Sweden has rapidly initiated its response to the EU Pay Transparency Directive (EU 2023/970). As one of the first EU member states to take concrete steps, Sweden already submitted a comprehensive proposal in the form of a government inquiry report, although formal legislation is still forthcoming.
What’s happened so far
The Swedish Government Inquiry — SOU 2024:40, titled Genomförande av lönetransparensdirektivet — was delivered to the government on 29 May 2024. This roughly 400-page report laid out proposals for amending the Discrimination Act (2008:567), including the addition of a new Chapter 3a to explicitly embed pay transparency and equal pay provisions into Swedish law
The inquiry leverages existing systems—particularly the mandated annual pay surveys, known as lönekartläggning, that employers with 10+ employees already conduct. These surveys will serve as the foundation for increased transparency and employee rights
Key Proposals from SOU 2024:40
| Feature | Proposed Change |
| Salary Information to Applicants | Employers must provide the initial salary or range and relevant collective bargaining agreement details before hiring |
| Ban on Salary History Questions | Employers will be prohibited from asking job applicants about their previous pay |
| Use of Pay Surveys for Transparency | Existing annual pay surveys will support transparency and help individuals understand pay structures |
| Reporting Requirements | Employers with ≥100 employees will report gender pay gaps to the Equality Ombudsman (DO), including explanations for gaps ≥5%, with overarching data made public |
| Beyond Directive | The proposals also suggest comparing pay progression related to parental leave, which goes beyond the EU’s minimum requirements |
What comes next
After its publication, the inquiry report entered a consultation phase during summer to autumn 2024, inviting input from labor market partners, agencies such as the Gender Equality Agency, and employer and union organizations. The consultation concluded in October 2024.
Following consultation, the Ministry of Employment is expected to prepare the legislative referral to the Council on Legislation, and then submit a formal government bill to parliament. While a specific timeline has yet to be publicized, the aim remains to adopt the law well before the EU’s 7 June 2026 deadline.
Why this matters
Sweden was the first EU member state to release a draft for implementing the Pay Transparency Directive, sending a clear signal that the issue is being prioritized at the national level. The planned changes represent the most substantial update to Swedish pay equity law since mandatory pay surveys were first introduced in the 1990s, underscoring the scale of the reform. At the same time, some employers have expressed concern that the increased transparency and reporting obligations could create administrative burdens, particularly for organizations with fewer than 100 employees