Sweden Finalizes Proposal for the EU Pay Transparency Directive

By Zhuang Liu

BLOG OVERVIEW: In January 2026, Sweden finalized its draft proposal to implement the European Union Pay Transparency Directive, introducing salary transparency requirements at hiring, employee rights to pay information, expanded gender pay gap analyses, and new pay reporting obligations for employers. The new rules are expected to take effect later in 2026, with phased reporting obligations for smaller employers beginning in 2027.

In January 2026, the Swedish Government finalized its draft legislative proposal for implementing the European Union (EU) Pay Transparency Directive and submitted a referral to the Swedish Council on Legislation. This marks a major milestone in Sweden’s transposition process ahead of the EU implementation deadline of June 2026.

The proposal would amend Sweden’s Discrimination Act and may introduce related adjustments to the Public Access to Information and Secrecy Act. The amendments would integrate Sweden’s existing rules on pay mapping and analysis requirements with new transparency and reporting obligations from the Directive.

Key Proposed Obligations

1. Pay Transparency at the Recruitment Stage
   Employers would be required to inform job seekers of the starting salary or salary range for a position. Employers would also be prohibited from asking candidates about their pay history. These rules are intended to prevent gender pay gaps from arising at the point of entry.
2. Employee Right to Pay Information
   Employees would gain a statutory right to request written information about (a) their own pay, and (b) the average pay of women and men performing equal work or work of equal value, broken down by gender and reported as annual and hourly pay. Employers would need to respond to employee requests within two months and inform employees annually of this right. Additionally, employers may not prevent employees from sharing their own pay information.
3. Expanded Pay Analysis Requirements
   Under the proposal, employers would be required to conduct a more comprehensive analysis of pay differences directly or indirectly related to gender. The new obligations require employers to assess differences under three scenarios: (1) between women and men performing equal work; (2) between groups performing female-dominated work and groups performing work of equal value that is not female-dominated; and (3) between groups performing female-dominated work and groups performing non-female-dominated work that is compensated at a higher level despite having lower job requirements.
4. Pay Surveys and Reporting Obligations
   The proposal would also strengthen and expand existing pay mapping requirements:

• • Employers with 25 or more employees would be required to prepare written pay mapping documentation containing detailed pay data by gender and planned measures to address pay gaps.
  • Employers with 100–249 employees would need to submit pay reports to Sweden’s Equality Ombudsman on a three-year reporting cycle.
  • Employers with 250 or more employees would have to submit annual pay reports to the Equality Ombudsman.
  • If a pay gap of 5% or more is identified for equal work or work of equal value, the employer would need to either justify it using objective, gender-neutral criteria or take remedial action.

Enforcement and Sanctions

Employers that fail to submit required information to Sweden’s Equality Ombudsman may be subject to an administrative sanction fee, indexed to inflation and payable to the state. Violations of the Act could also lead to discrimination claims by employees or job seekers.

Importantly, in pay discrimination cases, employers who have not complied with the new requirements may face a heightened burden defending discrimination claims, unless the breach was manifestly unintentional and minor.

What’s Next

Following review by the Council on Legislation, the Swedish government is expected to submit a formal bill to Parliament later in 2026. If adopted, the new rules would go into effect later before the end of 2026, with certain reporting obligations phased in for smaller employers beginning in 2027¹. Given the proposal’s use of concepts such as “groups of employees” and “female-dominated work,” further interpretative guidance from the Equality Ombudsman will likely play a critical role in assisting employers with implementation. With this in mind, employers should continue to monitor updates from Sweden.

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