I never heard this before. I thought unions were always involved, regardless of kollektivavtal or not. Would like to hear from a Swedish expert on this.
Source (Swedish law): https://lagen.nu/1976:580#P13S2
Google translated:
> If the employer is not bound by any collective agreement at all, the employer is obliged to negotiate in accordance with § 11 with all relevant employee organizations in matters relating to dismissal due to a lack of work [...]
Also, they have to give six months notice to the unemployment agency if they plan to fire more than 100 people.