Salary Transparency 2026/2027 – request for salary information, salary comparison & employer response | Word/PDF/Excel

An employee requests access to pay setting – how does the employer receive the request, assess equal or equivalent work, and respond without disclosing colleagues' salary details? This niche document package contains Swedish Word and PDF templates for the information request itself, the employer's assessment, and the written response, as well as an Excel register with aggregated salary data and manual confidentiality checks.

Important Swedish legal status November 2026: EU Pay Transparency Directive 2023/970 has been adopted, but the new Swedish information regulations have not yet been introduced. The government announced in March 2026 that it will not present the bill for the time being, and DO continues preparations. Article 7 of the Directive specifies a response time of no more than two months, but this is not an established general Swedish statutory deadline today. Any direct effect and special requirements under collective agreements or other law are assessed separately. GDPR and the current annual pay mapping under the Discrimination Act already apply.

Five work documents – concrete use cases

1. Request for pay information – employee: a neutral letter for inquiries about their own pay, substantive pay criteria, and possible aggregated comparison. It does not claim that Article 7 has already been adopted as Swedish law.
2. Employer receipt and legal status assessment: register the request and receipt date; distinguish the EU Directive scenario from the Swedish Discrimination Act, GDPR register extracts, collective agreements, and possible public employer situation.
3. Equal/equivalent work and privacy: compile job evaluation criteria, comparison groups, uniform periods, anonymity and identification risk, and approval of actual disclosure.
4. Written response from employer: communicate verified information about their own pay, pay criteria, and any aggregated averages. Document reasoned limitations when disclosure of other people's data is not permitted.
5. Supplementation and annual information: register substantive objection, corrections, and follow-up. A separate voluntary message can be prepared for future Article 7 information without describing it as current Swedish law.

Excel with nine tabs – without individual payslips

Overview, Cases, Workgroups, Aggregated Pay, Confidentiality, Responses, Actions, Legal Status, and Sources. Only fill in aggregated numbers and total compensation per category of equal/equivalent work. Excel automatically calculates averages and indicative pay gaps when the data is available and comparable. It records actual responses and provides a separate EU planning indicator two calendar months from receipt – expressly not a claimed Swedish statutory deadline.

Privacy check: if a gender group contains a single person, the data is flagged as an individual risk. Other aggregates are still marked for manual confidentiality assessment. There is no claimed statutory “safe minimum group size”. No personal identity numbers, named colleagues' individual salaries, or test data are included.

What applies under the Directive – and what already applies in Sweden?

EU Directive 2023/970 Article 7 deals with an employee's information about their individual pay level and the average pay levels for women and men in the same or equivalent work, annual information, and a maximum response time of two months. Article 12 specifies data protection rules and possibilities for Member States to protect identifiable individual pay through special recipients. The Swedish national implementation of the new requirements is still being prepared.

Even today, annual pay mapping under the Discrimination Act applies to all employers, with a documentation obligation for at least ten employees. This is not the same as an unrestricted right for an employee to receive colleagues' payslips. IMY's principles of data minimization require that personal data is not collected or disclosed in a greater extent than necessary.

See also the government's statement of 26 March 2026 and DO's current status on continued Swedish preparation.

Difference from Mallbutikens other pay products

Pay Mapping Template Package systematically maps pay gaps for the employer. Pay Policy & Pay Review helps with the pay setting process and review. This product starts when an employee actually asks and ends when the employer has made a tested, documented response.

Frequently Asked Questions

Do all employees already have a general Swedish right to receive colleagues' average salaries within two months?

Not according to a new implemented Swedish Article 7 rule as of 9 November 2026. The EU Directive contains this future framework, but the Swedish implementation has been paused. Individual rights under other law, such as GDPR, public access rules, or collective agreements, need to be assessed separately.

Can we automatically disclose the average when Excel has calculated it?

No. Even an average can indirectly identify a certain person in a small or particularly delimited group. Disclosure always requires an independent legal and data protection assessment. Excel shows a warning indicator, not a confidentiality approval.

Does annual pay mapping also apply to companies with fewer than ten employees?

Yes, annual pay mapping applies to all employers under the Swedish Discrimination Act. For at least ten employees, a special documentation obligation applies. This is a different question from future pay access under the EU Directive.

Can a public employer already be bound by parts of the Directive?

Any direct effect is a legal assessment on a case-by-case basis. DO has not established which individual provisions may have direct effect. The templates do not draw any automatic conclusions about this.

Are all templates in English and are the PDF files fillable?

Five work templates and Excel are in Swedish. A Swedish user guide and a separate English User Guide are included. DOCX and XLSX are editable. The PDF files are searchable and printable but are not interactive fillable forms.

Version, review, and delivery

Edition 1.0, internal AI-assisted legal source check 9 November 2026. The document package is an administrative and informative work tool – not a lawyer-approved solution, a government decision, or a guarantee of legal compliance. No external legal review or independent audit has been performed. Digital ZIP delivery is activated separately when the product is published; no files have been linked to a download app.