation. The proposal largely aligns with earlier draft legislation to implement the Directive into Swedish law, while also introducing certain changes. For example, the proposal provides that while all Swedish employers will continue to be required to carry out annual gender pay gap surveys, only employers with 25 employees or more will be required to document those surveys in writing, compared to the current threshold of ten employees. For employers with 100 or more employees, who will be subject to the new rules requiring the preparation and submission of gender pay gap reports, the proposal introduces certain amendments to the previously proposed content of those reports. Further, the proposal provides that employers with fewer than 50 employees in Sweden will be exempt from the new obligation under the Directive to inform employees of the criteria used to determine pay, pay levels and pay progression.

The final legislative proposal from the Government is expected to be presented during spring 2026.

Employer implications/action needed Employers should monitor the progress of the implementation of the EU Pay Transparency Directive in Sweden. With the implementation of the Directive approaching, we recommend businesses in Sweden ensure that they are compliant with the current rules on gender pay gap analysis, to prepare for any increased reporting and transparency requirements

Employer risk N/A

Links EU Directives tracker - Managing a Global Workforce; Implementation of the EU Pay Transparency Directive: The latest development in Sweden

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

Links N/A

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Per Westman Partner


E: perwestman@eversheds-sutherland.se T: +46 854 532 288

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