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The Discrimination Act’s equal pay survey requirement needs reviewing

To counteract unfair gender pay differences, all employers must carry out equal pay surveys. A Swedish National Audit Office audit shows that the legislative requirements can only affect pay differences to a minor extent, particularly among small employers.

Woman and man in stairs in office environment.

Photo: Nicho Södling

One central government instrument for counteracting unfair pay differences is equal pay surveys, which all employers are required to carry out. Companies with at least ten employees must also document the surveys and the measures that are planned as a result.

The Swedish NAO has examined how effective equal pay surveys are in counteracting unfair pay differences. The audit findings include the following:

  • For employers with between 20 and 30 employees, the requirement for documented equal pay surveys has had no effect on gender income differences.
  • Employer and employee organisations consider that equal pay surveys are demanding, while seldom leading to the discovery of unfair pay differences.
  • Pay differences between women and men working at the same employer were six per cent in 2016. The figure for the labour market as a whole in the same year was 12 per cent.
  • The pay differences are somewhat smaller at small employers than large employers.

“The requirements regarding documentation of equal pay surveys did not have any measurable effect on pay differences in the companies studied. The audit also shows that parts of the equal pay survey may be complicated to implement. The Swedish NAO’s assessment is therefore that the legislation needs to be reviewed,” says Auditor General Stefan Lundgren.

“Equal pay surveys are intended to counteract unfair pay differences between men and women who work for the same employer. At present there are no overall statistics on pay differences at employer level. These statistics need to be compiled to enable the Government and public authorities to assess how central government measures in this field can be developed,” says Christer Gerdes, project leader for the audit.


The Swedish National Audit Office recommends that the Government:

  • investigates whether the legislation can be simplified, so that equal pay surveys are not a burdensome task for employers,
  • investigates whether the legislation can be better adapted to size of the employer,
  • instructs the Swedish National Mediation Office to monitor developments in pay differences between men and women employed by the same employer.

Note: The pay differences referred to are differences in salary corresponding to full-time employment between men and women. Earned income refers to total work-related income during the year, taking into account the employee’s actual working hours.

Press contact: Olle Castelius, phone: +46 8-5171 40 04.

Presskontakt: , telefon: 08-5171 42 06.


Updated: 25 June 2019

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