The Swedish government has now published its draft legislation (Lagrådsremiss) outlining how the EU Pay Transparency Directive will be implemented into Swedish law.
The proposal introduces several new employer obligations, while largely building on existing requirements around pay audits and active measures under the Swedish Discrimination Act.
The overall objective is clear: to reduce unjustified pay gaps between women and men through increased transparency, stronger employee rights, and clearer enforcement mechanisms.
Background: The Gender Pay Gap Persists
Despite long-standing efforts to promote equal pay, gender pay gaps remain. In 2024, the average pay gap between women and men in Sweden amounted to 10.2%, of which 4.6% was considered unexplained.
Against this backdrop, Sweden is now moving forward with the implementation of the EU Pay Transparency Directive. The directive strengthens the principle of equal pay for equal or work of equal value—particularly by improving transparency for both job applicants and employees around how pay is determined.
Pay discrimination must be eliminated. Equal pay should apply regardless of gender. The government is now proposing clear and enforceable rules that, among other things, give individuals the right to insight into pay-setting processes and actual pay differences within organisations.
– Nina Larsson, Minister for Gender Equality
New Requirements – With an Emphasis on Proportionate Administration
The government has emphasised that the implementation should respect the Swedish labour market model and, as far as possible, limit administrative burden for employers. Rather than introducing parallel systems, the proposal builds on existing structures and processes already in place.
In practice, the draft legislation includes the following key measures:
Key Proposals in the Draft Legislation:
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Pay Information in Recruitment
Employers must inform job applicants about the starting salary or salary range for the relevant position at an early stage of the recruitment process. -
Employees’ Right to Pay Transparency
Upon request, employers must provide employees with information about average pay levels—broken down by gender—for employees performing the same or equivalent work. -
Pay Reporting for Larger Employers
Employers with 100 or more employees will be required to produce a pay report showing, among other things, average gender pay gaps. The report must be submitted to the Swedish Equality Ombudsman (DO), which will also publish certain elements of the data. -
Damages and Administrative Penalties
Employers that fail to comply with information or reporting obligations may be subject to damages or administrative fines payable to the state. -
Strengthened Legal Remedies for Individuals
Procedural rules are amended to make it easier to pursue pay discrimination claims. The limitation period is extended to three years, and individuals are given stronger opportunities to have discrimination formally established by a court.
When Will the Rules Enter into Force?
According to the draft legislation, the proposed rules are expected to enter into force on 1 July 2026. The government plans to submit a formal bill to the Swedish Parliament in spring 2026.
This means employers should already begin preparing—particularly when it comes to pay audit structures, documentation, job evaluation frameworks, and pay analysis processes.
Pihr’s Perspective: Pay Audits as the Foundation for Pay Transparency
Pay transparency is not just about reporting or formal compliance. Meeting the new requirements in a sustainable way requires structured, data-driven, and continuous processes for analysing and monitoring pay over time.
In this context, pay audits become a critical foundation—not only as a legal obligation, but as a strategic tool to support fairness, transparency, and long-term compliance with both national legislation and EU-level requirements.
→ Learn more about the EU Pay Transparency Directive
