Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
As regards the proposal for a directive on pay transparency, the LO is in favour of strengthening the tools to identify and address pay discrimination. The extensive Swedish practice concerning the Equal Pay Directive, the Equal Treatment Directive and others have not produced sufficient results, despite the fact that the legislation has been in place since the 1970s.
Filed in Swedish · English published by the European Commission
Summary of Unionen's* position on the Commission’s proposal for a Pay Transparency Directive Unionen believes that the proposed Pay Transparency Directive could, by promoting greater pay transparency, have a positive impact on gender equality in the workplace, by increasing the pressure on employers to carry out pay surveys and enforce equal pay between women and men for equal work of equal value.
Swedish Trade Union Confederation (LO) • LO considers that the Commission's proposal constitutes a very serious attack on the Swedish collective agreement model. In the long term, the collective self-regulation model - in which the social partiners have the primary responsibility of independently regulating conditions on the labour market - is at stake.
On behalf of the PTK, the (Swedish) council for negotiation and cooperation, Unionen would like to provide feedback in the form of the attached joint legal analysis of the Commission’s proposal for a directive on adequate minimum wages in the European Union. Our main concerns and conclusions can be summarised in three points: 1.
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