Sweden Online Gambling Regulation, Licensing & Tax Regime

The dominant development for Sweden this period is the Administrative Court of Appeal's confirmation of combined administrative penalty fees of SEK 44 million against the two Swedish-licensed bet365 entities, Hillside (Sports) ENC and Hillside (Gaming) ENC, for duty-of-care and deposit-limit breaches. The Kammarrätten i Jönköping rejected both entities' appeals, upholding Spelinspektionen's warnings and fees arising from a no-limit deposit configuration offered instead of a mandatory numerical cap. Both entities retained their licences following corrective action. This confirms active judicial backing for Spelinspektionen's enforcement approach toward player-protection configuration under Spellagen, and establishes an appellate-level standard against which deposit-limit tooling will now be read. No other category recorded a material change this period, and market structure, product-class status, and the licensing framework stand as previously described.

Licence application fees are due at the time of application and amount to the following (all in SEK): - Licence for commercial online gambling 230,000 - Licence for betting 230,000 - Joint application for 1. and 2. 230,000 - Amendment of key persons or owners 1,000 for a natural person and 3,000 for a legal entity License holders are required to pay annual supervisory fees, which are due in advance for each 12-months. For licenses concerning commercial online gambling or betting, a fixed supervisory fee of SEK 240,000 is payable per licence. The fee is charged on an annual basis and covers a full 12-month period. Whether this fee can be refunded if a licence is surrendered or expires before the end of the 12-month period, is currently subject to an appeal in the Administrative Court. If the licence applicant is a startup without financial history or has negative equity, a capital guarantee from a parent company, or another affiliated entity, may be required by the SGA. This is mainly to cover potential tax and player liabilities. The SGA expects licence holders to have stable finances and good capital strength. The SGA does not approve of negative equity and if a licence applicant has negative equity, it can expect to have to provide additional assurances (for example by way of a parent guarantee) and will receive a licence period for three years, rather than the normal five years. Bingo: Land-based bingo licences may be held by not-for-profit organisations only. Application fee is SEK 6,000 for one legal entity and an additional SEK 500 for each additional legal entity. Casino: Land based commercial casino licences can be applied for in restaurants, amusement parks and hotels. The fee is SEK 25,000 per location for a natural person and 80,000 for a legal entity. Lottery licences may be held by the state monopoly or not-for profit organisations only. Application fee depends on the balance sheet total and ranges between SEK 6,000 and SEK 175,000. Software/B2B: The application fee for a B2B permit is SEK 120,000. There is also an annual supervisory fee of SEK 16,500. Gambling tax shall be paid to the Tax Agency by any licensed B2C gambling operator. The rate is 22% of the gross gambling revenue (stakes accepted - winnings paid out). Reporting is monthly and deficit cannot be carried over from one period to the next. Sales taxes. There are no sales taxes applicable (unless the licence holder is established in Sweden). Corporate taxes. There are no corporate taxes applicable (unless the licence holder is established in Sweden). Skill games: No gambling specific taxes are levied on operators providing pure skill games. Skill games can be offered without a licence, but winnings received by Swedish customers will be taxed as income and the social charges (at approximately 30%) should be paid by the operator.

Main payment method used is direct debit and cards. Some online licence holders offer so called Pay N Play which means that players use bank login both to verify their identity and deposit. Due to the supposed AML risk connected with gambling, banks have generally been unwilling to service the industry but more and more online license holders have been able to establish a collaboration with the smaller banks, which means they are able to offer the mobile payment method Swish, enabling players to deposit and withdraw with their mobile phones and phone numbers. Effective 1 May 2026, the Gambling Act's credit-ban provision prohibits funding gambling deposits from credit cards and other credit deferred payment options. It also requires operators to have procedures in place to prevent gambling for credit where overdrafts, personal loans, bank loans, and third-party loans have been discovered. Certain information requirements towards customers have also been introduced. Spelinspektionen has powers to suspend, fine, or in serious cases revoke licences for breaches of the credit ban, materially raising the enforcement stakes of funding-source screening. Operators must now screen deposit sources to exclude prohibited credit-linked funding at the point of transaction. In cases where indirect funding (through loans or other credits) is discovered, operators must have a process in place to prevent stakes from credit to be made.

Regulatory action and supervision of marketing of gambling services is divided between the SGA and the Swedish Consumer Agency. The two regulators cooperate closely but have also agreed to divide the regulatory tasks between them. Provisions regarding marketing of gambling services are mainly found in Chapter 15 of the Gambling Act. General rules applicable on all marketing are found in the Marketing Act. These acts apply equally to the online and offline market unless a provision explicitly states differently. The Marketing Act is based on Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market. Annex 1 of this directive is a blacklist which specifies commercial practices which are in all circumstances considered unfair. The annex has the force of law in Sweden. First of all, it should be established that it is a criminal offence to advertise or otherwise market gambling services offered without the required licence. Secondly, there are several restrictions related to marketing of lawful and licenced gambling. The general starting point is that marketing of gambling services shall employ a degree of moderation. It is not yet defined exactly what is included in the definition of moderate marketing. Guidance can mainly be found in the preparatory works and in two reports on the review of the gambling market issued by the Consumer Agency in June 2019, which was followed up through a new report issued in May 2020. Case law will also develop over time and cases are already being assessed by the Patent and Market Court (and the Court of Appeal). Furthermore, marketing of gambling may not be aimed specifically at people under 18 years of age, nor directly at players who have opted for self-exclusion from gambling. On 1 January 2023, the possibility for the authorities to issue a market disturbance fee against those operators who do send out such marketing was introduced. If a player has closed his/her player account with a licence holder, marketing may only be aimed directly to the player if the player actively approved this in conjunction with the account closure. Under Chapter 15, Section 3 of the Gambling Act, commercial communication concerning gambling shall include clear information regarding the minimum age to gamble. Licence holders shall furthermore at venues where gambling takes place, and in the context of commercial communications concerning gambling – with the exception of such communications via radio – ensure that contact information is also stated for an organisation that provides information on, and support for, problem gambling. Licence holders who conclude sponsorship agreements, shall ensure that logos and the names of gambling products or gambling services are not to found on products that are intended to be used or worn by persons under 18 years of age. Under the Marketing Act, marketing shall also at all times be consistent with good marketing practice. Good marketing practice is defined as generally accepted business practices or other established norms aimed at protecting consumers and traders in the marketing of products. For Swedish holders of gambling licences, one example of good marketing practices are the Marketing Guidelines which have been issued by the two trade associations for gambling, BOS and SPER (these can be accessed via link - Marketing Guidelines of the Swedish Gaming Industry. The Marketing Act also includes provisions related to misleading marketing, how to manage limitations in the means of communications, invitations to purchase, misleading copies, comparative advertising and unsolicited marketing (also known as direct marketing). Affiliates are not directly regulated through the Gambling Act. However, under the Swedish Marketing Act, both affiliates and the operator whose products are being marketed may be made fully liable for any violations of marketing provisions. That marketing may not be aimed directly at players who have opted to self-exclude from gambling presents a practical problem for affiliates since they are not able to access database of the National Self-Exclusion Registry. The Swedish Consumer Agency has issued general guidance on marketing in Sweden (KOVFS 2025:2), together with accompanying comments. The guidance is based on legislation, preparatory works, and court practice, and will enter into force on 1 September 2025. Although not legally binding, it is expected to function as an important benchmark in practice.

Swedish Gambling Authority (SGA) supervises compliance with both the Gambling Act and the Money Laundering Act. The Swedish Consumer Agency supervises the marketing of gambling services. Monitoring methods As part of its supervision, the SGA may e.g., visit premises of land-based operations or the location of the gambling system (servers). If equipment is placed abroad, the SGA may ask for remote access or request assistance from other regulators with which it has entered into MOUs. However, in general and thus far, supervisory cases have been based on incompliances discovered by the SGA or reported to the SGA by third parties. In a majority of cases, supervision is performed through written correspondence between the SGA and the relevant operator. Following initial questions, the SGA may follow up and request extracts and reports from the gambling system, request information in relation to specific players and account history. The SGA has also ad hoc sent out questions to operators selected randomly to inquire on a specific question, e.g., how the registration process functions, how customer service is set up and processes around employees' gambling. The SGA has discretionary power when it comes to both methods and frequency of supervisory matters. On 1 January 2023, stricter rules and sanctions were implemented to prevent those who support and / or promote illegal gambling from doing so. As a result of this regulation, the SGA is anticipated to oversee that B2B permit holders refrain from supplying gambling software to operators targeting the Swedish market without the necessary license(s).There was also an extended ban on the promotion of unlicensed gambling implemented. The SGA can enforce the provisions of the Gambling Act directly through decisions against licence and permit holders and such decisions may be coupled with a of between SEK 5,000 and 10% of the operator's/supplier’s gross gaming revenue (GGR) in the previous year. The SGA also has the power to revoke gambling licences and permits in severe cases. The SGA is also empowered to take actions against B2C licence holders and legal representatives of licence holders under Act (2017:630) on measures against Money Laundering and Terrorist Financing. The SGA may intervene by issuing an injunction to rectify the matter and may also issue a financial penalty in cases which are not minor. Decisions from the SGA can be appealed to the administrative court and thereafter in some instances to the higher administrative court and eventually the Supreme Administrative Court. Unless the SGA has included that its decision shall be applicable in the interim, the decision is not enforceable until the decision has entered into legal force, i.e., there is a final decision or judgment in place which cannot be appealed. The Consumer Agency can enforce the marketing rules, mainly through the initiation of a legal case at the Patent and Market Court. The lawsuit may include a prohibitory injunction, which can be coupled with fines (can also be ordered in the interim). When it comes to violations of the Marketing Act, the Consumer Agency may also request payment of a market disturbance fine. Injunctions in some matters of lesser importance do not require court involvement, and the Consumer Ombudsman has direct authority to take action. The main approach by the Consumer Agency so far has been a dialogue with the industry and the goal for the Consumer Agency is that operators shall voluntarily correct incompliances. It should be noted that violations of the marketing provisions can also be taken into account by the Gambling Authority, for example when assessing if an operator is suitable to hold a licence or when considering if a licence is going to be renewed. Criminal offences Criminal offences that may be committed and which are directly linked to gambling activities include the following: - A party that intentionally or through gross negligence provides unauthorised gambling or gambling without a licence commits the offence of operating unlawful gambling. Possible sanctions range from a fine up to imprisonment for 6 years in intentional and severe cases. - Those who intentionally or through gross negligence promote participation in such gambling as referred to in (i) commit the offence of promotion of unlawful gambling. It should be noted that this offence will e.g. include marketing activities. Possible sanctions range from a fine up to imprisonment for 6 years in intentional and severe cases. - Those who take inappropriate actions to manipulate the outcome of a game that is subject to licence requirements under the Gambling Act may be convicted for cheating in gambling. It should be noted that this offence will e.g. include the manipulation of a sports event (match-fixing). Possible sanction is imprisonment up to six years in severe cases. - In some instances, attempts or preparations of the offences may also be punishable under the Swedish Criminal Code. There are also criminal provisions included in other legislation which concern gambling operators, such as for example anti-money laundering laws. ## Severity The SGA has considered e.g., every violation of responsible gambling regulations (including violation of the bonus provisions) and provision of betting on events where the majority of participants were under the age of 18 as serious violations of the Gambling Act. Warnings have been issued and hefty fines of up to SEK 100M (approximately EUR 9,98M). The SGA has revoked licences when gambling has not been provided even after the first year of the licence being valid. It has also revoked a licence in a case involving an entity where the SGA found serious incompliances both in relation to RG provisions. It should be noted that the vast majority of the decisions issued by the SGA have been appealed and, in some areas, we are still awaiting binding case law from courts of higher instances. A full list of decisions taken by the SGA can be found here: https://www.spelinspektionen.se/lagar--forordningar/beslut/ Typical triggers for enforcement against unlicensed operators Typically, the SGA has initiated enforcement against online operators that target the Swedish market without the required licence. The SGA has implemented a long (non-exhaustive) list of targeting criteria, including when a company accepts deposits, withdrawals and winnings in Swedish Krona, has a website with information in Swedish, and/or that a company or the company's affiliates provide marketing in Swedish. When the SGA has identified an operator that illegally targets the Swedish market, it usually sends out a warning letter, giving the operator a chance to cease the targeting and thus comply with the Gambling Act. Should the operator not comply, the SGA issues a prohibition order and adds the operator to the so called blacklist (https://www.spelinspektionen.se/vara-beslut/beslutslista/?query=&top=10&skip=0&decisions=1)The SGA also files a police report. From 1 January 2023, the SGA has been given further authority to issue prohibitions and fines against those who aid and abet illegal gambling and is expected to make use of this authority. The SGA has since then issued one decision against a payment service provider to cease the offer of payment services to operators who illegally target the Swedish market. The order was coupled with potential fine of 25 million SEK. The Administrative Court rendered its judgment in the case on 22 May 2024, and the payment service provider was acquitted in full. The SGA has appealed the court's judgment to the Administrative Court of Appeal. As from 1 July 2023, new regulations have entered into force to aim to prevent illegal gambling in the Swedish market and includes amendments that will: Enable the government to oblige payment providers to send in transaction details regarding illegal gambling to the Swedish Gambling Authority Repeal the current regulations on payment blocking and enable the SGA to issue sanctions directly on payment service providers Betting: Match-fixing is a crime that can lead to imprisonment for two years. Casino: The state-owned casino, Casino Cosmopol was fined by the SGA in 2018 due to lack of compliance with the anti-money laundering provisions. In 2020, the amusement park Liseberg AB was fined for not providing information that the premises for gambling within the amusement park was reserved for 18+. Software/B2B: The same sanctions apply to B2B permit holders as to B2C licence holders. However, since B2B operators do not have any direct relationship with consumers and are not subject to the AML Act, supervision and enforcement is focused on whether licenced software providers also supply the black market. The SGA has initiated several cases against software providers which hold permits under the Swedish Gambling Act due to games being available on gambling websites targeting the Swedish market without the necessary license(s). In one case, the supplier was aquitted due to a legal technicality and in other cases suppliers have been acquitted when they have been able to demonstrate that the software used on the illegal websites were in fact piracy copies of their games. In other cases, the SGA issued a warning and a sanction fee. One of the cases, where the relevant supplier had implemented geo-blocking and only thumbnails were available on the illegal websites when accessed from Sweden, the Administrative Court imposed a supervisory fee of SEK 20,000. However, the decision has been appealed to the Administrative Court of Appeal.

The Swedish government has appointed a special investigator to review the scope of the Gambling Act (2018:1138). on 24 September 2025, the result was published (Ds 2025:23) proposing significant amendments to the Gambling Act, including: - Replacing the targeting criterion with a participation criterion, so that any gambling where people in Sweden can participate fall within the scope of the Gambling Act. - Extending the prohibition on aiding and abetting illegal gambling to cover payment solutions and similar services. - Introducing a presumption rule, requiring payment intermediaries to assume that participants are located in Sweden if they are Swedish residents. - Adjusting the criminal liability for unlawful gambling activates and the aiding and abetting thereof. The changes were proposed to enter into effect on 1 January 2027. However, as of 23 October 2026, no further progression has been made, making the timeline and feasibility of the suggestion uncertain.