Nordic Employment Law Bulletin - October 2026
In our monthly Nordic Employment Law bulletin our employment lawyers across the Nordic region highlight relevant news and trends on the Nordic employment market scene. The bulletin intends to provide high-level knowledge and insight. Want to learn more? Our experts will be happy to hear from you.
Highlights from Denmark
New pay limit scheme for foreign workers. From 1 January 2027, certified companies covered by a qualifying collective bargaining agreement will have a new route for recruiting employees from selected third countries. The scheme will allow employees from selected third countries to obtain a residence and work permit for full time-employment with certified companies, provided that, among other things, the position is covered by a qualifying collective bargaining agreement, and the annual salary is at least DKK 322,000 at the 2026 level. The companies must meet several certification requirements, including having at least ten full-time employees in Denmark.
- Mandatory ID cards for major construction projects. On 3 September 2026, the Danish Parliament adopted a new Act introducing mandatory ID cards for individuals working on construction and civil engineering projects with a total capital sum exceeding DKK 100 million. The Act also introduces requirements to register time spent at the construction site and reporting obligations for the project owner. The date on which the Act will enter into force has not yet been determined.
Highlights from Finland
Amendments to prevent discrimination based on pregnancy and family leave – From 1 October 2026, an employer must provide a written statement explaining why a fixed-term employment relationship is expiring or will not be extended if the employee has notified the employer of their pregnancy or childbirth, or has taken, or notified the employer of their intention to take any family leave provided for in Chapter 4 of the Employment Contracts Act. The employer must provide the statement without a separate request and no later than upon expiry of the fixed-term employment relationship. From the same date, the Act on Equality between Women and Men expressly prohibits discrimination in working life on the grounds of parenthood or family responsibilities, and clarifies that the prohibition of discrimination applies to fixed-term employment relationships. Furthermore, liability to pay compensation for violating the prohibition of discrimination is extended to companies that use temporary agency workers.
- Could criminal charges affect termination of employment? – An employee responsible for the sale and rental of machinery had, among other things, accepted as a trade-in, in connection with a machinery transaction, a machine that was not owned by the customer. Consequently, the employee was charged with negligent money laundering, and the employee’s employment was terminated based on both the employee’s conduct and the criminal charge. The charge was subsequently dismissed. The case proceeded to the Supreme Court, which held that the grounds for termination must be assessed separately even if the criminal charges are dismissed. The termination of employment was found to be justified because it was ultimately established that the employee had breached the employer’s sales processes and because the criminal charges might have created the impression that money laundering could be carried out in the employer’s business operations or, at the very least, that the business was not conducted appropriately, thereby causing reputational harm to the employer. The case also emphasizes the importance of documenting key processes and policies, including those relating to ethical business practices, and implementing them effectively.
Highlights from Norway
New Government-commissioned report highlights continued debate on part-time overtime pay – On 15 September 2026, a tripartite working group submitted its report to the Ministry of Labour and Inclusion on the rules governing additional work and overtime pay for part-time employees. The report follows recent EU and Norwegian case law questioning whether the current Norwegian rules are compatible with EEA law and is the first step in the Government's consideration of whether Norway's rules need to be amended. The issue concerns whether part-time employees are entitled to overtime compensation for hours worked beyond their agreed working hours, even where the statutory limits for ordinary working hours have not been exceeded.
In a district court judgment from February 2026, the majority found that a part-time employee was entitled to overtime pay for such hours. The judgment has been appealed, and related proceedings remain pending before the Norwegian courts.
The working group did not reach a consensus on whether the current rules comply with EEA law or whether legislative changes are required. The question therefore remains unresolved, and the Government is now considering the way forward. The debate also raises an important practical question: if the current rules are ultimately found to be incompatible with the Directive, who will bear the financial consequences: employers that have applied the rules as written, or the State for any failure to implement the Directive correctly?
The report can be found (in Norwegian only) HERE.
Government seeks expert input on part-time overtime reform - Following the publication of the recent report on overtime and additional work for part-time employees, the Ministry of Labour and Inclusion has appointed two independent experts, labour law specialist Ingeborg Moen Borgerud and economist Steinar Holden, to help identify possible solutions. The appointment signals that the Government is moving forward with its review of the current rules.
The experts have been asked to consider how Norwegian legislation can address concerns raised under EEA law while also supporting the policy objective of encouraging full-time employment. Their work will include assessing the impact of potential changes on employers, employees and the wider labour market. They will also consider whether related rules affecting part-time employees should be revised. For employers, the review is another indication that changes to the current framework remain a realistic possibility. However, no legislative proposals have been put forward at this stage, and the legal position remains unchanged pending further consideration by the Government and the courts.
Highlights from Sweden
Swedish employers see brighter days ahead — if politics and interest rates play nice —The Confederation of Swedish Enterprise (Svenskt Näringsliv), the umbrella organisation for private employers in Sweden, is looking on the bright side of the Swedish economy. In its latest economic update, the employer organisation forecasts GDP growth of 2.5% in 2026 and 2.7% in 2027, describing the figures as strong from an international perspective. Ahead of the upcoming round of collective bargaining negotiations, the outlook among employers appears notably upbeat. There are, however, a few clouds on the horizon. The employer organisation points to certain proposals emerging in the election campaign, as well as the risk of higher interest rates, as factors that could dampen the economic outlook. For now, though, the message is clear: while politics and monetary policy may create some uncertainty, Swedish employers see more reasons for optimism than concern as the economy heads into 2027.
Price base amount rises for 2027 — and so do several thresholds — The Swedish Government has confirmed the base amounts for 2027. The price base amount will increase by SEK 400 to SEK 59,600, while the elevated price base amount will rise to SEK 60,900. The adjustment may sound technical, but it has practical consequences. The price base amount is used to calculate various social insurance benefits and affects certain sanction fees under employment-related legislation. It also plays an important role in occupational pension schemes, where several thresholds and pension calculations are linked to statutory base amounts. The new figures will apply from 1 January 2027. In other words, not every salary review will be more generous next year, but at least some thresholds will be.
- Staffing companies report strong growth amid improving labour market outlook— New figures from Almega, Sweden's largest employer organisation for the services sector, indicate that Sweden's staffing industry is continuing to expand. Revenue among staffing companies continues to increase, with companies supplying personnel to the manufacturing sector reporting revenue growth of 20% in the second quarter compared to the same period last year. For labour market observers, this is often seen as a promising sign, as staffing companies tend to be among the first to feel the effects of an economic recovery and, importantly, among the first to increase recruiting. "It's a signal that the economy is improving," says Patrick Joyce, Chief Economist at Almega. He expects stronger labour market figures to follow, although with some delay. Historically, it takes a couple of quarters before economic growth translates into noticeable reductions in unemployment. Temporary agency work is sometimes described as the labour market's equivalent of a test drive. If all goes well, today's agency worker may become tomorrow's permanent employee.
