Sweden Gambling — Market entry in practice: How hard is entry, really?

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