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.
Sweden · Question 11 of 11
Sweden Gambling — Outlook: What is coming?
Mixed · Confirmed · Expert approved · 4 post-review updates · Not reviewed · In expert review scope · Back to full Sweden report →
Key section parameters
| Jurisdiction | Sweden (SE) |
|---|---|
| Regulator | Spelinspektionen |
| Favourability | Mixed |
| Confidence | Confirmed |
| Review status | Expert approved · 4 post-review updates · Not reviewed · In expert review scope |
| Last collected | 25 Oct 2026 |
Summary answer
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…
Not reviewed Read update
The principal item on Sweden'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.
Not reviewed 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'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.
Not reviewed Read update
The Ministry of Finance has endorsed a proposal to remove the Gambling Act's 'directional criterion', which currently limits Spelinspektionen'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.
Not reviewed Read update
The principal item on Sweden'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's extraterritorial gambling jurisdiction to date, materially raising the compliance burden for offshore-licensed operators and the payment providers that service them.