At a glance
- The Swedish government has published its legislative agenda for the coming months, confirming that its bill to implement the Gender Pay Transparency Directive (Directive) will be presented in January 2026. The bill will amend the existing Discrimination Act to bring Swedish laws into alignment with the Directive obligations.
- Notwithstanding that it is not an EU Member State, Norway's status as a country within the European Economic Area means that it may also implement the Directive by June 2026.
- Norway already has gender pay gap reporting regulations under the Equality and Anti-Discrimination Act, which apply to employers with 50 or more employees.
- However, Norway's existing laws are not wholly Directive compliant. This means that new reporting obligations may be introduced for employers of 250 or more employees from June 2027.
- Norway may also introduce new rules requiring employers to disclose salaries / pay ranges and preventing employers from asking candidates about their previous salary.
- Further, Norway's laws may provide for employees to be able to request information about their own pay and average pay by gender for work of equal value. Employers may also be required to proactively explain pay-setting criteria.
- Final confirmation of Norway's approach to the Directive will be determined in due course.
Update: 18 December 2025
Three major Swedish employer organisations have formally asked the Swedish government to request a postponement of the Directive’s implementation in Sweden. The organisations involved are:
- The Confederation of Swedish Enterprise.
- The Swedish Association of Local Authorities and Regions.
- The Swedish Agency for Government Employers.
According to these organisations, the current timeline will leave businesses and public sector employers only a few months to prepare for extensive new reporting and transparency obligations. They argue the transition period is too short given the administrative and technical adjustments required.
The organisations have therefore urged the Swedish government to ask the European Commission to allow Sweden to delay domestic entry into force until 1 January 2027 at the earliest.
Further developments on this situation will need to be monitored closely.
