MBL and AI rollout: what Swedish employers must do
5 min readPublished 2026-11-11Last reviewed 2026-11-11
Short answer
Under the Swedish Co-determination Act (MBL), employers must negotiate with the union before deciding on major changes to operations or working conditions, and keep unions informed. Introducing AI that changes tasks, monitoring or roles usually triggers this duty. Plan the consultation into the AI roadmap early, so it shapes the design instead of delaying the launch.
- Section 11: negotiate before major changes to operations or working conditions
- Section 19: keep unions continuously informed about how the business develops
- Section 12 and 13: duties also apply when changes affect specific employees
Does MBL apply when you introduce AI? Usually yes, when the AI changes how people work.
How to plan it into the AI roadmap
- Map which roles and tasks each AI use case changes
- Share the plan with union representatives before the decision
- Document what was discussed and agreed
- Combine with EU AI Act duties to inform worker representatives
Empley's Readiness and Risk Control package builds the consultation step into the AI roadmap from week one.
Evidence
- Our assessment
Requirements summarised from public legal sources; not legal advice.
Common questions
- Is a pilot also covered by MBL?
- It can be, if the pilot changes working conditions for a group of employees. Assess each case.
- Who leads the consultation?
- The employer, usually HR together with the business owner of the change.