Status of implementation of the Pay Transparency Directive

The Pay Transparency Directive was due to be transposed into Swedish law by 7 June 2026 at the latest. However, as we reported in our previous newsletter, the government announced earlier this spring that implementation of the directive would be postponed. The government had been pushing for a renegotiation of the directive, but on 22 May 2026, the European Commission announced that it did not intend to include the Pay Transparency Directive in any future omnibus package for regulatory simplification or in any so-called ‘stop-the-clock’ measure. In other words, renegotiation is not on the table. This means that the Swedish legislative process will now resume, but there is still uncertainty as to when a concrete legislative proposal will be presented. However, the fact that the directive has not been transposed into Swedish law does not mean that it is entirely without legal significance. In certain limited respects, the directive may have direct effect on public-sector employers. For private-sector employers, however, the directive will have no legal effect until it has been implemented.

Although there is uncertainty as to when the Directive will be implemented into Swedish law, preparations are still ongoing. In June 2026, the Government announced that the Discrimination Ombudsman (DO) had been tasked with continuing to take preparatory measures, including carrying out promotional initiatives regarding employers’ pay survey work. The remit aims, amongst other things, to map out how pay survey work is conducted and to identify what support employers need ahead of the implementation of the Directive.

New rules on work permits

New rules on work permits have been in force since 1 June 2026. The main change is a new, increased salary requirement that replaces the previous condition of ‘adequate means of support’. The new salary requirement means that workers must have a salary equivalent to at least 90 per cent of the median wage applicable in Sweden at the time of application. Based on the current median wage, this equates to a salary of at least 33,390 kronor per month, regardless of the scope of employment (i.e. part-time or full-time). However, the salary must still comply with collective agreements or what is customary within the profession or sector.

The new rules apply to everyone applying for a new work permit and whose application is decided on after 1 June 2026. However, for those applying to extend an existing work permit, transitional rules apply, meaning that applicants applying between 1 June and 1 December 2026 are not subject to the new salary requirement.

There are also certain exemptions, which apply, for example, to shortage occupations in healthcare, technology and specialist fields, as well as to certain recent graduates, employees at start-ups and people covered by the Mass Influx Directive. In addition to the new salary requirement, a requirement is also being introduced that workers with work permits who are to stay in Sweden for a maximum of one year must have full health insurance.