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# Sweden gambling licensing, cost and supervision | advennt.io

[Jurisdictions](/jurisdictions/) › Sweden

# Sweden Online Gambling Regulation, Licensing & Tax Regime

Enter via a per-operator Spelinspektionen licence, but model 22% tax and a credit-funding ban into the business case.

[12 open · 1 restricted · 2 closed · 1 uncertain · 4 not yet assessed → 20 classes](#products) Regulator: Spelinspektionen · Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 [PDF](report.pdf) [Sign in for PDF](https://advennt.io/auth/) [Compare](/compare/?j=sweden)

Regulatory Dimension Sweden Standing Position

Jurisdiction Sweden (SE)

Primary Gambling Regulator Spelinspektionen

Product Access Summary 12 open · 1 restricted · 2 closed · 1 uncertain · 4 not yet assessed

Permitted (Open) Verticals Casino, Poker, Bingo, Sports betting, Esports betting, Pool betting, Virtual event betting, Skill games, Sweepstakes, Free play, Software / B2B, Affiliate marketing

Restricted / Monopoly Verticals Payments for gambling

Prohibited (Closed) Verticals Lottery, Crypto gambling

Primary Instruments Referenced SE-SPELLAG-2018-1138; SE-SPELSKATT-2018-1139; SE-SGA-NYHETSARKIV; SE-HACKSAW-FR-2025

Verification & Currency Expert reviewed · Published 25 Oct 2026 (collected 25 Oct 2026)

## Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

### Player products

- CasinoModels agreeOOpen
- PokerModels agreeOOpen
- BingoModels agreeOOpen
- LotteryState monopoly · Models agreeXClosedVaries by form · 2Non profit lottery: restricted
- Lottery as addon to licensed online product: open

- Sports bettingOOpen
- Other event betting–Not yet assessed
- Horse and greyhound racing betting–Not yet assessed
- Esports bettingModels agreeOOpen
- Exchange betting–Not yet assessed
- Pool bettingModels agreeOOpenVaries by form · 1Lokalt poolspel: restricted

- Virtual event bettingModels agreeOOpen
- Fantasy sportsGrey zone?Uncertain
- Skill gamesModels agreeOOpenVaries by form · 1Pure skill: outside_perimeter

- Prediction markets–Not yet assessed
- SweepstakesOutside the regulatory perimeter · Models agreeOOpen
- Free playOutside the regulatory perimeter · Models agreeOOpen

### Supply roles

- Software / B2BModels agreeOOpen
- Affiliate marketingModels agreeOOpen
- Payments for gamblingRRestricted

### Settlement rail

- Crypto gamblingProhibited (not actively enforced)XClosed

Class-level certainty is graded for 12 of 20 classes.

## Board briefing

Sweden is an open, mature online market that is tightening — 22% tax, credit ban (Apr 2026), and a sharp AML-enforcement uptick.

#### What has changed

- Gambling tax rose to 22% (Jul 2024); land-based casinos banned (Jan 2026); a full credit-funding ban takes effect 1 April 2026 with Q2 audits; 2025 saw ~SEK 19m+ in AML sanctions across major operators.

#### What to do now

- Secure a per-operator Spelinspektionen licence (and a B2B software permit if supplying), rebuild deposit funnels to exclude credit/BNPL, harden source-of-funds CDD, and connect to Spelpaus.se.

#### What to watch

- The Isgren review (shift to &#x27;actual participation&#x27; liability and euro/English-language loophole closure), credit-ban audit outcomes, and online-casino channelisation (currently 72–82%).

## 11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

### Sweden Gambling — Overview

The dominant development for Sweden this period is the Administrative Court of Appeal&#x27;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 breache…

Full analysis · 124 words The dominant development for Sweden this period is the Administrative Court of Appeal&#x27;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&#x27; appeals, upholding Spelinspektionen&#x27;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&#x27;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.

- 22% gambling tax since July 2024
- Strict single-bonus regime depressing online casino channelisation
- Full credit-funding ban from April 2026
- Rising AML enforcement intensity

28 Sep 2026 Read update Sweden&#x27;s licensed gambling regime is in a mid-reform state through 2026. A credit-funded deposit ban is being phased in for licensed operators, the land-based casino licence class has been discontinued following the legislated closure of Casino Cosmopol, and restaurant slot-machine hosting has been tightened to venues above a turnover threshold. Enforcement remains active on two fronts: confirmed AML/customer-due-diligence penalties against licensed operators upheld on court appeal, and continued prohibitions against unlicensed operators. A government-endorsed proposal to widen extraterritorial reach via a participant criterion sits on the reform horizon but is not yet enacted. Taken together, the online casino and betting classes remain open and operable, but the regime is visibly tightening rather than static.

### Sweden Gambling — Licensing and regulation

## Regulated

The Swedish Gambling Act (2018:1138) allows any gambling operator satisfying the suitability criteria set out in the Gambling Act to apply for and be granted licences to offer online commercial gambling and/or betting to Swedish consumers.

Included in the product scope for online comm…

Full analysis · 1413 words ## Regulated

The Swedish Gambling Act (2018:1138) allows any gambling operator satisfying the suitability criteria set out in the Gambling Act to apply for and be granted licences to offer online commercial gambling and/or betting to Swedish consumers.

Included in the product scope for online commercial gambling is online bingo, online casino (including roulette, baccarat, punto banco, blackjack, poker and dice games) and computer simulated gambling machines (slots). Betting, both online and land-based betting, are included in the licence scope.

Changes to the Gambling Act mean that as from 1 July 2023, B2B operators manufacturing, amending, installing or supplying gambling software to Swedish B2C online licence holders also require a software permit.

Land-based bingo, casino, lottery, poker, skilled games are - with few exceptions - reserved for the state monopoly and/or charity organisations.

For gambling operations, the relevant regulator is the Swedish Gambling Authority (SGA). Within gambling, the SGA is also the regulatory authority when it comes to compliance with AML-legislation.

## Licence Triggers

The main legislative act in Sweden governing gambling is the Gambling Act (2018:1138). In addition, there is a governmental Gambling Ordinance (2018:1475) and secondary legislation issued by the SGA pursuant to the Gambling Act. Other relevant regulations directly applicable to gambling operations include the Swedish Gambling Tax Act (2018:1139) and the Money Laundering Act (2017:630).

A licence is required in Sweden for games of chance involving money and other prizes with a monetary value. The Gambling Act applies to gambling that is provided in Sweden and online gambling that is not directed at the Swedish market shall not be considered to be provided in Sweden. The SGA has set up extensive (non-exhaustive) criteria for when online gambling can be considered targeting the Swedish market, including inter alia marketing in Swedish/on Swedish websites, Swedish currency and other Swedish specific services.

Licences and permits under the Gambling Act may be granted to those who:

- Are deemed to have the knowledge, experience and organisation required to run the operation

- Presumably will run the operation in accordance with acts and other statutes that govern the operation

- Are deemed in other respects to be fit to run the operation

In order for the Swedish Gambling Authority to assess whether an applicant satisfies these criteria, it has provided application forms to be filled in and submitted by operators who wish to provide gambling in Sweden.

There is no requirement of local presence, but if the licence or permit holder is established outside the EEA, it needs to appoint a local representative.

Furthermore, a B2C operator’s gambling system needs to be placed in Sweden but an exception can be granted if the licence holder:

- Has permission to offer gambling in another country where a public authority monitors the licence holder’s gambling offers and said authority has concluded an agreement with the SGA on oversight of its gambling offers in Sweden, or

- Can give the Swedish gambling authority the ability to perform adequate controls over the gambling system by means of remote access or the like

## Type of licence

The Gambling Act is a prohibitory law, which means that any gambling not explicitly included in the scope of the law or an individual licence will be prohibited.

Six different types of licences exist:

1. Licence for the state monopoly – including gambling on land-based gambling machines (slots) and certain forms of lotteries.

2. Licence for charities/good causes – may include lotteries, land-based bingo and local pool betting at horse racing tracks.

3. Licence for land-based commercial gambling – which may include specific casino and card games and gambling machines (slots) if provided at an amusement park or at hotel or restaurant premises that hold a permit to serve alcohol.

4. Licence for gambling on ships in international traffic

5. Licence for commercial online gambling – included in the product scope for online commercial gambling is online bingo, online casino (including roulette, baccarat, punto banco, blackjack, poker and dice games) and computer simulated gambling machines (slots).

6. Licence for betting – including both land-based and online betting. A betting licence also covers betting on horse races, betting on electronically simulated events and the outcome of lotteries (if consent of the entity providing the lottery has been obtained). Certain defined forms of betting and betting on certain kinds of events are prohibited.

As from 1 July 2023, suppliers who manufacture, supply, install or amend gambling software available in the Swedish market require a permit. The requirement includes current B2C licence holders who perform such activities.

Social games and skill games fall outside the scope of the Gambling Act and, therefore, do not require a licence. It must be noted that winnings from a game of skill will be taxed as income in Sweden and the operator supplying such games will need to pay social charges.

As of 1 January 2026, the license for the state monopoly will be discontinued, and land-based casinos will no longer be permitted. The last Swedish casino, closed its doors on 25 April 2025, marking the end of land-based casinos in the country.

Period of licence & renewal process

Licences and B2B permits are normally issued for a period of five years. The SGA has however limited the licence period in certain instances where the authority has found reason to reassess the operators’ suitability sooner. Examples of when the licence period has been limited to two or three years is when an operator has indicated historic negative equity or where the operator has not been able to sufficiently demonstrate a that it has a sufficiently large organisation to operate in the Swedish market.

Application timeframe and phrases

Licence and permit applications

A licence or permit application is filed through the application form provided by the SGA and by submission of annexes and supporting documents.

In relation to a B2C licence, key individuals, including UBOs, directors, management and certain key roles held in the applicant company must submit an Annex A form and due diligence documents. Qualified owners, i.e. legal entities directly or indirectly holding 10% or more of the shares or voting rights in the applicant company must fill in and submit an Annex B, together with certain due diligence documents. As part of the licence application, several other supporting document will need to be submitted. Certification reports from accredited testing houses showing compliance with the Swedish technical requirements are usually the most time-consuming part of the applicants’ licence preparations.

The SGA aims to issue a licence or permit within three months of a complete licence application being filed. If an application for renewal is filed at least four months in advance of the licence or permit expiry, the old licence and/or permit will remain valid until the SGA has made a decision on the renewal application.

List of documents & type of information needed to support application

Several documents need to be included to support a B2C licence application. For example, an operator applying for an online commercial licence needs to submit:

- Application Form with basic information regarding the applicant and the operations

- Annex A – to be filled in by certain key personnel, directors, UBOs, etc. (and certain due diligence documents)

- Annex B – to be filled in by qualified owners (legal entities) (and certain due diligence documents)

- Business plan.

- Description of the owner/group structure.

- Description of the applicant’s operations.

- Financial documentation.

- Technical certification.

- Corporate documents

- Other licences held, if issued in a country other than Sweden.

- Licence rejections, revocations etc.

All documents must be submitted in Swedish.

In addition to the above, a registration must be made with the Swedish Tax Agency.

The application procedure for a B2B permit is easier and normally requires a filled in application form, a description of the gambling software, a description of the applicant’s operations and information about potential licences rejections, revocations, etc.

A B2B permit allows for the manufacture, supply, amendment and installation of gambling software with Swedish B2C licence holders.

Mechanics of the licence process

There is no limit on number and timeframes for licence applications. Certain licences are only available to the state monopoly or charity lotteries.

Bad Actor / Cooling off periods

There are no bad actor or cooling off periods but sanctions issued by other regulators have historically resulted in a shorter licence periods (two or three years instead of the normal five years), but the SGA seems to have now abandoned this practice.

28 Sep 2026 Read update The land-based casino licence class has been discontinued: Casino Cosmopol ceased physical operation on 24 April 2025, ahead of a Riksdag-legislated closure effective 1 January 2026. This is a structural, primary-legislation-level change to the licensing map rather than a licence-condition amendment, and it leaves the online casino licence class untouched. No new evidence surfaced this cycle on the entry pathway, capital, or fit-and-proper requirements for online licences, which remain governed by the existing statutory framework. The practical effect for a market entrant is that any land-based casino ambitions in Sweden are foreclosed, while online licence routes are unaffected by this closure.

21 Sep 2026 Read update The licensing framework itself, grounded in the Gambling Act (2018:1138), is unchanged in category terms this cycle, but its cost structure has shifted materially. SIFS 2026:1 replaces SIFS 2024:4, moving Spelinspektionen&#x27;s supervision-fee calculation from a per-corporate-group basis to a per-licence basis, effective 1 March 2026. The headline fees are SEK 240,000 per year for a B2C licence and SEK 16,500 per year for a B2B software permit. As a regulator fee schedule rather than primary legislation, SIFS 2026:1 is a fragile instrument -- revocable and revisable by Spelinspektionen without a legislative process -- but its practical effect is immediate: multi-licence corporate groups now face materially higher aggregate supervision costs than under the prior per-group charging model.

25 Aug 2026 Read update No new evidence of change to Sweden&#x27;s online licensing categories was identified this cycle. The one licensing-scope development is the permanent closure of the land-based casino segment: Casino Cosmopol&#x27;s physical casinos closed on 1 January 2026, and Spelinspektionen will not issue any new physical casino licences going forward. This is treated as a durable change, since it rests on the underlying statutory and administrative framework governing the land-based segment rather than on a circular or short-lived ministerial instruction, and it is not expected to be reversed through ordinary regulatory action. The practical effect is that Sweden&#x27;s licensing framework is now exclusively an online-licensing regime, with the state&#x27;s former physical-casino monopoly segment permanently retired.

### Sweden Gambling — Market entry in practice

The Swedish Gambling Act (2018:1138) allows any gambling operator satisfying the suitability criteria set out in the Gambling Act to apply for and be granted licences to offer online commercial gambling and/or betting to Swedish consumers. Included in the product scope for online commercial gambling…

Full analysis · 316 words The Swedish Gambling Act (2018:1138) allows any gambling operator satisfying the suitability criteria set out in the Gambling Act to apply for and be granted licences to offer online commercial gambling and/or betting to Swedish consumers. Included in the product scope for online commercial gambling is online bingo, online casino (including roulette, baccarat, punto banco, blackjack, poker and dice games) and computer simulated gambling machines (slots). Betting, both online and land-based betting, are included in the licence scope. Changes to the Gambling Act mean that as from 1 July 2023, B2B operators manufacturing, amending, installing or supplying gambling software to Swedish B2C online licence holders also require a software permit. Land-based bingo, casino, lottery, poker, combination games are - with few exceptions - reserved for the state monopoly and/or charity organisations. For gambling operations, the relevant regulator is the Swedish Gambling Authority (SGA). Within gambling, the SGA is also the regulatory authority when it comes to compliance with AML-legislation.

In 2024, the total turnover for the gambling market amounted to SEK 27,848 billions (approximately EUR 2,490 billions), of which online commercial gambling and betting represented a total of SEK 17,833 billions (approximately EUR 1,6 billions). Further market insights are available here: https://www.spelinspektionen.se/om-oss/statistik/

## Attractions

- Relatively competitive product scope

- Relatively easy market entry (licence process is not too onerous)

- Acceptable tax rate at 22% on Gross Gaming Revenue

- No local presence required (the licence holder’s gambling system shall be placed in Sweden but exemptions are normally granted)

- No limit on number of issued licences

## Challenges

- Market concentrated to top 5 online licence holders

- Big leakage to unlicensed market (the SGA calculates that 2.500M SEK was spent with operators without a Swedish licence in 2023)

- Only welcome bonus (no retention bonus) permitted

- Harsh sanctions from the SGA in case of violations

- Unequal access of popular payment methods

### Sweden Gambling — Licence fees

Application and annual supervisory fees are set by Spelinspektionen ordinance (SIFS schedules), payable per licence class. Fees are moderate by EU standards. No general capitalisation or guarantee requirement, though fit-and-proper and financial-stability assessments apply.

5 Oct 2026 Read update Sweden levies gambling tax at a flat 22 per cent on the proceeds of licensed gambling, defined as stakes less payouts, with liability declared on a monthly basis. For commercial online gambling specifically, the taxable proceeds for each taxation period are calculated only from stakes placed by, and payouts made to, players who live in Sweden or are habitually resident there, which narrows the effective base to the Sweden-facing share of an operator&#x27;s customer book rather than its full international footprint. Licences granted for public-interest purposes fall outside this tax entirely, a structural exemption distinct from the commercial-licence base. This rate and base were confirmed from Skatteverket&#x27;s own English-language guidance, cross-checked across two separate quoted passages from that same source, though the guidance has not yet been matched against the text of the underlying gambling tax statute, which remains an open item for fuller statutory corroboration. Operators modelling entry costs into Sweden should apply the 22 per cent rate against the Sweden-resident proceeds base for online commercial products, and should factor the public-interest exemption only where the licence itself is granted on that basis.

21 Sep 2026 Read update SIFS 2026:1, effective 1 March 2026, restructures Spelinspektionen&#x27;s supervision fees from a per-corporate-group to a per-licence charging basis, with a headline SEK 240,000 per year B2C licence fee and SEK 16,500 per year B2B software-permit fee. This raises the effective cost of operating multiple licences under one corporate group relative to the prior charging model. Layered on top is the compliance-technology spend implied by the mandatory Spelpaus self-exclusion API integration entering force 1 August 2026, together with a reported but only uncertainly-confirmed five-year data-retention obligation. The overall cost trajectory for 2026 is upward, driven primarily by the fee-basis change and the technical-integration mandate rather than by any change to headline licence-category tax rates.

### Sweden Gambling — Tax

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…

Full analysis · 475 words 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.

### Sweden Gambling — Payments and banking

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 indus…

Full analysis · 220 words 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&#x27;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.

28 Sep 2026 Read update Sweden&#x27;s licensees must ensure that customer deposits are not traceable to credit cards, overdrafts, loans, or buy-now-pay-later services, directly narrowing the permitted funding sources for gambling deposits. This obligation, reported to take effect in either April or May 2026 depending on the source, requires operators to implement payment-source verification distinguishing prohibited debt-funded payment rails from permitted funding methods such as debit cards and direct bank transfers. The underlying primary regulatory text was not independently retrieved this cycle, so the precise commencement date and any technical implementation guidance remain to be confirmed against Spelinspektionen&#x27;s own publication.

21 Sep 2026 Read update A blanket ban on credit-funded gambling -- covering credit cards, overdrafts, personal loans and buy-now-pay-later products -- expands the existing credit-funding prohibition under the Gambling Act (2018:1138). This is assessed as a durable statutory change in instrument type, but its precise commencement date is genuinely unresolved: trade-press sources diverge between 1 April 2026 and 1 May 2026, and this divergence is treated as an open question rather than resolved fact pending primary-source confirmation. Once in force, the ban represents a major restriction on the payment channels available to Swedish players and a significant compliance point for any operator&#x27;s payment-acceptance stack.

6 Sep 2026 Read update The extended credit ban under Spellagen (2018:1138) prohibits funding of licensed gambling via credit cards, loans, overdrafts and buy-now-pay-later products, with mandatory operator-side source-of-funds testing, in force since 1 May 2026. Spelinspektionen retains a narrow exemption power for public-benefit lotteries capped at one-fortieth of the price base amount (SEK 1,480 in 2026). This is a confirmed, durable statutory restriction on funding methods, confirmed by two Tier-1 sources including Spelinspektionen and the Riksdag&#x27;s Kulturutskottet committee report, representing a material tightening of the payments-flow environment for licensed operators.

25 Aug 2026 Read update From April and May 2026, Swedish licensees may no longer process gambling deposits funded by credit cards, overdrafts, personal loans or buy-now-pay-later products such as Klarna and Afterpay, across all licensed gambling forms. Spelinspektionen retains narrow discretion to grant exceptions, such as for charity lotteries. Operators must test and audit their payment-processing systems to identify and block these funding sources and take risk-based preventive action against attempts to route prohibited funding through permitted channels. This is a confirmed, in-force restriction that materially narrows the set of payment rails available to fund Swedish gambling accounts, applying as a structural constraint on payment architecture rather than as a temporary or discretionary measure.

### Sweden Gambling — Marketing

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…

Full analysis · 709 words 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.

### Sweden Gambling — Technical compliance

SIFS 2026:3, finalised 23 April and published 29 April 2026, mandates that all licensed operators integrate a new API for real-time verification of Spelpaus.se self-exclusion status, using regulator-issued credentials, entering force 1 August 2026. This is a fixed-date, mandatory technical-integrati…

Full analysis · 77 words SIFS 2026:3, finalised 23 April and published 29 April 2026, mandates that all licensed operators integrate a new API for real-time verification of Spelpaus.se self-exclusion status, using regulator-issued credentials, entering force 1 August 2026. This is a fixed-date, mandatory technical-integration obligation rather than guidance, though as a standing regulator instrument it remains fragile in durability terms -- revisable by Spelinspektionen without legislative process. It represents the clearest, most concretely dated technical-compliance development in this cycle&#x27;s reform bundle.

6 Sep 2026 Read update SIFS 2026:3 converts Spelpaus self-exclusion from operator-designed checks into a mandatory, API-based real-time verification model, requiring regulator-issued Actor IDs and API keys, effective 1 August 2026. This is a fragile instrument in evidentiary terms: the primary regulatory text was not directly retrieved this cycle, and the finding rests on secondary trade-press reporting corroborated across two lower-tier outlets, so it carries only probable confidence despite its material effect on operators&#x27; technical build requirements. Operators should anticipate integration work against a regulator-issued API specification rather than continuing to rely on internally designed self-exclusion checks once the effective date passes.

### Sweden Gambling — Distribution and platforms

## Infrastructure

As a main rule, the gambling system, including servers, shall be based in Sweden. However, the SGA may grant an exemption from this main rule if it has entered into an MOU with the operator’s local regulator or if the operator is able to grant the SGA satisfactory remote access.

…

Full analysis · 266 words ## Infrastructure

As a main rule, the gambling system, including servers, shall be based in Sweden. However, the SGA may grant an exemption from this main rule if it has entered into an MOU with the operator’s local regulator or if the operator is able to grant the SGA satisfactory remote access.

## Integrations

There is no requirement for integration with local regulatory or monitoring systems. However, when a player registers or logs on to the player account, a check must be made against the national self-exclusion registry (Spelpaus).

Software certification

Games provided need to go through a technical certification and have reports issued annually by an accredited testing lab to ensure compliance with the technical regulations and the licenced B2C operators shall submit the result to the SGA as part of their license application and/or upon request.

Licensees face three converging new operational duties. First, the credit-funding ban effective 1 May 2026 requires funding-source verification to exclude 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 may suspend, fine, or in serious cases revoke licences for breaches. Second, SIFS 2026:3, effective 1 August 2026, means that the requirement to use a unique Actor ID and API Key per licensee with separated marketing and registration/login query paths is codified. Third, Spelinspektionen has opened a supervisory investigation into four named operators regarding handling of customers with monthly deposit limits above SEK 10,000.

### Sweden Gambling — Enforcement

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…

Full analysis · 1513 words 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&#x27; 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&#x27;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&#x27;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&#x27;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.

18 Oct 2026 Read update The Administrative Court of Appeal (Kammarrätten i Jönköping) ruled on 14 October 2026 to uphold Spelinspektionen&#x27;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&#x27; 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&#x27;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&#x27;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&#x27;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&#x27;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&#x27;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.

### Sweden Gambling — Outlook

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 crit…

Full analysis · 148 words 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.

28 Sep 2026 Read update The principal item on Sweden&#x27;s reform horizon is a government-endorsed proposal to replace the directional criterion with a participant criterion, extending Swedish gambling law to any offshore site accessible to Swedish players. This would reverse case law that had limited enforcement against offshore operators to those specifically targeting the Swedish market. The proposal has not been enacted, and draft bill text was not located on regeringen.se or riksdagen.se this cycle; it rests on a single lower-tier secondary source, so its precise scope, timeline, and likelihood of passage remain unconfirmed.

21 Sep 2026 Read update Two forward-looking reforms are in train for Sweden. The first is the proposed shift in the jurisdictional-reach test from a directional to a participant criterion, which would substantially expand Spelinspektionen&#x27;s practical reach over offshore operators; this remains at proposed stage and uncertain confidence. The second is the continued rollout of the 2026 compliance charter itself -- the credit ban, the Spelpaus API mandate and the expanded enforcement powers -- several elements of which are already enacted but carry open questions on exact commencement dates. Both threads point toward continued regulatory tightening rather than any near-term liberalisation.

6 Sep 2026 Read update The Ministry of Finance has endorsed a proposal to remove the Gambling Act&#x27;s &#x27;directional criterion&#x27;, which currently limits Spelinspektionen&#x27;s jurisdiction to offshore operators that direct marketing or services at the Swedish market. This is government-endorsed but not yet enacted, and rests on uncertain confidence from a single lower-tier source. If enacted, it would extend jurisdiction to non-Swedish-facing offshore operators, representing a material forward-looking signal of broader extraterritorial enforcement intent, though the proposal remains pre-legislative and could stall.

25 Aug 2026 Read update The principal item on Sweden&#x27;s gambling reform horizon is a proposed amendment to the Gambling Act (2018:1138) that would replace the current directional criterion for extraterritorial reach with a participant criterion, under which mere accessibility from Sweden would trigger Swedish jurisdiction. The proposal would also place a burden-shifting presumption on payment providers regarding the Swedish residency of end users. This remains at proposal stage and has not been enacted this cycle; its assessed confidence is probable rather than confirmed. If adopted, it would represent the most significant expansion of Sweden&#x27;s extraterritorial gambling jurisdiction to date, materially raising the compliance burden for offshore-licensed operators and the payment providers that service them.

Evidential record & source register 3 enforcement · 25 red flags · 14 sources · Expand full record

## Enforcement record

What the regulator has actually done, newest first. 3 recorded events.

- 9 Sep 2025Spelinspektionen · Betsson Nordic LtdConfirmedSource 9 · T3
- 4 Jun 2025Spelinspektionen · TSG Interactive PLC (PokerStars/Flutter)ConfirmedSource 5 · T2
- 25 Mar 2025Spelinspektionen · Glitnor Services LimitedConfirmedSource 3 · T1

## What gets operators fined

25 red flags (11 high, 11 medium, 2 low) and 6 controls that address them.

- highSource-of-funds / CDD failures on high-deposit playersMultiple SEK-millions sanctions in 2025 (Glitnor, Betsson, TSG, Spooniker, Videoslots).Source 9 · T3
- highCredit-funded deposits after 1 April 2026Full credit ban with Q2 audits; fines from SEK 1m.Source 8 · T3
- highOperating B2B software supply without permitMandatory since July 2023; Hacksaw Studios court ruling confirms breach exposure.Source 4 · T1
- highTargeting Swedish players without licencePayment blocking, DNS warnings, prohibition orders; Isgren reform may add &#x27;actual participation&#x27; liability.Source 8 · T3
- highFailure to connect to Spelpaus.seMandatory national self-exclusion; non-connection is a licence breach.Source 1 · T1
- highBNPL/Klarna deposits post-April 2026Explicitly folded into the credit ban scope.Source 8 · T3
- highTreating prior withdrawals as source-of-funds justificationSpelinspektionen rejected this rationale (Betsson case).Source 9 · T3
- highEuro/English-language loophole relianceGovernment memorandum targets closure to make all unlicensed offshore operators illegal.Source 12 · T3
- highRepeat or egregious offendingRegulator has signalled escalating sanctions for repeat offenders.Source 9 · T3
- highFailure to trace loan-origin funds transferred via bankCredit ban extends to funds tracing back to borrowed money.Source 8 · T3
- highOffering lottery outside monopoly/charity reservationLottery reserved to state/public-benefit sector.Source 10 · T3
- mediumUnderpayment of 22% gambling taxTax base is GGR-equivalent balance; errors trigger Skatteverket exposure.Source 2 · T1
- mediumExceeding single-bonus rule or targeting self-excluded playersKonsumentverket/Spelinspektionen sanctions on advertising.Source 13 · T3
- mediumNon-EEA operator without Swedish representativeChapter 11 Section 6c requires a resident physical representative.Source 13 · T3
- mediumOnline-casino leakage to offshoreChannelisation 72–82% in casino erodes licensed-market share.Source 6 · T3
- mediumAffiliate content breaching RG/content rulesStrict content rules; operator liable for affiliate conduct.Source 13 · T3
- mediumUncertified games or unconnected control systemsSIFS technical standards require certification and control-system connection.Source 1 · T1
- mediumAssuming 18% legacy rateRate is 22% since 1 July 2024 — outdated modelling risk.Source 11 · T3
- mediumInadequate deposit-limit offeringMandatory under Chapter 14.Source 1 · T1
- mediumNo annual AML compliance reportRequired of designated reporting entities under AML Act.Source 9 · T3
- mediumCrypto-funded gamblingCrypto gambling outside licensing framework; rising in illegal segment.Source 9 · T3
- mediumInfluencer promotion of unlicensed gamblingRegulator pursued influencers promoting illegal gambling in 2025.Source 9 · T3
- lowMarket consolidation pressureCredit ban + tax may drive consolidation by 2027.Source 8 · T3
- lowFailure to report personkrets changesNew 2025 routine for reporting suitability-circle changes; supervision active.Source 3 · T1
- criticalLand-based casino operation after Jan 2026Land-based casinos banned from 1 January 2026.Source 6 · T3

### Controls

- 001Source-of-funds EDD on high-deposit playersTrigger enhanced due diligence and source-of-funds checks where deposits exceed declared income.Source 9 · T3
- 002Credit-source payment screeningReal-time BIN checking and bank-transfer tracing to reject credit/loan/BNPL-funded deposits.Source 8 · T3
- 003Spelpaus.se integrationMandatory connection to the national self-exclusion register before serving any player.Source 1 · T1
- 004Single-bonus enforcementLimit to one active welcome bonus per account, capped per regulation.Source 13 · T3
- 005Geolocation gatingIP-based confinement of play to Swedish-eligible users.Source 1 · T1
- 006B2B software-permit verificationConfirm supplier holds a Spelinspektionen software permit before integration.Source 10 · T3

## Worked scenarios

5 entry scenarios, each with the move we would make.

#### MT-licensed casino wants to enter Sweden.

Must obtain its own Spelinspektionen commercial online gambling licence, appoint a Swedish representative (non-EEA), connect to Spelpaus.se, and comply with the April 2026 credit ban.

Do this: Apply for a per-operator licence; do not rely on the euro/English-language loophole, which is targeted for closure.

Source 1 · T1 Source 12 · T3

#### Game studio supplies slots to a Swedish B2C licensee.

Since 1 July 2023 a gambling-software permit is mandatory; Hacksaw Studios was found in breach for non-compliance.

Do this: Obtain the software permit before any supply.

Source 10 · T3 Source 4 · T1

#### Operator models Swedish P&L using 18% tax.

The rate is 22% of GGR since 1 July 2024; modelling at 18% understates duty.

Do this: Update tax assumptions to 22%.

Source 2 · T1 Source 11 · T3

#### Player deposits SEK 491,950 over three months exceeding declared income.

Spelinspektionen rejected treating prior withdrawals as source-of-funds justification (Betsson case), imposing a SEK 6.5m fine.

Do this: Trigger EDD and document source-of-funds independently of winnings.

Source 9 · T3

#### Operator allows Klarna BNPL deposits in 2026.

BNPL is within the credit-ban scope from 1 April 2026; Q2 audits and fines from SEK 1m apply.

Do this: Disable all credit/BNPL rails and implement credit-source tracing.

Source 8 · T3

## What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Fees. precise SIFS fee-schedule figures per licence class not retrieved at point-level from primary ordinance.

- searched: Spelinspektionen ansökningsavgift licens 2025
- searched: Sweden gambling licence application fee SEK
- searched: SIFS avgifter tillsyn spellicens
- checked: spelinspektionen.se

Competitive landscape. published unlicensed-market-share point figure is inferred from channelisation (~15% of competitive market), not a directly stated regulator figure.

- searched: Sweden unlicensed gambling market share percent
- searched: Spelinspektionen olicensierad marknad andel
- searched: Sweden offshore gambling GGR estimate 2024
- checked: spelinspektionen.se

## Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.

14 sources · 4 tier 1 · 1 tier 2 · 9 tier 3

No. Source Tier Verification

1 SE-SPELLAG-2018-1138 T1 of 4 Source 1 · Open in drawer →

2 SE-SPELSKATT-2018-1139 T1 of 4 Source 2 · Open in drawer →

3 SE-SGA-NYHETSARKIV T1 of 4 Source 3 · Open in drawer →

4 SE-HACKSAW-FR-2025 T1 of 4 Source 4 · Open in drawer →

5 SE-TSG-FINE-2025 T2 of 4 Source 5 · Open in drawer →

6 SE-SGA-ANNUAL-2025 T3 of 4 Source 6 · Open in drawer →

7 SE-CHANNEL-METHOD-2024 T3 of 4 Source 7 · Open in drawer →

8 SE-CREDIT-BAN-2026 T3 of 4 Source 8 · Open in drawer →

9 SE-AML-FINES-2025 T3 of 4 Source 9 · Open in drawer →

10 SE-ADVENNT-MARKET-2025 T3 of 4 Source 10 · Open in drawer →

11 SE-TAX-EFFECT-2024 T3 of 4 Source 11 · Open in drawer →

12 SE-CREDIT-BAN-IGB-2026 T3 of 4 Source 12 · Open in drawer →

13 SE-ALTENAR-OVERVIEW T3 of 4 Source 13 · Open in drawer →

14 SE-ATG-CHANNEL-Q3-2025 T3 of 4 Source 14 · Open in drawer →

### Claims with their own provenance

Gambling tax raised to 22% of GGR effective 1 July 2024.

· ·

Source 15 · T1

Full credit-funding ban effective 1 April 2026 across all licensed gambling.

· ·

Source 8 · T3

## Related coverage
