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Compliance

Sweden employment compliance: a guide for employers

What you owe a Swedish employee, and by when: collective agreements, annual leave and holiday pay, and the first fourteen days of sick pay. Every figure links to Riksdagen or Försäkringskassan so you can check it.

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Sweden employment compliance: a guide for employers

At a glance

  • Collective agreements: nothing binds you but membership or your own signature. Sweden has no equivalent of Finland's general applicability, so being the sector standard is never enough.
  • But MBL still reaches you without one: bargaining over redundancies and business transfers (13 § 2nd para), and continuous information to unions with members on your payroll (19 a §).
  • Annual leave: 25 days a holiday year, 5 if employment started after 31 August. How many are paid comes out of a separate formula whose denominator is 365 or 366, not a fixed 365.
  • Holiday pay: 0.43% of monthly pay per paid day under sammalöneregeln. A variable pay component reaching 10% forces you onto the percentage rule instead, whether you noticed or not.
  • Sick pay: 80% for 14 calendar days, less one karensavdrag of 20% of an average week. Then report to Försäkringskassan on day 15, day 21 at the very latest.

You have hired someone in Sweden, and three Acts now decide what you owe them. None of them waits until you have an HR team, and the two that cost money most often are the ones nobody warns a foreign employer about.

This page is the map. Each section gives you the rule, the numbers you need at month-end, and a link to the full treatment.

Start where you are. A union has been in touch, or you are wondering whether you need an agreement? What actually binds you, and what still reaches you if you sign nothing. Running payroll, or booking the summer? Annual leave and holiday pay, including which of an employee’s days are actually paid, which is rarely all of them. Someone off sick? Who pays, for how long, and the two deadlines. Want the year on one page? The recurring deadlines.

Two Acts that a Finland-shaped guide would cover, the minimum terms of an employment contract and working time, are deliberately absent rather than invented. They are a follow-up.

Do you have to have a collective agreement?

No. Swedish law imposes no general duty to sign one, and nothing binds you just because an agreement is standard in your sector.

26 § of the Co-Determination Act settles the mechanism: an organisation’s agreement binds its members, within the agreement’s scope. Membership, or your own signature on a hängavtal, an ordinary collective agreement signed direct with a union under 23 §, just with a different counterparty. Nothing else.

This is the biggest structural difference from Finland, and the reason Finnish guidance does not translate. Finland’s yleissitovuus makes a sufficiently representative agreement bind non-members. Sweden has no equivalent mechanism at all.

But an unbound employer is not outside MBL. Two duties reach it:

Duty Unbound employer Bound by an agreement
Statutory floor — leave, sick pay, protection Applies in full Applies in full, usually with more
Primary bargaining before significant changes No Yes — 11 §
Bargaining before redundancies or a business transfer Yes — 13 § 2nd para Yes — 11 §
Continuous duty to inform Yes, narrower — 19 a § Yes — 19 §
Bargaining before engaging agency staff No Yes, in certain cases — 38 §
Bound by the sector standard without your own agreement No Not applicable

The two that catch unadvised companies are in the Co-Determination Act: 13 §, second paragraph, requires bargaining with all affected worker organisations over redundancy dismissals and transfers of the undertaking, and 19 a § requires continuous information to unions with members on your payroll. Neither depends on having signed anything.

Read more: Collective agreements in Sweden: what a hängavtal commits you to, what changes the day you become bound, and what your employees have without one.

How does annual leave accrue, and how is holiday pay calculated?

Twenty-five days a holiday year, but how many of them are paid is a separate calculation, and the two are confused constantly.

Rule Figure
Annual leave days per holiday year 25 — or 5 if employment started after 31 August
Holiday year and earning year 1 April – 31 March
Paid days Employment days ÷ actual days in the earning year × 25, rounded up
Holiday supplement, sammalöneregeln 0.43% of monthly pay per paid day; 1.82% of weekly pay
Holiday pay, procentregeln 12% of pay that fell due in the earning year
Variable pay forcing procentregeln 10% of total pay for the holiday year
Saveable days Those above 20 paid days, for five years
Main holiday period Four consecutive weeks, June–August
Notice of scheduling Two months before the leave begins
Holiday compensation on termination Within one month of employment ending

Two things quietly produce wrong numbers every year. The denominator in the paid-days formula is the actual number of days in the earning year, 365 or 366, and a hard-coded 365 is wrong one year in four (7 §). And a variable pay component reaching ten percent of total pay makes the percentage rule mandatory even for a monthly-paid employee, whether or not payroll noticed (16 §, second paragraph). Commission, shift premiums and bonuses cross that line early.

The Act is mandatory in the employee’s favour: an agreement reducing their rights under it is void to that extent (2 §).

Read more: Annual leave and holiday pay in Sweden: both models worked through, the five mandatory cases, saved days and holiday compensation. Or run one person through the annual leave calculator.

Who pays for sick leave, and for how long?

You do, for fourteen calendar days, at 80 percent. Then Försäkringskassan takes over, provided you reported the case.

Day What happens Who pays
Day 1 Karensavdrag: 20% of an average week’s sick pay, deducted once You
Day 1–14 Sick pay at 80% of employment benefits You
Day 8 Sick pay is due only against a doctor’s or dentist’s certificate You
Day 15 Report the case to Försäkringskassan Försäkringskassan
Day 21 Last permitted day for that report —

Three things go wrong repeatedly. The karensavdrag is not an unpaid day. The karensdag was abolished on 1 January 2019, and the replacement is a fixed 20 percent of an average week’s sick pay, deducted once per sick period and capped at ten in twelve months (6 §). The fourteen days are calendar days, not working days (7 §). And the day-8 certificate rule sits in the second paragraph of 8 §, not in 10 § as it is usually cited: it conditions your duty to pay rather than granting you a right to ask (8 §).

Day 21 is the number to build a process around. Försäkringskassan cannot begin paying sickness benefit until your report exists, so a late report delays your employee’s income rather than your paperwork.

Read more: Sick pay in Sweden: the period day by day, the relapse rule, and the ten most common errors. If the illness starts during a holiday, see Sick leave during annual leave in Sweden.

What are the recurring deadlines?

The same rhythm every year, whatever your headcount. Three clocks run:

When What Where
Monthly The arbetsgivardeklaration is filed and contributions paid, generally by the 12th — the 17th in January and August Skatteverket
Spring and summer 31 March closes the holiday year · four consecutive weeks fall in June–August · scheduling notice runs two months ahead Annual leave
On every absence Day 8 certificate · day 15 report to Försäkringskassan · day 21 outer limit Sick pay

Two months before June is the end of March, which means summer scheduling has to happen before the holiday year closes, not after.

A dated listing covering the whole year, sourced from Riksdagen and Skatteverket, is collected in the Sweden HR compliance calendar, which is the canonical source for those dates.

Beyond these three Acts

Two more areas arrive with the first hire and are covered separately:

How does Taito.ai help with this?

The mistakes above rarely come from not knowing the law. They come from nobody having, in one place, which agreement applies to whom, how many calendar days of a sick period have elapsed, how many karensavdrag an employee has had in the past twelve months, or how much leave has actually accrued and how much of it is paid.

Taito.ai is a people operations system, not a substitute for payroll or for legal advice. It does not track legislative changes for you and it will not tell you whether your company is bound by a particular agreement. It handles the part a spreadsheet handles worst: leave policies are defined as rules, balances update against them, and each employee’s accrual, taken leave, remaining balance and sick periods stay visible without a separate spreadsheet per person.

Start a free trial or see how Taito.ai works.

Frequently asked questions

Does a collective agreement bind an employer that has not joined an employers association?
No, not on its own. Under 26 § of the Co-Determination Act (1976:580), an organisation's collective agreement binds only that organisation's members within the agreement's scope. An employer that has not joined the contracting employers' association, and has not separately signed a hängavtal, a stand-alone agreement direct with a union, is not bound, no matter how standard the agreement is in the sector or how many competitors apply it. 27 § reinforces the same point from the other direction: parties who are bound cannot validly agree to terms that conflict with it. So binding force runs strictly through membership or a signed agreement, never through sector membership by itself. In practice this means a request from a union to apply a sector agreement is a decision the employer makes, not an obligation it is already carrying. It is also the single biggest structural difference from Finland, where a sufficiently representative agreement can bind non-member employers directly, a mechanism Sweden has no equivalent of.
What does the Co-Determination Act require of an employer with no collective agreement at all?
Fewer duties than a bound employer carries, but not nothing, and the gap is where unadvised companies get caught. The primary bargaining duty in 11 §, the continuous duty to inform in 19 § and the duty to bargain before engaging agency staff or a contractor in 38 § all attach to an employer bound by a collective agreement, so an entirely unbound company does not carry them. Two provisions reach it anyway. Under the second paragraph of 13 §, an employer bound by no collective agreement must bargain under 11 § with all affected worker organisations on questions concerning redundancy dismissals, or a transfer of the undertaking within the meaning of 6 b § of the Employment Protection Act. And under 19 a §, it must continuously inform worker organisations that have members among its employees about how the business is developing in production and financial terms, and about its personnel-policy guidelines. So having no agreement narrows the counterparty rather than removing it.
How many paid annual leave days is an employee entitled to?
An employee is entitled to 25 annual leave days every holiday year under the first paragraph of 4 § of the Annual Leave Act (1977:480). That is a statutory floor: a collective agreement can add days, never subtract them. The same paragraph carries an exception that recruiters miss most often: an employee who starts after 31 August is entitled to only five annual leave days that year, because the holiday year runs 1 April to 31 March. Entitlement to 25 days of leave is not the same as entitlement to 25 paid days, though. 7 § calculates paid days separately, from employment days in the earning year less unpaid absence that does not generate holiday pay, over the days in that year, times 25, rounded up. Someone who worked the whole earning year without such absence receives all 25 days paid; someone who started partway through receives fewer paid days but keeps the right to the leave itself, the difference being unpaid leave unless otherwise agreed.
Sammalöneregeln or procentregeln — which one applies to holiday pay?
Sammalöneregeln, the same-pay rule under 16 a §, is the default for an employee on a fixed monthly salary: pay continues unchanged during leave, plus a holiday supplement of 0.43 percent of monthly pay per paid leave day. Procentregeln, the percentage rule under 16 b §, instead sets holiday pay at 12 percent of pay that fell due during the earning year, and normally applies to employees without a fixed monthly salary, such as hourly-paid staff. The choice is not free: the second paragraph of 16 § lists five situations where the percentage rule is mandatory even for a monthly-paid employee: pay not fixed weekly or monthly; a variable pay component reaching ten percent of total pay for the holiday year; employment level that varied during the earning year; employment level that changed between the earning year and the leave; and absence during the earning year that does not generate holiday pay. The variable-pay case is missed most often: commission, shift premiums and bonuses cross ten percent faster than expected.
How many annual leave days can be saved, and by when must they be used?
An employee entitled to more than 20 paid annual leave days in a holiday year can save the surplus for a later year, under 18 § of the Annual Leave Act. At the statutory floor of 25 days that allows up to five saved days a year, more if a collective agreement grants more than 25 days of leave. A saved day must be used within five years of the end of the holiday year in which it was saved, under the second paragraph of 18 §; if using it in the fifth year would cause significant inconvenience, the parties can agree under the second paragraph of 20 § to push it to a sixth year. A detail that is easy to miss sits in the third paragraph of 18 §: new days cannot be saved during a holiday year in which previously saved days are being used, so payroll records must keep saved days and new accrual visibly separate, or which days are closest to expiring becomes impossible to see.
What happens to unused annual leave when employment ends?
Under 28 §, unused leave is paid out as holiday compensation instead of taken as time off, covering all leave not yet taken or compensated, both from earlier earning years and from the current, still-open earning year. The compensation is calculated under 29 § using the same model that applied during employment, sammalöneregeln or procentregeln, and saved days are valued as if taken in the holiday year in which employment ended. The deadline is in 30 §: compensation must be paid without undue delay and no later than one month after employment ends, so the law does not require it on the final payroll run, but a month is an outer limit rather than a normal processing time. A common mistake is calculating compensation only for the last completed earning year and forgetting the proportional share accrued during the still-open earning year up to the final day of employment. Both parts need calculating before final pay goes out.
How is the karensavdrag calculated, and is it the same as a karensdag?
No. The karensdag, a whole unpaid first sick day, was abolished on 1 January 2019 by SFS 2018:648 and replaced by the karensavdrag. Under 6 § of the Sick Pay Act (1991:1047), the karensavdrag is a fixed deduction equal to 20 percent of the sick pay calculated on an average week's employment benefits, the same amount regardless of which weekday the sick period starts or how many hours that particular day would have involved, rather than one unpaid day. It is deducted once per sick period, not once per sick spell within that period, and the same paragraph's third clause caps it: once ten karensavdrag have been made within a twelve-month period, no further deduction is made. Older templates, collective-agreement text and internal routines sometimes still use the retired term karensdag; updating them matters, because it describes a different, and no longer applicable, calculation.
How and when do you report a sick employee to Försäkringskassan?
When the 14-calendar-day sick-pay period runs out, responsibility shifts to Försäkringskassan, and the employer, not the employee, must report the case on calendar day 15, because the employer paid sick pay for the first 14 days and knows when the sick period started. The last permitted day for that report is calendar day 21, an outer limit that is easy to overlook but decisive, because Försäkringskassan cannot begin paying sickness benefit until the report has been made. A late report therefore delays the employee's benefit, not just an administrative step. Building a reminder around day 10 to 12 of the sick period gives enough margin to report well before day 21, since attention naturally drifts elsewhere during a longer sick spell and the day-21 deadline is easy to miss without a prompt built into the process itself.
When is a medical certificate required for continued sick pay?
From the seventh calendar day after the sick report, under the second paragraph of 8 § of the Sick Pay Act, colloquially day 8. The rule is not that the employer may request a certificate; it is that the duty to pay sick pay from that day onward is conditional on the employee substantiating reduced work capacity with a certificate from a doctor or dentist. Until then, the employee's own sick report is sufficient. An employer wanting a certificate earlier than day 8 needs special grounds under 10 a §, and the request must be in writing; a separate provision, 10 §, gives Försäkringskassan its own power to require an earlier certificate, a different situation from the employer's own request. Stating the day-8 requirement up front, as part of the standard sick-reporting routine rather than only when a certificate is first requested, reduces friction and makes clear the request follows a fixed rule rather than singling anyone out.
Does a relapse within five days restart the sick-pay period?
No. Under the third paragraph of 7 § of the Sick Pay Act, if an employee recovers and then falls ill again within five calendar days, both spells count as the same sick period rather than two separate ones. That has two practical effects: the karensavdrag is not made a second time, since it has already been deducted for the sick period, and the new sick-pay period covers only as many days as, combined with the earlier one with the same employer, add up to 14 calendar days; the count does not restart from day one. Payroll administration therefore needs to check each employee's sick history back at least five days, not only the most recent report, to calculate both the karensavdrag and the remaining sick-pay days correctly; a system that looks only at the latest report in isolation will get this situation systematically wrong.
What happens when an employee falls ill during annual leave, and does that sick absence still count toward the next holiday year of leave?
Under 15 § of the Annual Leave Act, days during a period of leave when illness or an occupational injury would have prevented the employee from working are not counted as annual leave days, provided the employee requests this without delay, from the first sick day, with no minimum number of leave days that must first be used up. The swapped days are paid as sick pay rather than holiday pay, meaning the karensavdrag and the 80 percent rate apply exactly as in ordinary sick absence, and the remaining leave after the swap must be scheduled in one block unless the employee agrees otherwise. Separately, sick absence is *semesterlönegrundande*, holiday-pay generating, for up to 180 days per earning year under the first paragraph of 17 §, with absence due to an occupational injury exempt from that limit; the second paragraph of 17 § cuts the entitlement off entirely once the employee has been absent for a whole earning year with no gap longer than 14 days.

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