EU Pay transparency directive in Sweden: What companies need to know

The EU pay transparency directive (Directive (EU) 2023/970), which must be implemented by June 2026, will change how pay is handled and communicated across member states – including Sweden.

For employers, this means moving from “we are roughly fair” to documented, provable pay transparency. Recruitment, salary structures, HR routines and leadership decisions all need to support that.

As a recruitment partner, we focus on the practical side: clear salary ranges, structured criteria for offers, and recruitment processes that support compliance instead of working against it.

Key changes at a glance

Salary ranges in job ads
Employers must provide the expected salary or salary range before interviews start – typically in the job ad or at the latest in the earliest contact. Vague “competitive salary” language, without a real range behind it, will not be enough.

No questions about pay history
Companies may no longer ask candidates about their previous salary or use pay history as a basis for offers. The focus needs to shift to the role, responsibilities and market data instead.

Right to information for employees
Employees gain the right to request information about:

• Their own pay level
• Average pay levels for workers doing the same or equivalent work, broken down by gender

This pushes employers to know – and be able to explain – how similar roles are paid. The focus is on pay differences between women and men in the same or equivalent roles. The main comparison is between women and men doing the same or equivalent work, not between every individual role in the company.

Regular pay audits for larger employers

• Employers with 250+ employees: annual pay audits
• Employers with 100–249 employees: audits every three years, with the first due by 2031

These audits will highlight structural pay gaps that need to be analysed and, where necessary, corrected. 

Correction of unjustified pay gaps
If there is an unexplained gap of more than 5% between women and men in comparable roles, the employer must investigate and correct it within a set period. It will not be enough to simply acknowledge that a gap exists.

Reporting to authorities
Larger employers must report pay data to the Swedish Equality Ombudsman (DO), with parts of the information made publicly accessible. Pay structures will be more visible to employees, unions and candidates.

For further legal detail, you can refer to:

• KPMG’s overview of the EU pay transparency directive
• Analyses from firms such as Ogletree Deakins, Eversheds Sutherland and Setterwalls

Why this matters for companies in Sweden

For organisations in Sweden – and for international companies with teams here – the directive has implications on several levels.

Compliance and legal risk
Non‑compliance can lead to:

• Fines and compensation claims
• Legal disputes and pressure from unions or employee groups
• Exclusion from certain public procurement opportunities

Having clear, documented structures reduces both risk and stress.

Talent and employer brand
Candidates are increasingly asking about pay fairness and transparency. Structured, open practices are becoming a deciding factor in competitive recruitment, especially for experienced professionals and international talent.

Cultural alignment
Sweden already has strong norms around equality and openness. The directive pushes companies – particularly international groups – to align their global practices with Swedish expectations on gender equality and fair pay.

How the directive affects recruitment in practice

From a recruitment perspective, several everyday routines will need to change.

Job ads and early conversations

• Salary ranges or pay bands need to be defined before a role goes live
• Job ads should give candidates a realistic view of pay, not just “competitive salary”
• Internal approvals must support this by agreeing the range in advance

Interview questions

• Standard questions about current or previous salary will no longer be allowed
• Recruiters and hiring managers need to focus on:
  • Salary expectations
  • Scope and responsibilities of the role
  • Market benchmarks and internal pay structure

Offer process

• Offers should sit within an agreed salary band for comparable roles
• Exceptions need clear, documented reasons to stand up in audits later
• Differences between Sweden and other markets (for example Sweden vs the Netherlands) must be grounded in role content, not “what we could get away with”

This is where recruitment, HR and finance need to work together. Without clear criteria for levels and pay bands, compliance becomes very hard very quickly.

How we support clients as a recruitment partner

We do not replace legal counsel, but we help turn the directive into practical routines in recruitment and salary work.

Recruitment and job ads

• Shape realistic, market‑aligned salary ranges or bands for key roles
• Make sure job ads and early candidate communication are transparent and aligned with the new rules

Objective salary structures

• Define neutral criteria for different salary levels, such as:
  • Experience and skills
  • Scope of responsibility
  • Business impact
• Prepare simple documentation so decisions are easier to explain in audits or internal discussions

Salary benchmarking

• Provide up‑to‑date market data for Sweden (and, where relevant, other markets)
• Help you avoid both underpaying and ad‑hoc overpaying that creates internal gaps

Audits, remediation and training

• Support HR and leadership in preparing for pay audits:
  • Interpreting audit results
  • Identifying patterns and anomalies
  • Planning salary corrections in a structured way
• Co‑create short guidelines and training so hiring managers:
  • Know how to talk about salary ranges in interviews
  • Avoid prohibited questions
  • Answer candidates who ask about pay fairness with confidence and consistency

When we help clients prepare for the EU pay transparency directive, we usually work in three steps:

• Stay ahead of regulation – we track evolving laws and guidance (including Sweden’s SOU 2024:40) and translate key points into everyday decisions, not long memos.
• Align your recruitment process – together we review job ads, interview routines, offers and approvals so they are transparent, consistent and ready for scrutiny.
• Plan long term – for organisations with 100+ employees, we outline a realistic roadmap for data, audits and communication so the directive becomes a planned project instead of a last‑minute rush.

Throughout this work, we also look at how you talk about fairness and transparency in your employer branding, so compliance requirements strengthen your position in the talent market.

Is your organisation ready for the new transparency rules?

The EU pay transparency directive is more than a legal requirement. It is an opportunity to make your pay practices clearer, fairer and easier to explain – to employees, candidates and stakeholders.

If you want to turn these new rules into a competitive advantage, we can support you in aligning your recruitment, salary ranges and communication with the upcoming requirements.

You are welcome to book a meeting with the Beyondo team to discuss where you are today and what a realistic roadmap could look like or Download our Ultimate guide to recruitment.

Key external resources

For more background, you can read:

• Overviews of the EU pay transparency directive from KPMG and Ogletree Deakins
• Information on Sweden’s implementation work (SOU 2024:40) and commentary from firms such as Eversheds Sutherland and Setterwalls
• Figures’ guide to pay transparency in Sweden for a compensation and data perspective