Sweden Pay Transparency Law: EUPTD Transposition Status
Local term: lönetransparens
As of 28 September 2026: At last check, Sweden had paused transposition. In March 2026 the government said it would seek postponement and renegotiation of the Directive. In June 2026 it instructed the Equality Ombudsman (DO) to continue preparatory work.
Status snapshot
| Status | No draft yet |
|---|---|
| National instrument | No bill. The government announced in March 2026 that it would seek postponement and renegotiation, and in June 2026 instructed the Equality Ombudsman to continue preparations. |
| Official source | Government of Sweden: Pay Transparency Directive |
Pay gap reporting required before the Directive
Pay survey (lönekartläggning)
| Who reports | All employers. Written documentation for employers with 10+ employees |
|---|---|
| How often | Annually |
| What is reported | Analysis of pay and pay criteria to detect unjustified differences between women and men doing equal or equivalent work |
| Published or internal | Internal. Carried out in cooperation with employee representatives |
| Legal basis | Discrimination Act, chapter 3, sections 8 to 13 |
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
Not yet legislated.
Things to work on now
- Priority for Sweden. Keep your annual pay survey (lönekartläggning) going: it already applies.
- Priority for Sweden. Swedish pay surveys are a good base for the Directive's job evaluation requirements.
- Use the Directive as your baseline. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4).
- Data readiness. Check your HR and payroll systems can produce the Article 9 indicators, including variable pay and gaps by category of workers.
- Contracts and recruitment. Review pay secrecy clauses and pay history questions now, as these changes carry little cost.
- Review date. Set a date to check for a published bill, as national timelines can move quickly.
Legislative timeline
- 26 March 2026Government announces it will seek postponement
- June 2026Equality Ombudsman instructed to continue preparations
Frequently asked questions
Has Sweden transposed the EU Pay Transparency Directive?
At last check, Sweden had paused transposition. In March 2026 the government said it would seek postponement and renegotiation of the Directive. In June 2026 it instructed the Equality Ombudsman (DO) to continue preparatory work.
When does gender pay gap reporting start in Sweden?
Some reporting already applies under national law: all employers carry out an annual pay survey, documented in writing where they have 10+ employees. Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Sweden.
What should employers in Sweden do now?
Keep your annual pay survey (lönekartläggning) going: it already applies. Swedish pay surveys are a good base for the Directive's job evaluation requirements. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.