Introduction
Across Organisation for Economic Co-Operation and Development (OECD) countries, there has been a growing interest in policies to extend working life for a number of reasons, such as concern for ageing populations, the pervasive neoliberal agenda, increasing white-collar work, and the taken-for-granted assumption that life expectancy is increasing for everyone (Hofäcker and Naumann Reference Hofäcker and Naumann2015; Krekula and Vickerstaff Reference Krekula, Vickerstaff, Léime, Ogg, Rašticová, Street, Krekula, Bédiová and Madero-Cabib2020; Macnicol Reference Macnicol2015; OECD 2025a; Phillipson Reference Phillipson2019). Indeed, over half of OECD countries have plans for increasing pension age to incentivise working longer (OECD 2025b). Workers across various job types and sectors experience inequalities in ability to extend working life – a problem that is often ignored by policies (McAllister et al Reference McAllister, Bodin, Brønnum-Hansen, Harber-Aschan, Barr, Bentley, Liao, Koitzsch Jensen, Andersen, Chen, Thielen, Mustard, Diderichsen, Whitehead and Burström2020). When governments implement polices to extend working life without investing in social policies that support workers throughout the life course, social inequalities are inflated, particularly for women and workers in low-skilled and/or physically demanding jobs (Hofäcker and Naumann Reference Hofäcker and Naumann2015; Kuitto and Helmdag Reference Kuitto and Helmdag2021; Macnicol Reference Macnicol2015).
Older workers in physically demanding jobs face additional challenges to working to pensionable age (Forden et al Reference Forden, Radpour, Conway, Cook and Ghilarducci2022; Kadefors et al Reference Kadefors, Nilsson, Rylander, Östergren and Albin2018). Physical demands are tough on workers’ bodies, including tasks that require awkward body postures, exerting force (e.g. lifting, carrying, pushing/pulling), repetitive motions, and using vibrating equipment or tools (Andrasfay et al Reference Andrasfay, Raymo, Goldman and Pebley2021). These physically demanding working conditions typically lead to poor health towards the end of working life and are complicated by age-related factors such as declines in physical capacity and longer recovery times (Andersen et al Reference Andersen, Pedersen, Sundstrup, Thorsen and Rugulies2021; Nowrouzi-Kia et al Reference Nowrouzi-Kia, Gohar, Casole, Chidu, Dumond, McDougall and Nowrouzi-Kia2018). Further, workers in physically demanding jobs typically have low education and poor compensation, thus occupying low socioeconomic positions in society – another factor associated with poor health outcomes (Landsbergis et al Reference Landsbergis, Grzywacz and LaMontagne2014). As such, the general trend of working longer is bolstering inequalities in retirement options, where older workers in physically demanding jobs are forced to work longer in less favourable working conditions out of financial necessity (Hofäcker and Naumann Reference Hofäcker and Naumann2015). It is also common for older workers in physically demanding jobs to experience involuntary early exits from the workforce due to poor health, often resulting in financially insecure retirements (Forden et al Reference Forden, Radpour, Conway, Cook and Ghilarducci2022).
Cross-national comparative policy analyses are helpful for understanding context-specific policy features in different nations. This can be used to inform policy development, implementation, and adaptation, as well as establish international standards and best practices for policy (Steiner-Khamsi and Morais de Sa e Silva Reference Steiner-Khamsi and Morais de Sa e Silva2024). For this research, we analysed Canada and Sweden as comparable countries – they are both capitalist, northern democracies with similar gross domestic product (GDP) per worker (Esping-Andersen Reference Esping-Andersen1990; Government of Canada 2025; OECD n.d.). What separates the two countries is their distinct welfare state regimes. Canada’s welfare state regime is widely considered to align most with the liberal regime, which is characterised by its market-oriented policies, means-tested assistance, modest social insurance benefits, emphasis on personal responsibility, and stigma related to welfare state dependence. Contrastingly, Sweden is typically regarded to have a social democratic regime, which emphasises equality, universalism, and de-commodification of social rights, where all citizens benefit from and are dependent on the welfare state (Esping-Andersen Reference Esping-Andersen1990; Powell et al Reference Powell, Yörük and Bargu2020). Despite their central differences in welfare state regimes, some nuances draw similarities between the countries. For example, Canada’s welfare state regime is predominantly liberal, yet the universal components of the old-age security system result in poverty reductions more like social democratic welfare regimes (e.g. Sweden, Denmark) than other liberal regimes (e.g. United Kingdom, United States) (Béland et al Reference Béland, Marchildon and Prince2020). In addition, Sweden’s social democratic regime experienced a neoliberal ideological shift in the 1990s following an economic crisis, resulting in increased welfare privatisation, a characteristic of liberal regimes (Blomqvist and Palme Reference Blomqvist and Palme2020).
In both Canada and Sweden, the proportion of the population aged 65 years and older has steadily increased over time, with the most recent statistics being 19.5% in Canada and 20.8% in Sweden (Statistics Canada 2025a; Statistics Sweden 2026). Population ageing has implications for the labour market, where economic growth is limited by the decreasing proportion of the population that are working (OECD 2025b). In Canada, the looming wave of retirement is expected to exacerbate this decreasing proportion of workers in the Canadian population (Statistics Canada 2022); one in five Canadian workers are aged 55–64 years and 66.7% of workers retire before the standard retirement age of 65 (Statistics Canada 2022, 2023a). On the other hand, Sweden (78.8%) has a much higher labour market participation rate of people aged 55–64 years than Canada (64.8%) and is one of the top-ranking countries for employment at older ages (Employment and Social Development Canada (ESDC) 2022a).
Canada and Sweden have different systems for organising labour policy. Like other liberal welfare states, Canada has a federal system that generally delegates responsibility of labour market policy to provincial governments. However, some labour matters, such as unemployment insurance, are a federal responsibility (Béland et al Reference Béland, Dinan and Waddan2023), and a small proportion of the labour force is federally regulated (6%) (ESDC 2023). In addition, some Canadian workers are covered by collective agreements by trade unions, but this only includes 30.4% of the labour force: 15.5% of the private sector and 76.7% of the public sector (Statistics Canada 2024). In contrast, in Sweden, collective agreements cover a majority of the labour force (88%) (National Mediation Office 2025). Collective agreements may include extensive deviations from national labour policy, resulting in employment sectors having individualised labour policies (Swedish Work Environment Authority (SWEA) 2025a). Sweden’s internationally recognised success in older worker participation is partially attributed to the social protection of their strong trade union tradition (AGE Platform Europe 2023).
Laws and policies to extend working life should support older workers’ health and well-being, as well as address inequalities in ability to work longer. By critically comparing two similar countries with different success in older worker participation, we can better understand how differences in laws and policy contribute to inequalities in extending working life. As such, the purpose of this research was to critically examine and compare laws and policies in Canada and Sweden that affect the retention of older men and women (age 55+) in physically demanding jobs in the labour market. The research question was: How do laws and policies in Canada and Sweden support the retention of older men and women (age 55+) in physically demanding jobs in the labour market?
Methods
Study design
This study was a critical comparative policy analysis of laws and policies encouraging older worker retention in Canada and Sweden. This design supported our investigation of how and if laws and policies consider factors contributing to inequalities in extending working life (e.g. age, gender, socioeconomic status, and job type) and to provide recommendations on how to address these factors.
Research paradigm
A critical paradigm guided this research. Critical paradigms are concerned with unequal distributions of power and motivated by goals of empowerment and social transformation (Brown and Dueñas Reference Brown and Dueñas2020; Ponterotto Reference Ponterotto2005). As critical researchers, we strive for positive social change for workers in physically demanding jobs who experience inequalities in extending working life. A critical paradigm focuses on the social and historical context of older workers’ experiences and how they are mediated by power relations (Ponterotto Reference Ponterotto2005). Within this, we used a post-structuralist approach to understand notions of power. As such, power is seen as relational rather than repressive, and it ‘produces things, it induces pleasure, forms knowledge, [and] produces discourse’ (Foucault Reference Foucault2000, 120). Power is a productive force (Foucault Reference Foucault2000) – we are interested in understanding how policy produces retention outcomes for older workers in physically demanding jobs. Ultimately, a goal of this research is to help stimulate action via providing recommendations for empowering this population of workers when making choices for extending working life.
Data collection
To find publicly available documents, we searched through government agency websites (e.g. ESDC, SWEA), performed a customised Google search with specific search terms (e.g. ‘Older worker retention policies in Canada OR Ontario OR Sweden’), and consulted professionals with expertise in the research area (e.g. work environment experts). Our search of documents occurred from January 2025 to August 2025. To reflect the labour policy organisation contexts of each country, intentional choices were made during data collection. First, in the Canadian federation, provinces are responsible for the design and implementation of key social programs, including labour, and this creates policy variation amongst provinces (Béland et al Reference Béland, Dinan and Waddan2023). To create an adequate comparison point to Sweden, we selected Ontario because it is Canada’s most populous province (Statistics Canada 2025b). In addition, we included federal policies that apply to Ontario workers in federally regulated sectors (e.g. banks, telecommunications, and air transportation) (ESDC 2023). Second, unlike Canada, Sweden uses collective agreements to regulate the work of most workers (National Mediation Office 2025); thus, we made sure to include at least one collective agreement from a male-dominated sector and one from a female-dominated sector. Ultimately, to be included in the study, documents had to be relevant to older worker retention. We considered documents to be relevant if they described laws or policies that influence an individual’s pension and sickness/injury benefits (e.g. pension incentives), work environment (e.g. accommodations based on work ability or age), and/or worker rights (e.g. age discrimination related to work). In addition, eligible laws and policies were required to have been created or updated within the last 25 years to reflect the relatively recent political and social context of worker rights and protections. Using this search strategy, we identified six relevant documents for Canada and seven relevant documents for Sweden (Table 1).
Documents used for analysis
Table 1. Long description
A table with 12 rows and 4 columns. The columns are labeled ‘Jurisdiction’, ‘Institution/agency’, ‘Name of document’, and ‘Relevant topic area’. The rows list specific policies and their details. Row 1: Canada, Government of Canada, Canada Pension Plan, Pension and sickness benefits. Row 2: Canada, Government of Canada, Canada Labour Code, Work environment. Row 3: Ontario, Ministry of Labour, Immigration, Training and Skills Development, Employment Standards Act, Work environment. Row 4: Ontario, Ministry of Labour, Immigration, Training and Skills Development, Occupational Health and Safety Act, Work environment. Row 5: Ontario, Ontario Human Rights Commission, Policy on discrimination against older people because of age, Worker rights. Row 6: Ontario, Workplace Safety and Insurance Board, Workplace Safety and Insurance Act, Pension and sickness benefits. Row 7: Sweden, Swedish Work Environment Authority, Risks in the work environment regulations, Work environment. Row 8: Sweden, Swedish Work Environment Authority, Planning and organising work environment work – basic obligations for you with employer responsibility regulations, Work environment. Row 9: Sweden, Equality Ombudsman, Act concerning the Equality Ombudsman, Discrimination Act and Parental Leave Act, Worker rights. Row 10: Sweden, Ministry of Health and Welfare, Social Insurance Code, Pension and sickness benefits. Row 11: Sweden, Ministry of Labour, Employment Protection Act, Worker rights. Row 12: Sweden, The Swedish Industrial Association and IF Metall, Industry Agreement, Work environment; Pension and sickness benefits. Row 13: Sweden, Care Entrepreneurs Municipal, Collective Agreement, General Terms and Conditions and Salaries, Work environment; Pension and sickness benefits.
The research team included researchers from Canada and Sweden with expertise in social security and employment systems in each country. The lead author, A.D., conducted data gathering in both Canada and Sweden. For Swedish documents, all documents were read and analysed by A.D. in English. When available, we used the official English version of the document provided by the institution. When this was not available, we machine translated the document into English and had the translated version reviewed by C.S., a Swedish-based researcher.
Data analysis
The document analysis was guided by Bacchi’s (Reference Bacchi2009) ‘What is the problem represented to be?’ (WPR) approach. This is a commonly used approach to critical policy analysis which challenges the notion of policy always being a good thing and fixing problems. Instead, the WPR approach critically scrutinises policies to reveal implicit assumptions about what policymakers perceive as the problems requiring change. In other words, the objective is ‘problem’ questioning, not ‘problem’ solving. In addition, this data analysis framework is grounded in poststructuralism, thus being consistent with the poststructuralist conceptualisation of power used for this study. Borrowing from the WPR approach, three questions were used as a guide for data analysis: (1) What is the major ‘problem’ represented to be across laws and policies?; (2) What presuppositions or assumptions underlie this representation of the ‘problem’?; and (3) What is left unproblematic in this problem representation? Where are the silences? Can the problem be thought of differently (Bacchi Reference Bacchi2009)? The data analysis process was iterative and collaborative. It consisted of repeatedly reading the law and policy documents with attention to the guiding questions and then having analytic discussions within the research team about our interpretations. This iterative process allowed us to reflect on initial findings, revisit examination of the documents, and refine our findings.
Findings
We begin our analysis by comparing each jurisdiction with respect to healthy work environment regulation, illness/injury legislation, the universality vs individualisation of laws/policies, and flexible work arrangements. We then close with an analysis of the underlying problem representations to explain the contrasts between Canada and Sweden legislation.
Healthy work environment regulation
Ontario and Sweden both have legislation meant to create a healthy work environment. However, Ontario’s legislation is less comprehensive than Sweden’s. Employment standards in Ontario are set by the Employment Standards Act and the Canada Labour Code. Each of these laws requires employers to follow regulations for working hours, overtime, minimum wages, vacation, paid and unpaid leaves, and more (Government of Canada 2024a; Government of Ontario 2024a). While they help to maintain minimum standards for a healthy work environment, these standards are narrow and do not specify regulations for conditions such as psychosocial factors or ergonomics. The Occupational Health and Safety Act helps to fill this gap by setting regulations for protecting workers from poor ergonomics and violence or harassment in the workplace. Within the Occupational Health and Safety Act, regulations for ergonomics are focused on actions of the employer, including maintaining good condition of equipment, communicating hazards, and providing supervision. Much of the ergonomics regulations are generalised protections, where workers are advised on how to stay safe, and the employer is responsible for inspection and supervision. The Occupational Health and Safety Act also has regulations for defining and responding to workplace violence (physical and sexual) and workplace harassment (psychological and sexual). Further, the Ontario Human Rights Commission’s Policy on Discrimination Against Older People Because of Age prohibits old-age discrimination in the workplace, aiming to foster good working conditions for older workers (Ontario Human Rights Commission 2009).
In contrast, Sweden has regulations that include specific provisions to complement the broader Work Environment Act (SWEA 2014) that are used in addition to minimum standards set by collective agreements. Altogether, these comprehensively regulate the work environment. The Planning and organising work environment work – basic obligations for you with employer responsibility regulations require workplaces to have adequate psychosocial working conditions to maintain a healthy work environment. The contained provisions define, enforce, and create general recommendations for work environment factors including job demands and resources, discrimination, (un)healthy workload, and the social work environment (SWEA 2025b). The Risks in the work environment regulations require employers to design the work environment in a way that is ergonomically safe and provides workers with a healthy job decision latitude. The included provisions outline employer responsibilities for preventing harm to workers’ musculoskeletal system regarding working postures, manual handling, force application, and repetitive movements. In addition, by having provisions for a healthy job decision latitude, workers have the right to be able to control the conduct of their work to improve ergonomic conditions due to variability in individual factors (SWEA 2025c). Like Ontario, Sweden also has legislation that prohibits age discrimination at work. The Discrimination Act prohibits discrimination and harassment due to age in an effort to maintain a healthy work environment for older workers (Equality Ombudsman 2024).
As such, Ontario and Sweden both set and enforce minimum standards for a healthy work environment, have specific regulations for discrimination against older workers, and have additional legislation to regulate psychosocial work conditions and ergonomics. However, compared to Ontario’s regulations, Sweden’s provisions ensure a more comprehensive promotion of a healthy work environment. While Sweden’s provisions comprehensively regulate the psychosocial work environment (SWEA 2025b), Ontario’s regulations are incomplete, only providing requirements related to workplace violence, harassment, and discrimination. Further, Sweden’s provisions for ergonomics support workers’ autonomy by allowing for human variation when interacting with the work environment, whereas the Occupational Health and Safety Act’s regulations for ergonomics are generalised. These differences have implications for older worker retention. Sweden’s more comprehensive approach for ensuring a healthy work environment includes regulation of more working conditions that affect health, thus having a greater contribution to the longevity of older workers’ working lives.
Legislative support when injured or ill
There are contrasting points between Ontarian and Swedish laws and policies affecting sick time and pay. Ontario’s Employment Standards Act has strict time constraints and lacks paid sick leave for short-term sickness. Indeed, employers are only required to provide workers with three unpaid sick days in the calendar year for personal illness, injury, or medical emergency. Employers may choose to offer additional days and/or paid sick leave, but this is voluntary (Government of Ontario 2024a). As such, employers who use the minimum employment standards restrict workers’ ability to avoid work when experiencing personal illness or injury. This limits older workers’ time to recover when in poor health and may force older workers to work while in poor health, exacerbating any health issues. As the three sick days are unpaid, this may act as an incentive to attend work while in poor health to avoid losing income. Federally regulated workers in Ontario have the right to a maximum of 10 fully paid sick days per calendar year via the Canada Labour Code. After working for an employer for 30 days, workers have a minimum of three fully paid sick days, adding another fully paid sick day per month until the maximum of 10 sick days is reached. Unused sick days are carried forward to the next year, to a maximum sum of 10 sick days (Government of Canada 2024a). This is an example where federally regulated work in Ontario (Canada Labour Code) has more generous minimum standards than provincially regulated work (Employment Standards Act). This increased recovery time provides older workers with more support when experiencing illness or injury, and the fully paid sick leave removes the incentive to continue working when in poor health. Clearly, inequities exist in support for older worker retention based on whether the type of work is provincially or federally regulated. This is problematic as physically demanding jobs are typically provincially regulated, meaning older workers in physically demanding jobs have more challenging working conditions and less generous sick leave. Alternatively, federally regulated job types, which often have less onerous work conditions, have more generous sick leave.
In comparison to Ontario, Sweden has looser limits on the number of sick days, and provides paid sick leave to all workers. According to the Swedish Social Insurance Code, when workers experience a short-term illness or injury, there is one unpaid waiting day, then the employer is responsible for providing 80% of their pay for the first two weeks of sick leave. After this initial two-week period, the ill or injured worker can apply for sickness benefits from the Swedish Social Insurance Agency (The Swedish Parliament 2025). In contrast to Ontario, Sweden provides more time to ill and injured employees than Ontario and provides equal assistance for paid sick leave across all job types, demonstrating increased support for prolonging the working lives of older workers. However, while the rate at which Sweden pays ill and/or injured workers is higher than provincially regulated workers in Ontario (for non-work-related illnesses and injuries) it is lower than Canada’s federally regulated workers. Further, because Sweden provides 80% of regular pay when sick, older workers may be incentivised to return to work (RTW) before they have recovered from illness or injury due to the 20% pay deduction. This pressure for early RTW could negatively affect older workers’ health.
Ontario and Sweden have different systems for long-term sickness compensation that result in contrasting support for older worker retention. According to the Workplace Safety and Insurance Act in Ontario, workers’ compensation is provided to workers with work-related illness or injury at 85% of their full pay. This compensation excludes workers with personal illness or injury, or workers who cannot prove their illness or injury was work-related (Government of Ontario 2024b), and thus, those who are not eligible must seek out other means for generating income. In contrast, Sweden’s sickness benefits (Social Insurance Act) provide ill or injured workers with 80% of their full pay and are universally available to all socially insured workers with personal or work-related illness or injury (The Swedish Parliament 2025). When comparing the two jurisdictions, Ontario’s workers’ compensation provides a slightly higher proportion of the ill/injured worker’s lost income, however, it is available only to those injured by work, thus, excluding the larger portion of claims for non-work-related illnesses/injuries. Sweden’s sickness benefits, while paying a slightly lower proportion, is available to nearly all ill or injured workers in Sweden. Older workers with poor health who require longer recovery time may be forced to continue working while ill or injured under Ontario’s policies, which could exacerbate their health issues. Alternatively, the universal nature of Sweden’s sickness benefits makes it widely available to ill or injured older workers, demonstrating more support for long-term recovery before returning to work. Again, it should be noted that since both Ontario and Sweden pay workers at a reduced proportion of their lost income, workers may be incentivised to RTW before they are ready. In addition, the Workplace Safety and Insurance Act emphasises the importance of early RTW in Ontario (Government of Ontario 2024b). Such measures may prioritise the speed of the RTW process over a proper recovery. RTW, as described in the Swedish Social Insurance Code, does not include this same language of indicating that workers must RTW quickly, suggesting there is less pressure for ill or injured workers to RTW early. This demonstrates comparatively greater support in Sweden for providing adequate recovery time for older workers with illness or injury.
Universally applied vs individualised laws and policies
Ontario laws and policies attempt to treat all workers the same, despite differences in work ability due to job type, age, and gender. In Ontario, older workers exist across a broad range of job sectors and work environments, yet laws and policies follow a one-size-fits-all approach. Most workers in Ontario have the same employment standards set by the Employment Standards Act except for federal employees having employment standards set by the Canada Labour Code (Government of Canada 2024a; Government of Ontario 2024a). In addition, Canada Pension Plan (CPP), Canada’s public old-age pension, has the same rules and incentives for all contributors. All workers are required to contribute to CPP, and CPP sets a minimum retirement age of 60 to start their CPP pension, and a standard retirement age of 65. In addition, CPP uses financial incentives to penalise workers for retiring earlier than age 65, and rewards workers for working up to age 70 (Government of Canada 2024b). Applying the same laws and policies to a diverse group of workers assumes an equal ability to have a fully extended working life. There is a clear gap in legislation – there are no laws or policies addressing the difference in work ability of older workers in different types of work environments. This uniform approach disadvantages older workers with physically demanding work environments as such environments can lead to rapidly declining health status and reduced work capacity. Older workers in physically demanding work environments should not be expected to have the same retirement timing ability as those in less onerous work environments. Similarly, Sweden applies the same logic of not considering job types in the Social Insurance Code for their public pension, the income-based retirement pension. All workers have the same minimum age of 63 to start collecting a pension, with the pension amount increasing each year one chooses to continue working (The Swedish Parliament 2025). This public pension scheme is like Canada’s in terms of having the same rules and incentives applied to all workers. However, there is one key difference: Sweden’s income-based pension does not set a single standard retirement age (The Swedish Parliament 2025). Unlike Ontario, Sweden allows mandatory retirement to occur, creating a smaller expected retirement age range (Equality Ombudsman 2024). At the higher end of the expected retirement range, as outlined by the Swedish Employment Protection Act, older workers are protected to continue working until age 69 (Ministry of Employment 2022). Overall, both Canada’s and Sweden’s retirement timing incentives lack sensitivity to variation in job types.
Distinguishable from Ontario, each job sector in Sweden has its own work environment requirements that are negotiated by trade unions with collective agreements. When comparing two different Swedish collective agreements, using cases from the industrial sector (The Swedish Industrial Association and IF Metall’s Industry Agreement) and the elderly care sector (Care Entrepreneurs Municipal’s Collective Agreement, General Terms and Conditions and Salaries), requirements differ for working hours, shiftwork, overtime, on-call hours, flexible work arrangements, and leaves of absences (Care Entrepreneurs Municipal 2023; The Swedish Industrial Association and IF Metall 2023). These collective agreements recognise how work environments differ across job sectors, and they allow for the ability to amend work environment requirements depending on the job sector. While this avoids the inequity of the same standards applied to all workers in a jurisdiction, inequities in support for older workers exist between collective agreements. When comparing the requirements outlined in these collective agreements, the elderly care agreement imposed more barriers to retention than the industrial work agreement (Care Entrepreneurs Municipal 2023; The Swedish Industrial Association and IF Metall 2023). Elderly care is a female-dominated job sector with physically demanding and intense working conditions, including required overtime, mandatory standby, unpaid leaves of absences, little flexible work options, and mandatory retirement by age 69 (Care Entrepreneurs Municipal 2023). These difficult working conditions impose challenges for sustaining good health for a full working life. In contrast, the agreement for the male-dominated industrial work sector offers more supportive policies for encouraging retention to compensate for the harsh work environment (The Swedish Industrial Association and IF Metall 2023). For example, the collective agreement requires overtime, some shiftwork, and describes demanding working conditions such as working underground or continuous two-shift work. However, hours are reduced for demanding tasks, working night shift requires passing a risk assessment, and older workers are offered phased retirement options starting at age 60 (The Swedish Industrial Association and IF Metall 2023). Thus, while this job sector also has a demanding work environment, there is more initiative for mitigating risks and sustaining health to prolong working life and increase productivity. With different provisions in collective agreements for physically demanding jobs in sectors dominated by men and women, this suggests gendered differences in support for older worker retention in Sweden.
Flexible work arrangements
Laws and policies affecting Ontarians assume older workers can sustain full-time work until they fully retire. Both the Employment Standards Act and the Canada Labour Code set employment standards that allow workplaces to require working full-time (and over-time in some cases) across the working life (Government of Canada 2024a; Government of Ontario 2024a). Thus, while CPP can start at age 60 and allows for part-time work, employment standards (Employment Standards Act; Canada Labour Code) do not provide workers with the right to flexible work arrangements (Government of Canada 2024a; Government of Canada 2024b; Government of Ontario 2024a). This all-or-nothing approach to work may oblige workers to choose between working full-time or exiting the workforce altogether. Not all older workers have the capacity to work full-time but many may continue to work if they had part-time options. Ontario’s Employment Standard Act completely lacks the right to flexible work options for provincially regulated workers, such as phased retirement (Government of Ontario 2024a). The Canada Labour Code, which applies only to federally regulated industries and workplaces (Government of Canada 2024a), does consider flexible work arrangements by providing workers of all ages with the right to request a change in work location, scheduling of work hours, and number of work hours. While this code for federal workers is one step closer to supporting older worker retention, there are several problematic factors. Importantly, the right to request flexible work arrangements is not the same as the right to be granted flexible work arrangements. Employers can deny this request, for instance, if they believe it would be a burden or negatively affect the worker’s performance. Ultimately, a phased retirement policy would help to prolong the working life of some older workers who do not have the capacity to work full-time.
Collective agreements in Sweden determine workers’ rights to flexible work arrangements. This means that each job sector has different rights to flexible work. Within the elderly care collective agreement from Care Entrepreneurs Municipal, the regular number of work hours and scheduling of work hours is outlined, but the agreement also notes how there may be alternative arrangements. If the employer and worker have a separate arrangement, the worker’s number of hours and scheduling of work hours can vary from the regular hours in the general collective agreement. As such, the worker may negotiate flexible work arrangements (Care Entrepreneurs Municipal 2023). In the industrial collective agreement from The Swedish Industrial Association and IF Metall, workers may work part-time, and workers may apply for partial pensions starting at age 60 (The Swedish Industrial Association and IF Metall 2023). Both collective agreements allow for part-time work, if agreed upon by the employer and worker. However, the industrial agreement also provides phased retirement options for workers, adding support for older worker retention. Overall, in Sweden, collective agreements provide more opportunities for flexible work arrangements for more workers when compared to Canada, but similarly, the problem of needing the employers’ permission persists. There are also inequities between collective agreements of different job sectors. The above collective agreements are from gendered job sectors, and in this example, the female-dominated job sector of elderly care has less support for flexible work arrangements than in the male-dominated industrial sector. This may exacerbate gender differences in older worker retention.
Problem representations
The different approaches to encouraging older worker retention between Ontario and Sweden can be explained by the underlying problem representations. Ontario laws and policies effectively promote older worker retention by reducing dependence on the social security system, asserting the underlying problem representation of social security dependency. This is demonstrated by, for example, when the Workplace Safety and Insurance Act emphasises early RTW to reduce time spent depending on workers’ compensation benefits (Government of Ontario 2024b); when CPP uses rewards and punishments to encourage workforce participation and discourage social security dependence (Government of Canada 2024b); or when the Ontario Human Rights Commission prohibits age discrimination in the workplace to improve working conditions which effectively delays workers drawing on the old age pension system (Ontario Human Rights Commission 2009). Swedish laws and policies appear to foster productivity of the older workforce to support retention. Sweden takes a strengths-based approach to the problem representation of a lack of productivity, where laws and policies target ways to optimise the output of older workers.
The avoidance of social security dependency in Ontario is a problematic approach to improving retention of older workers. This is because it neglects to acknowledge or address the reasons for retention challenges among older workers. Instead of being supportive, it is a more forceful approach to encouraging older worker retention. Reflecting on the comparisons between Ontario and Sweden, the avoidance of social security dependency can explain many of Ontario’s differences from Sweden’s legislation. First, when comparing regulations affecting healthy work environments, Ontario has a less comprehensive approach, which could be due to the alternative focus on avoidance of social security dependency rather than health promotion. Second, Ontario’s meagre support for ill or injured workers can also be understood through this problem representation. The limited number of sicks days each year, the unpaid sick leave for provincially regulated workers, the exclusive eligibility of workers compensation, and the emphasis on early RTW all promote workers to continue working and not be dependent on social security. Third, by using universal laws and policies, Ontario neglects to recognise differences in work ability and requires older workers with less work ability to remain in the workforce. And lastly, employers are not required to provide flexible work arrangements for retirement, such as a phased retirement. This would help to prolong older workers’ working lives but would require workers having a partial dependence on social security and is thus avoided in Ontario laws and policies.
Sweden’s laws and policies presume that a sustainable, productive workforce depends on having healthy workers. This can explain why Sweden has a more comprehensive approach to regulating the health effects of the work environment. Further, this is exemplified by the more generous sick leave time, right to paid sick leave, and the more inclusive long-term sickness benefits. Another underlying assumption that appears to be present is that a productive workforce prioritises workers with a high work capacity. With public pension age beginning at age 63 and mandatory retirement practices being allowed at age 69, the retirement window is short and suggests older workers become less productive at this time and should exit the workforce to let younger workers with higher work capacities in. In addition, the different collective agreements for different job sectors appear to create requirements for work conditions that are most efficient for each job sector. Lastly, flexible work arrangements can help workers to be more efficient when at work, especially when having a lower work capacity; this could justify why Sweden has flexible work arrangements more availably than Ontario. Overall, this problem representation demonstrates legislative concern for having an efficient workforce. Swedish legislation meant to improve the work environment and nurture poor health are supportive ways to encourage older worker retention. Alternatively, legislation meant to prioritise a high work capacity may create some challenges to older worker retention. The small retirement window may shape perceptions of older workers becoming less valuable, and the allowance of mandatory retirement removes older workers’ ability to work longer if desired.
Discussion
Our results demonstrate how Canada and Sweden have different legal and policy approaches to encouraging longer working lives. These divergent approaches contrast in their support for the health and well-being of older workers in physically demanding jobs. Canada’s approach, which is focused on reducing social security dependence, directs older workers in physically demanding jobs to continue working in conditions that are difficult without providing much support for their health and well-being. This finding aligns with the tendency of liberal regime countries to rely on market solutions and workers’ self-reliance, using social security as a last-ditch resource (Esping-Andersen Reference Esping-Andersen1990). Sweden’s approach, on the other hand, aims to optimise the output of workers by using laws and policies to promote worker health and well-being, thus improving human capital and productivity. This finding is consistent with a social democratic welfare state, where because all citizens benefit from and are dependent on the welfare state, Sweden is incentivised to minimise social problems by maximising employment (Esping-Andersen Reference Esping-Andersen1990). Overall, Sweden’s use of social investment policies throughout the life course to promote worker health and well-being is a more effective way to support longer working lives and produces fewer inequalities (Kuitto and Helmdag Reference Kuitto and Helmdag2021; McAllister et al Reference McAllister, Bodin, Brønnum-Hansen, Harber-Aschan, Barr, Bentley, Liao, Koitzsch Jensen, Andersen, Chen, Thielen, Mustard, Diderichsen, Whitehead and Burström2020).
It is evident that both countries’ welfare state regimes are constrained by institutional structures and past policy trajectories, also known as path dependency (Pierson Reference Pierson2000). As such, we make policy recommendations for improving support for older workers in physically demanding jobs that consider the historical and political contexts of each country. We recognise that despite path dependencies, systems are dynamic and continue to change over time. For example, in Canada, the coronavirus pandemic helped to permanently increase the allowed number of paid sick days and extended the length of unpaid medical leave for federally regulated workers (ESDC 2022b). In Sweden, since the 1990s, neoliberal ideas have seeped into the welfare state and weakened universalism, including stricter eligibility of sickness insurance, increased privatisation of sickness insurance and pensions, and an overall less generous social insurance system to incentivise longer working lives (Altermark and Plesner Reference Altermark and Plesner2025; Blomqvist and Palme Reference Blomqvist and Palme2020). Ultimately, we hope to provide realistic recommendations for policy transformation that could improve support for health and well-being.
Social investment policies can support workers’ health and well-being throughout the life course (OECD 2025b). First, Canada could more proactively invest in healthy work environments through laws and policies, such as by making comprehensive psychosocial work environment regulations a legal requirement rather than a voluntary guideline (Mental Health Commission of Canada 2022). Having a healthy psychosocial work environment (e.g., social support, healthy job decision latitude) could enable older workers to modify their work demands and workload as they age to protect their health and support sustained employment (Stengård et al Reference Stengård, Leineweber and Wang2023; Vinstrup et al Reference Vinstrup, Meng, Sundstrup and Andersen2021). Second, support for worker health and well-being can be improved by increasing the minimum number of allowed sick days and/or by making the minimum number of sick days paid (Statistics Canada 2023a). Further, a better way to improve support for older workers’ sick leave is to require increased sick time for workers once they reach a certain age, such as age 55. Third, overall employment standards could be more equal (but ideally, equitable) between provincially and federally regulated workers, such as by harmonising sick leave time and pay, or flexible work arrangement opportunities. Sweden already implements many social investment policies that contribute to their high older worker participation (AGE Platform Europe 2023; Kuitto and Helmdag Reference Kuitto and Helmdag2021). Despite this, there is still a gender gap in older worker participation with older women having a lower employment rate (AGE Platform Europe 2023). Our findings displayed differences in working conditions between two gendered job sectors, with the female-dominated sector having worse conditions than the male-dominated sector. This finding adds to previous evidence which pointed to the gendered segregation of the labour market to explain gender disparities in employment rate at older ages (Ministry of Finance 2021). Sweden already audits gender disparities in the workplace via economic gender equality reports (Ministry of Finance 2021) – we suggest more attention is given to examining how working conditions in collective agreements vary between gendered sectors of work, and how this may contribute to gendered gaps in older worker participation.
Flexible work arrangements are an effective way to support older workers to continue working (OECD 2025a), yet our findings show there are barriers to doing so, especially in Canada. While it is possible for older workers in Canada to afford to work part-time by concurrently collecting a retirement pension, this option is limited by the need for employers to agree to part-time or reduced hours. Many physically demanding job sectors, such as construction and manufacturing, have very low rates of part-time work (ESDC 2026a, 2026b), which can make it difficult to get employers’ agreement to flexible work hours. To support extending working life, Canada could move away from the all-or-nothing approach to work and retirement. Indeed, over half of older workers in Canada would be willing to retire at an older age if they could work part-time (Statistics Canada 2023b). To create opportunities for gradual retirement transitions for all workers, employers could be mandated to provide the option of flexible work arrangements to workers once they reach a certain age. Contrastingly, in Sweden, approximately a third of older workers (aged 50–69 years) combine work and pensions in the first 6 months after starting their pension, being among the European countries with the highest rates of workers continuing to work after retirement (OECD 2025a). To further this, Sweden could provide more equal opportunities for flexible work arrangements for all workers – our findings demonstrated differences in flexible work options between gendered sectors, with the female-dominated sector being disadvantaged. This result has also been found in other literature (Magnusson Reference Magnusson2021).
Workers should not be restricted from working longer if they desire to continue working. Older workers may wish to continue working for a variety of reasons, such as financial need, social connection, health benefits, joy of work, and feeling useful and active (Heisler and Bandow Reference Heisler and Bandow2018). Sweden’s policy to protect employment only until age 69 limits workers’ choices for extending working life. While older workers in physically demanding jobs typically exit the workforce earlier (Kadefors et al Reference Kadefors, Nilsson, Rylander, Östergren and Albin2018), some workers may desire extending working life beyond 69. To support workers’ ability to make their own choices about the length of their working life, we recommend that countries remove any form of mandatory retirement policies and practices, including laws that oblige or allow the dismissal of workers at a certain age, and practices that allow worsening of working conditions at a certain age (OECD 2025a).
Our findings show how Canada’s and Sweden’s universal pension age and incentives perpetuate inequalities for workers in physically demanding jobs, as they are expected to work for as long as workers with less demanding working conditions. Scholars have suggested pension reform may be necessary to address inequalities in ability to extend working life, such as by having differentiated retirement pathways for disadvantaged workers (e.g. workers in physically demanding jobs) (Andersen et al Reference Andersen, Pedersen, Sundstrup, Thorsen and Rugulies2021; Berkman et al Reference Berkman, Boersch-Supan and Avendano2015; Hofäcker and Naumann Reference Hofäcker and Naumann2015; Phillipson Reference Phillipson2019). While pension incentives are effective in accomplishing older worker retention for most workers, they are less effective for supporting the retention of workers with low health-related capacities, regardless of their willingness to continue working (Kuitto and Helmdag Reference Kuitto and Helmdag2021). Indeed, some OECD countries have recently introduced pension reform to address these inequalities, such as Czechia allowing workers in arduous and hazardous working conditions to retire 15–30 months earlier without penalty (OECD 2025a). We recommend that Canada and Sweden also consider alternate retirement pathways for older workers in physically demanding jobs, such as allowing for earlier collection of pension benefits without penalties or having a separate pension age altogether (Berkman et al Reference Berkman, Boersch-Supan and Avendano2015; OECD 2025a).
Limitations
The study did not examine how effectively each law and policy is implemented as part of the analysis. The focus of this study was to critically compare laws and policies to inform policy recommendations, thus, analysing the effectiveness of implementation for each law and policy was beyond the scope of this study. Future research could investigate how effectively laws and policies affecting the retention of older workers in physically demanding jobs are implemented in Canada, Sweden, and similar countries.
A second limitation was that all documents were analysed in English only. Because of this, it is possible that for Swedish-to-English translated documents, some of the original meaning could have been altered or lost. We mitigated this by using professionally translated documents provided by the institutions when available, and by having C.S., who has both English and Swedish language proficiency, review machine translated documents for accuracy prior to analysis.
Conclusion
This paper critically compared laws and policies that encourage older worker retention in Canada and Sweden. Our findings demonstrate how Canada’s approach (reducing social security dependence) to encouraging older worker retention is comparatively less supportive and more forceful than that of Sweden (optimising the output of workers via the promotion of worker health and well-being). To improve support for older workers in physically demanding jobs, we recommend that Canada extend social investment policies to support worker health and well-being across the life course (e.g., increase number of allowed sick days, provide paid sick leave, more equitable employment standards for provincially regulated workers); Sweden could work towards equality in working conditions between gendered job sectors and could better support workers’ autonomy of retirement timing via the removal of mandatory retirement practices. We also recommend that both countries increase opportunities for flexible work arrangements and consider pension reform (e.g., alternate retirement pathways for older workers in physically demanding jobs). Ultimately, the interest in policies to extend working life is expected to persist across OECD countries. We need to consider what is fair to expect of workers. How can we support (not force) workers in prolonging working life? What can be done to reduce harm for workers who are expected to work longer when it is difficult to do so? As well, should all workers be expected to prolong their working life? Future research should aim to answer these questions.
Funding statement
This project was supported by the Social Sciences and Humanities Research Council of Canada through the Canada Graduate Scholarships – Michael Smith Foreign Study Supplements program.
Competing interests
The authors declare none.
Abbey Davis (BKin) is a Ph.D. candidate in the School of Public Health Sciences at the University of Waterloo. Her research investigates inequities concerning older workers’ experiences with policies and practices for extending working life. More generally, her research interests are related to work and health.
Ellen MacEachen is a Professor and Director of the School of Public Health Sciences at the University of Waterloo. Her research examines vulnerable workers, precarious employment, and the changing nature of work as related to worker health.
Christian Ståhl is a Professor of Sociology at Linköping University, Sweden. He leads a research group, Greening of Working Life, focusing on the green transformation of society with emphasis on work. He conducts research on varying dimensions relating to work, welfare, and social policy.
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