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on salary levels, and, not least, reporting. In practice, all employers will be affected, especially by the new information rights for employees and job applicants. In Sweden, this also interacts with the role of the Swedish labor market model and collective agreements. Sweden’s Baseline: Pay Mapping is Already Established At the same time, Sweden is not starting from scratch. Pay surveys/ pay mapping (“lönekartläggning”) have been a legal requirement since the mid-1990s, originally under the former Equal Opportunities Act. Today, pay mapping is regulated under the Discrimination Act as part of the rules on active measures. Since 2017, it must be carried out annually, and employers with 10 or more employees must document the work. This existing framework provides a strong baseline for pay transparency. The guiding principle in the Swedish implementation has therefore been to reuse and build on established rules and processes to the extent that this is possible.

In practice, all employers will be affected, especially by the new information rights for employees and job applicants.

the private sector. Although trade unions can request pay data under the Co-Determination in the Workplace Act (MBL) to verify compliance with agreements and law. Separately, taxable income information is public and can be obtained from the Swedish Tax Agency under the Freedom of the Press Act (Tryckfrihetsförordningen), subject to any secrecy limits in the Public Access to Information and Secrecy Act. A Directive With Many Angles: Recruitment, Rights, and Reporting Those who have followed the EU Pay Transparency Directive closely know that it has multiple angles: information to presumptive employees, present employees, obligations for the employer in transparency

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GLOBAL PAYROLL MAGAZINE ISSUE 21

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