--- title: "Sweden — Enforcement: How hard does the regulator enforce? | advennt.io" canonical: https://advennt.io/jurisdictions/sweden/enforcement/ source_html: /jurisdictions/se/enforcement/index.html description: "Sweden — Enforcement: How hard does the regulator enforce?" generated_at: 2026-11-07T14:55:18Z content_sha256: 5f1b1f199a17ce56281515d8bdd32811020bd5d3f2b97498f0d8676e95f8941c generator: "fe-fleet/md-twin@1.0" --- # Sweden — Enforcement: How hard does the regulator enforce? | advennt.io [Jurisdictions](/jurisdictions/) › [Sweden](/jurisdictions/sweden/) › Enforcement # Sweden Gambling — Enforcement: How hard does the regulator enforce? Key section parameters Jurisdiction Sweden (SE) Regulator Spelinspektionen Favourability Mixed Confidence Confirmed Review status Expert approved · 5 post-review updates · Not reviewed · In expert review scope Last collected 25 Oct 2026 Summary answer 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… 18 Oct 2026 Read update The Administrative Court of Appeal (Kammarrätten i Jönköping) ruled on 14 October 2026 to uphold Spelinspektionen's warnings and administrative penalty fees against Hillside (Sports) ENC and Hillside (Gaming) ENC, the two Swedish-licensed entities operating as bet365, rejecting both companies' appeals. The court confirmed a SEK 40 million fee against Hillside (Sports) ENC and a SEK 4 million fee against Hillside (Gaming) ENC, a combined SEK 44 million, for serious breaches of duty-of-care and mandatory deposit-limit obligations stemming from a no-limit deposit setting offered to players in place of a numerical cap. Both entities retained their licences following corrective action, so the confirmed outcome combines a substantial monetary penalty with continued market presence rather than licence suspension or revocation. This is the first appellate-level confirmation of Spelinspektionen's position that an uncapped deposit-setting option fails the mandatory numerical deposit-limit requirement and amounts to a serious duty-of-care breach, raising the practical compliance bar for any operator offering a similar configuration. The pinpoint statutory provision within Spellagen (2018:1138) applied to the breach was not confirmed from the source retrieved, and a fuller judgment text was not independently obtained. 28 Sep 2026 Read update Enforcement in 2026 confirms two parallel tracks. An administrative court in Linköping upheld a SEK 10 million AML/customer-due-diligence penalty against Kindred subsidiary Spooniker in July 2026, alongside related AML fines against Betsson and Snabbare, showing that Spelinspektionen's AML enforcement against licensed operators survives judicial review. Separately, a supervisory sweep covering the second half of 2025 reviewed 18 unlicensed operators, issuing 13 prohibitions and bringing 9 cases against promotion of unlicensed gambling, of which 3 were penalty-backed injunctions. This indicates sustained enforcement against unlicensed promotion running into 2026. A pending government-endorsed proposal to replace the directional criterion with a participant criterion would, if enacted, extend enforcement reach to any offshore site accessible to Swedish players, reversing case law that had limited enforcement to sites specifically targeting Sweden; the proposal is not yet enacted and its draft text was not located in primary sources this cycle. 21 Sep 2026 Read update Spelinspektionen's 2026 reform package expands its sanctioning toolkit to include heavier fines, suspension and licence revocation, assessed as probable at amber. Separately, and reported through a single trade-press source this cycle, the regulator has repealed the SIFS 2019:2 exemption that previously excused land-based casinos from the anti-money-laundering and counter-terrorist-financing obligations applied to online operators; land-based and online channels are now reported to sit under obligation parity. This repeal is treated as probable rather than confirmed pending primary Spelinspektionen corroboration. Both developments point toward a tightening enforcement posture, though the precise durability of the underlying instruments -- likely regulator circulars rather than primary statute -- keeps this module's evidentiary footing fragile-to-mixed rather than fully durable. 6 Sep 2026 Read update Spelinspektionen opened supervisory cases against operators during 2026 for unlicensed offering and inadequate deposit-source checks, with continued casework on illegal or unlicensed gambling marketing recorded through the second quarter of 2026, at probable confidence corroborated by trade press. Consistent with the civil-law enforcement-theory framing, the primary licensing-offence statute is Spellagen (2018:1138) itself: unlicensed operation is an offence under the enabling Act, a durable instrument, rather than a secondary licence-breach theory. A separately reported set of named-operator AML fines (Betsson Nordic, Snabbare, Spooniker, exceeding SEK 19 million combined) could not be structured as a claim because it surfaced only via a single lower-tier aggregator without a corroborating Spelinspektionen decision page, and is excluded here rather than asserted on thin sourcing. No blocking-regime or criminal-referral development was reported this cycle. 25 Aug 2026 Read update Spelinspektionen's enforcement posture is tightening this cycle. The regulator has been granted expanded powers to impose heavier sanctions, revoke licences and broaden compliance investigations, tied directly to the rollout of the credit-funded gambling ban and the new Spelpaus regime; this is assessed as probable, and the underlying instrument enabling the expanded powers is fragile in form, having emerged alongside the reform package rather than through amendment of the primary Gambling Act itself. Leadership has also changed: Peter Knutsson has been appointed Director General of Spelinspektionen from 17 August 2026, for a six-year term, succeeding acting Director General Johan Röhr, and will oversee implementation of both reforms. Taken together, an expanded sanctioning toolkit and new leadership arriving at the same moment as two major compliance deadlines signal that Spelinspektionen intends to use its enforcement powers actively rather than passively in the coming period. ## Full section analysis 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.