Financial Services Regulation 2025 Comparisons

Sweden’s financial regulatory framework is largely derived from EU directives, which are implemented through national legislation and regulations. Swedish law, however, departs in certain respects to reflect domestic policy choices and supervisory practice. In line with the broader EU framework, the Swedish financial market is subject to comprehensive regulation.

Some of the key pieces of legislation governing the Swedish financial market include the following.

The Banking and Financing Business Act (lag (2004:297) om bank- och finansieringsrörelse; the BFBA)

The BFBA implements the Capital Requirements Directive 2013/36/EU (CRD) and constitutes the principal statute within Sweden’s financial regulatory framework. It governs entities conducting banking business, meaning the acceptance of repayable funds from the public and the execution of payment intermediation through payment systems, as well as entities engaged in financing business, defined as the acceptance of repayable funds from the public combined with the granting of credit. The BFBA governs, inter alia, authorisation, organisational and governance requirements, risk management and internal control. Consumer protection in the credit market is currently a legislative priority, which has resulted in the BFBA applying, as of 1 July 2025, to all undertakings that provide or mediate consumer credit.

The Certain Financial Activities Act (lag (1996:1006) om viss finansiell verksamhet; the CFAA)

The CFAA applies to other undertakings that engage in certain types of financial activities, such as granting or mediating credit to corporates, participating in financing arrangements like factoring and leasing, and providing means of payment. Undertakings engaged in such activities are regarded as financial institutions (finansiella institut). The CFAA primarily governs the requirements relating to registration, governance, and supervision of these financial institutions.

The Securities Market Act (lag (2007:528) om värdepappersmarknaden; the SMA)

The SMA implements Directive 2014/65/EU (MiFID II) and applies to undertakings that provide investment services and activities, including the reception and transmission of orders, execution of orders, dealing on own account, underwriting and placing of financial instruments, portfolio management, and investment advice, as well as the operation of trading venues such as regulated markets, multilateral trading facilities (MTFs), and organised trading facilities (OTFs). Undertakings engaging in such activities are regarded as investment firms (värdepappersbolag) or market operators (marknadsoperatörer).

The Alternative Investment Fund Managers Act (lag (2013:561) om förvaltare av alternativa investeringsfonder; the AIFMA)

The AIFMA implements Directive 2011/61/EU (AIFMD) and applies to undertakings managing alternative investment funds (AIFs), including portfolio and risk management, and, where relevant, the marketing of AIFs in Sweden. Undertakings engaging in such activities are regarded as alternative investment fund managers (AIF-förvaltare).

The UCITS Act (lag (2004:46) om värdepappersfonder; the “Swedish UCITS Act”)

The Swedish UCITS Act implements Directive 2009/65/EC (the “UCITS Directive”) and regulates undertakings that manage undertakings for collective investment in transferable securities (UCITS), including portfolio management, risk management and, where relevant, the marketing of UCITS in Sweden. Undertakings engaging in such activities are regarded as UCITS management companies (fondbolag).

The Anti-Money Laundering and Terrorist Financing Prevention Act (lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism; the “Swedish AML Act”)

The Swedish AML Act applies to a range of undertakings, including credit institutions, financial institutions, payment and e-money institutions, investment firms, fund managers, and insurance distributors. The Swedish AML Act implements the EU AML framework and requires a risk-based approach. It governs business-wide and customer-level risk assessments, customer due diligence, record keeping, internal governance and controls (policies and procedures, training, screening and appointment of an AML compliance function), reliance and outsourcing arrangements, as well as reporting obligations to the Swedish Financial Intelligence Unit (Finanspolisen) concerning suspicious activities and transactions.

In general, most financial activities conducted on the Swedish market require authorisation or registration with the Swedish Financial Supervisory Authority (SFSA). The regulatory framework covers a broad range of products and services across the financial sector.

Banking and financing activities are regulated, including the provision of accounts, deposits, consumer and corporate lending, guarantees, factoring, and finance leasing. The regulation also extends to payment services and the issuance of electronic money, encompassing card issuing and acquiring, money remittance, payment initiation and account information services, and electronic wallets.

Retail financial products, such as consumer credit, mortgages, insurance policies, and investment products, are subject to conduct and distribution rules, including requirements relating to advice, disclosure, product governance, marketing, and complaints handling. Investment services, such as brokerage, order execution, proprietary trading, underwriting, portfolio management, and investment advice, are regulated alongside access to trading venues, including regulated markets and other organised trading facilities.

The regulatory perimeter also extends to foreign exchange trading, the management and distribution of collective investment schemes (including UCITS and AIFs), and securities issuance and disclosure obligations for listed companies. Market infrastructure services such as the operation of trading venues, central clearing, and securities settlement and custody are likewise supervised. Finally, insurance and reinsurance activities, as well as occupational pension products and their administration and distribution, are subject to specific regulatory regimes.

In Sweden, there are generally two main exemptions available to avoid triggering a licensing or registration requirement: the de minimis exemption and the reverse solicitation exemption.

The De Minimis Exemption

In order for the provision of regulated activities to trigger a licensing or registration requirement, the regulated activities need to amount to a certain level of duration, frequency and regularity. Conversely, the provision of regulated activities on a very limited basis would not trigger a licensing requirement under Swedish law. The SFSA has not given any formal guidance on the application of the exemption, and the SFSA will judge each case on its own merits, taking into account a number of factors. These factors include:

• the volume of regulated activity;
• the number of clients;
• the type of clients (ie, professional or non-professional);
• the amount of physical presence in Sweden; and
• the amount of marketing activities directed towards the Swedish market.

Please note that the above list should not be considered exhaustive.

Reverse Solicitation

The provision of regulated activities on a pure reverse solicitation basis would not trigger a licensing requirement under Swedish law. To qualify for the exemption, the user must have approached the provider of its own initiative, without any marketing or solicitation activities having preceded the request.

Crypto-assets in Sweden are regulated under the EU Markets in Crypto-Assets Regulation (EU) 2023/1114 (MiCA), which has applied in Sweden since December 2024. The SFSA acts as Sweden’s national competent authority, responsible for the authorisation and supervision of both issuers and service providers.

Crypto-assets issued or offered in Sweden are governed by MiCA’s asset-based classification, which distinguishes between asset-referenced tokens (ARTs), e-money tokens (EMTs), and other crypto-assets.

Issuers of ARTs and EMTs established in Sweden must obtain SFSA authorisation prior to issuance, publish an approved white paper, and comply with requirements on governance, capital, reserves, and redemption rights. ARTs referencing multiple assets are subject to enhanced oversight regarding reserve composition and stabilisation mechanisms, while EMTs linked to a single fiat currency may generally be issued only by credit institutions or e-money institutions.

Issuers of other crypto-assets (such as utility tokens) are not required to obtain prior authorisation from the SFSA unless the asset qualifies as a financial instrument under Swedish or EU financial markets legislation.

Any firm providing crypto-asset services in Sweden such as custody, trading platform operation, exchange between crypto-assets and fiat currencies, or portfolio management must hold authorisation from the SFSA.

Applications are assessed under criteria derived from MiCA and the SFSA’s procedural guidance, with review focusing on governance, capital adequacy, safeguarding of client assets, and internal controls.

The SFSA’s supervisory responsibilities extend beyond licensing to include ongoing compliance monitoring, covering organisational standards, AML/CTF measures, transparency, and consumer protection.

The Ministry of Finance (Finansdepartementet)

The Ministry of Finance is primarily responsible for developing and proposing legislation and regulations governing the financial sector in Sweden. It develops the framework for financial institutions, ensuring alignment with EU directives and regulations as well as national policy objectives. It does not perform any supervisory tasks.

The SFSA

The SFSA is the primary supervisory authority for the Swedish financial market, with a mandate including supervision, regulation and authorisation. The SFSA is authorised to intervene against undertakings that do not comply with the regulations by issuing injunctions, reprimands and warnings, which may be accompanied by fines. The SFSA also monitors systemic risks, such as imbalances in the financial market, to promote stability across the financial system.

The Swedish Central Bank (Sveriges Riksbank; the “Riksbank”)

The Riksbank has primary responsibility for maintaining a stable financial system, with a focus on maintaining price stability, ensuring the security and efficiency of the Swedish payment system as well as monitoring and assessing systemic risks on the Swedish financial market.

The Swedish National Debt Office (Riksgälden)

The Swedish National Debt Office has a central role in safeguarding financial stability by managing banks in distress and overseeing the deposit insurance system. It acts as a resolution authority, implementing measures designed to prevent or mitigate financial crises and maintain confidence in the financial system.

The Swedish Consumer Agency (Konsumentverket; the SCA)

The SCA is the supervisory authority responsible for consumer protection in the financial market. It monitors that financial institutions operating with consumers comply with consumer protection law. Where incompliance is identified, the SCA is authorised to issue injunctions accompanied by fines.

The SFSA, the Riksbank, the National Debt Office and the SCA are, within their respective areas of responsibility, authorised to issue regulations in addition to the statutory regulations applicable to financial market participants.

The rules and guidance issued by these authorities can be found in their respective regulatory codes:

• for the SFSA: Finansinspektionens författningssamling (FFFS);
• for the Riksbank: Riksbankens författningssamling (RBFS);
• for the National Debt Office: Riksgäldens författningssamling (RGKFS); and
• for the SCA: Konsumentverkets författningssamling (KOVFS).

These codes include regulations (föreskrifter) and general guidance (allmänna råd) that supplement and clarify the statutory requirements set out in law.

Status and Timeline

Sweden has not yet fully implemented the final Basel III reforms. In May 2025, the government presented a memorandum outlining a proposed legislative package on how Basel III will be implemented, including the EU’s banking package comprising Regulation 2024/1623/EU (CRR III) and Directive 2024/1619/EU (CRD VI), which transposes the outstanding Basel III elements at EU level.

The proposal has been sent to various Swedish authorities, courts and industry associations for review, and their responses also have been published. However, the government has not yet presented the proposal in its final form.

According to the government’s proposal, the bulk of Swedish legislative changes would enter into force on 11 January 2026. However, some legislative changes (which are not related to Basel III), such as the new third‑country branch regime and certain cross‑references, are scheduled to enter into force on 11 January 2027. The proposal also incorporates EU transitional provisions, including grandfathering for some pre‑July 2026 contractual arrangements and the phased application of third-country branch reporting.

How Basel III Is Being Implemented

Basel III’s remaining elements are implemented in Sweden primarily by directly applicable EU regulation (CRR III) and by amendments to Swedish framework laws that complement CRD VI, including the Banking and Financing Business Act, the Special Supervision of Credit Institutions and Investment Firms Act and the Capital Buffers Act. The proposal confines Swedish legislative changes to areas where CRD VI requires national transposition or where Swedish law must be adapted to interact with CRR III. Supervisory details are largely delegated to the SFSA through existing or expanded rulemaking powers.

Key Elements of the Proposal Relevant to Basel III

The proposal addresses four main pillars that operationalise the final Basel package in Sweden.

Governance, risk management, and ESG

Boards must review risk policies at least biennially, with explicit integration of ESG risks in governance and supervisory review. Internal control enhancements and expectations for internal audit are to be implemented through the SFSA secondary rules, aligning with CRD VI.

Pillar 2 and interaction with the output floor

The SFSA’s Pillar 2 capital add‑ons and communicated capital guidance must avoid double‑counting risks now captured by the CRR III output floor. The SFSA should also review O‑SII and system risk buffers when institutions become subject to the floor.

Capital buffers

Adjustments have been made to the setting and review of O‑SII buffers and the system risk buffer, including process changes for buffer levels above 3% or 5%, and the recognition that system risk buffers may target climate‑related systemic risks. National rules confirm that buffers cannot substitute for risks already captured by the CRR III output floor.

Alignment With the Final Basel III Reforms

The proposal closely aligns with the EU implementation of the Basel output floor, revised standardised and internal model approaches across risk stripes, and the re‑calibrated Pillar 2 framework by ensuring Swedish law neither duplicates CRR III requirements nor allows double counting. The supervisory methodology and governance expectations mirror CRD VI, including the enhanced fit‑and‑proper framework, expanded transactions approvals (significant acquisitions, asset transfers, mergers/splits), and strengthened sanctions. Where CRD VI contains national options, such as exempting “qualified” third-country branches from liquidity requirements or applying bank‑equivalent rules to all third-country branches, the proposal generally eschews gold‑plating, opting for the baseline EU approach and declining optional exemptions that could undermine consistency.

Impact on Firms

For Swedish banks and credit market companies, the most immediate effects are process‑oriented:

• board‑level risk governance cadence;
• ESG risk integration;
• clearer, non‑duplicative calibration of Pillar 2 relative to the output floor; and
• refined buffer‑setting and review.

Transactional scrutiny will intensify, with harmonised timelines, broadened criteria, and enhanced AML/CFT co-ordination for significant acquisitions, major asset transfers, and group reorganisations.

Sweden has not yet implemented a T+1 settlement cycle. In line with the EU-wide programme, Sweden will transition to T+1 on 11 October 2027. Under the European Securities and Markets Authority’s (ESMA) final proposals on settlement discipline and tools to improve settlement efficiency, there is a phased pathway ahead of go‑live. Key pre‑settlement process changes meant to support T+1 (most notably the requirement to exchange allocations and confirmations in an electronic, standardised format and to complete them on trade date) are scheduled to apply from 7 December 2026. ESMA also proposes that settlement instructions be submitted to securities settlement systems as soon as possible and no later than 23:59 on trade date, reinforcing intraday instruction and matching. Enhanced monitoring and disclosure of settlement fails by CSDs would begin from 1 July 2027, providing supervisors with a meaningful pre‑ and post‑migration dataset.

By the 11 October 2027, transition, market infrastructures and intermediaries are expected to support functionalities critical to settlement efficiency under T+1.

ESG Framework

Sweden’s regulatory framework for ESG investment largely derives from EU legislation, complemented by supervision and guidance from the SFSA. The central pillar is Regulation 2019/2088/EU (SFDR), which imposes entity- and product-level sustainability disclosures on asset managers, insurers and other financial market participants. In practice, SFDR, together with Regulation 2020/852/EU (the “Taxonomy Regulation”), creates clear categories for products with sustainability characteristics or objectives, which has supported the development and distribution of ESG funds in the Swedish market.

Product governance and suitability rules further integrate sustainability. Under MiFID II, and the corresponding regime for insurance under Directive 2016/97/EU (IDD), firms distributing portfolio management, investment advice and insurance-based investment products must assess clients’ sustainability preferences and incorporate these preferences in product design and distribution. This requirement has driven the mainstreaming of ESG across Swedish wealth and retail channels, as intermediaries must be able to explain and source products that meet articulated sustainability criteria.

At the corporate level, Sweden is within scope of Directive 2022/2464/EU (CSRD), which phases in extensive sustainability reporting obligations and use of European Sustainability Reporting Standards. More robust corporate data should, over time, improve the quality and comparability of ESG information available to investors and fund managers. Sweden also applies EU rules on climate benchmarks and the oversight of ESG ratings as these initiatives progress, supporting transparency in index construction and the ecosystem that informs investment decisions.

Greenwashing

Greenwashing risks are addressed through several overlapping regimes. First, SFDR and the Taxonomy Regulation prohibit overstating sustainability characteristics or alignment and require that claims be substantiated with prescribed metrics and narrative disclosures. Second, under the EU prospectus, UCITS and AIFMD frameworks, fund documentation must not be misleading, and ongoing disclosures must fairly present sustainability features and outcomes. Third, general conduct-of-business rules under MiFID II/IDD require that marketing communications, including sustainability claims, be fair, clear and not misleading.

The SFSA has published a strategy to prevent greenwashing, where it states that it will prioritise the following areas in its work to prevent greenwashing:

• implementing new rules and maintaining a dialogue and communication with the industry;
• improving access to sustainability-related information;
• improving transparency about ESG ratings and ESG data suppliers;
• improving disclosures regarding sustainable financial products;
• following up on information provided in conjunction with financial advice;
• integrating sustainability factors into its authorisation process;
• building capacity in the area of sustainable finance; and
• international co-operation in task groups on this topic.

To date, there has not been any monetary sanction issued due to greenwashing.

Regulation 2024/1689/EU (the “AI Act”), which directly applies in Sweden, regulates AI use (generally, rather than specifically in the financial services sector). In connection to the entry in to force of the AI Act, the SFSA has mapped the use of AI by financial firms on the Swedish financial market. The findings in the SFSA’s report indicate that, although AI has been used over a long period of time across the financial sector in Sweden, its use is increasing while risk management and formal governance appear to lag behind.

The SFSA considers it likely that the Swedish financial sector will operate within high-risk areas under the AI Act. Within the financial markets, two domains are explicitly designated as high risk: (i) credit assessment, and (ii) life and health insurance. According to the SFSA, some firms already classify certain credit assessment use cases as high risk under the AI Act. Moreover, fourteen financial firms consider it likely or highly likely that, within the next 24 months, they will have high-risk use cases in both credit assessment and life or health insurance.

Despite rising adoption across the Swedish financial sector, the SFSA concludes that most financial firms with AI in production currently lack a formally approved AI policy for the development and use of AI, underscoring the governance gap.

The SFSA has not yet published any binding regulations (föreskrifter) or general guidance (allmänna råd) regarding the use of AI within financial operations on the Swedish financial market. However, the current Acting Director General (when serving as head of the payments department) has expressed certain expectations on the financial firms under the SFSA’s supervision as the use of AI increases. The core expectations mentioned are set out below.

• Firms implementing AI must have sufficient expertise to assess the impact of AI-specific risks on the operations. Such risks include a lack of transparency and limited ability to retrospectively explain why an AI system has produced a given outcome. Any firm using AI in its operations must therefore understand how their AI models are constructed, what data they are trained on and how they evolve over time.
• Firms should establish appropriate structures to manage these AI-specific risks when necessary and to ensure these structures support careful, case-by-case risk assessments. While rapid expansion can be tempting when results come quickly and technology becomes more accessible, possible consequences of the usage may be missed without systematic and well-considered risk management.
• Firms should continue to comply with all applicable regulatory frameworks for financial institutions, even as AI use expands. As the financial sector is highly regulated, there are certain requirements that might already be challenging to reconcile with AI’s specific characteristics. However, these obligations cannot be disregarded.

General Comments on the Swedish Fintech Scene

Sweden has one of the most vibrant fintech scenes in Europe, with several globally recognised companies like Klarna, Tink, Zettle and Trustly. However, fintech in Sweden is increasingly seen as a general wave of innovation and development in the financial market rather than individual companies. Many of the new services that are currently challenging established players with alternative offerings and business models are likely to be standard market practices in the future. Over the past decade, Sweden has seen strong growth in companies that create new innovative financial services. The country has been early to adopt digital banking, electronic identification systems, as well as mobile payments. This is supported by a robust regulatory framework, a strong digital infrastructure and digital literacy, and a culture of entrepreneurship.

Regulatory Sandboxes

With regards to privacy and data protection issues, the Swedish Authority for Privacy Protection (IMY) has, since 2022, been providing in-depth guidance to innovation projects in the form of dialogue-based guidance, in which the authority highlights grey area issues relating to data protection and privacy. The IMY refers to this approach as a regulatory sandbox and states that it can reduce uncertainty among innovation actors and promote privacy-friendly innovation, which in turn can lead to sustainable digitalisation. However, the approach differs slightly from the regulatory sandboxes of the financial supervisory authorities. Notably, the IMY does not allow any exceptions to existing legislation, and it, together with market participants, decides which grey area issues should be pursued as innovation projects in the sandbox. To participate in an innovation project, innovation actors submit an expression of interest, and the IMY then decides which innovation projects will proceed.

In relation to financial regulation, the SFSA published a statement in 2024 concluding that there is no justification for introducing a national regulatory sandbox, like other financial supervisory authorities in the EU have done. However, the SFSA will continue to evaluate how its Innovation Center, through means other than a regulatory sandbox, can strengthen its guidance function and thereby support fintech companies.

Nevertheless, under certain EU legislation, such as the AI Act and the DLT Pilot Regime, the EU legislator has introduced regulatory sandboxes through pilot regimes, allowing companies to apply to the SFSA to participate.

Central Bank Digital Currency

The Swedish government and the Swedish Central Bank have extensively investigated the adoption of “e-krona”, a digital complement to cash, issued by the Swedish Central Bank. The technical aspects of the e-krona project were finalised in 2023, but the e-krona has not yet been adopted. The Swedish Central Bank’s focus for future work will be to closely follow international work on central bank digital currencies, with a particular emphasis on a digital euro.

An e-krona could ensure the ability to exchange every krona deposited in a Swedish bank into money issued by the Swedish Central Bank. This is important because it guarantees that a krona retains the same value regardless of the bank in which it is held.

While the technical aspects of introducing the e-krona have been investigated, whether or not to introduce it is ultimately a political decision. As part of a government investigation into the role of the state in the payment market, presented in March 2023, the investigator concluded that there is currently insufficient social need for the Swedish Central Bank to issue an e-krona. However, global changes may lead to a different conclusion in the future.

The Swedish legislator, the SCA and the SFSA have several initiatives to protect consumers. One of the most notable is the National Board for Consumer Disputes (Allmänna Reklamationsnämnden; ARN), a public authority that, for a small fee of SEK150, reviews disputes between consumers and business operators (including financial services firms). Although ARN’s decisions are not binding, it is common practice to adhere to its decisions. This provides retail customers with access to affordable dispute resolution.

The SFSA’s consumer protection mandate is implemented through supervision of firms’ conduct frameworks, with emphasis on the design, distribution, and ongoing review of retail products. Swedish firms must apply EU product oversight and governance requirements under MiFID II and IDD, including the identification of target markets and controls for sales to clients exhibiting characteristics of vulnerability. Suitability and appropriateness assessments, disclosure and cost transparency, and rules limiting conflicted remuneration and aggressive cross-selling all operate to reduce the risk of mis-selling to consumers with lower financial capability. The SFSA also monitors complaints data, sales practices, and the treatment of customers in arrears, and issues risk warnings on scams and high-risk products.

With regards to lending, Sweden has implemented Directive 2008/48/EC (CCD) into national law, which will be replaced by Directive 2023/2225/ (CCD2) effective from 20 November 2026. Under these frameworks, lenders must perform thorough credit worthiness assessments before granting consumer credit, document the basis for their decisions, and adjust lending limits where affordability is constrained. To protect consumers most exposed to detriment in the small-sum, high-cost credit market, Sweden has introduced an interest rate cap and an overall cost cap, alongside stricter marketing rules. These measures curb repeated rollovers, excessive pricing, and aggressive advertising, which disproportionately affect financially stressed or digitally targeted borrowers. Mortgage lending is subject to the SFSA’s macro prudential amortisation requirements and supervisory expectations on debt to income, which serve both financial stability and consumer protection by preventing over indebtedness. During periods of economic stress, the SFSA has supported proportionate approaches to amortisation relief in the mortgage market within prudential limits.

Debt collection is regulated to ensure professionalism, proportionality, and respect for debtor rights, and authorities monitor fees and practices that could exacerbate hardship. The statutory framework for debt restructuring provides a structured pathway out of unsustainable indebtedness for the most vulnerable households.

Sweden has implemented the EU right to a payment account with basic features, ensuring non-discriminatory access to an account, payment instruments, and essential services at a reasonable charge. To mitigate exclusion risks arising from rapid cash decline, larger credit institutions are subject to statutory obligations to ensure reasonable access to cash services across the country.

The SFSA has not provided any guidance, opinions or other statements regarding shadow banking in the last few years. The last SFSA statement on the concept was published in 2020, highlighting the systemic risks associated with shadow banking.

Since 1 January 2017, the SFSA has followed the European Banking Authority’s guidelines on limits on exposures to shadow banking, requiring institutions to set limits, as part of their internal processes, on their individual exposures to shadow banking entities and on their aggregate exposure to shadow banking entities.

The process of applying and obtaining authorisation from the SFSA varies depending on the type of authorisation being sought. Under Swedish law, different financial activities are governed by different regulations and are consequently subject to different requirements. In general, the application process is as follows.

• Pre-application preparation: the applicant must prepare comprehensive documentation in accordance with the applicable regulations needed for the application. For financial activities that are regulated more lightly, the documentation can be limited to filling out forms and drafting AML/CTF documentation. For authorisations that are subject to more regulation, an application can consist of hundreds of documents, including policies, capital adequacy and liquidity calculations and a comprehensive business plan.
• Submission of application: the completed application is submitted by the applicant to the SFSA. Submission is usually made electronically.
• Registration: the SFSA registers the application, assigns a designated case officer responsible for processing it, and issues a reference number.
• Application fee: the relevant application fee is paid by the applicant in accordance with payment instructions given by the SFSA.
• Review and assessment: the SFSA conducts a review of the application. During the review, the SFSA may request further details or clarifications to be able to assess whether the applicant meets applicable requirements. If such requests are not met within set deadlines, the SFSA may dismiss the application.
• Decision: it is generally not possible to request a preliminary ruling. When the SFSA has decided upon the application, a formal decision to grant or deny authorisation is issued and the applicant is notified.

As different financial activities are subject to different regulatory frameworks, both the processing times and application fees vary. In general, the more comprehensive the authorisation requirements, the longer the processing time and the higher the application fees, as additional review is required. Examples of the processing time for a complete application and the applicable fees for certain authorisations include the following.

• Credit institution (kreditinstitut): SEK1,500,000/six months.
• Insurance company (försäkringsföretag): SEK1,500,000/five months.
• Investment firm (värdepappersbolag): SEK975,000/six months.
• Debt collection company (inkassobolag): SEK25,500/90 days.
• Payment institution (betalningsinstitut): SEK405,000/three months.
• Electronic money institution (institut för elektoriska pengar): SEK405,000/three months.
• Credit servicer (kreditförvaltare): SEK75,000/90 days.

When a financial services firm is applying for authorisation from the SFSA to conduct certain regulated financial activities, senior individuals in management positions at the firm are subject to a management assessment by the SFSA. The same applies when changes to the management are made during the course of operations after authorisation has been granted. The main purpose of the assessment is to ensure that the firm’s management is suitable and competent to operate within the financial sector.

Persons subject to the assessment include the chairperson of the board, board members and their deputies, and the managing director and their deputy.

The information to be submitted to the SFSA for the assessment primarily concerns the individual’s personal data, curriculum vitae, and details regarding reputation. As part of its assessment, the SFSA also collects information from various public sources. If the individual is a foreign national, the SFSA may contact the competent supervisory authority in the individual’s home country as part of the assessment.

Implementation of CRD VI

During 2026, certain legislative amendments are expected to be adopted in Sweden to implement CRD VI. The Swedish Ministry of Finance has, in a memorandum, published proposed amendments to Swedish legislation to implement CRD VI.

The most noteworthy proposed legislative amendments in the memorandum are the following.

• The same requirements that apply to the assessment of the suitability of board members or the managing director of a credit institution will also apply to certain investment firms and holding companies.
• A new obligation will be introduced for certain credit institutions and holding companies to notify the SFSA in advance of information regarding a new board member or managing director.
• A new obligation will be introduced for companies to assess the suitability of certain persons in senior positions, and the suitability assessment by the SFSA will be extended to some of these position holders in certain credit institutions and holding companies.
• A new notification procedure will be introduced for certain transfers of assets and liabilities.

Additionally, CRD VI introduces an authorisation requirement and specific supervisory provisions for companies from countries outside the EEA that wish to provide so-called core banking-related services from a branch in Sweden. This new framework is established in the Special Supervision Act, replacing scattered provisions in sectoral laws. It introduces an authorisation requirement for non‑EEA firms providing core banking services or taking repayable funds, with limited exemptions for reverse solicitation, intragroup and interbank activity. To establish a third-country branch, the SFSA requires minimum capital and liquidity resources ring‑fenced on segregated accounts, robust governance with two resident managers, risk management and booking/documentation standards, AML/CFT safeguards, and effective home/host supervisory co-operation.

Third-country branches are classified as Class 1 and Class 2 branches based on assets and deposit‑taking thresholds, with dynamic reclassification possible. The classification will affect the capital requirements for the branch. The third-country branches will be subject to reporting requirements, inclusion in the SFSA’s supervisory review programme, and the SFSA’s intervention powers, which may include additional capital/liquidity, business restrictions, and sanctions.

Lastly, the SFSA will assess third-country branches’ systemic relevance (notably where EU group branch assets amount to or exceed EUR40 billion) and may require restructuring measures or, if other measures are inadequate, conversion to a Swedish subsidiary and application for a credit‑institution licence.

Non‑EEA firms operating in Sweden will face a materially more prescriptive third-country branch regime with ring‑fenced capital and liquidity, resident management, enhanced reporting, and the possibility of subsidiarisation where systemic risk is a concern. Although the ambition is to introduce proportional requirements, especially for Class 2 branches, the compliance and authorisation burden will increase.

The legislative amendments are proposed to enter into force on 11 January 2026, except for those relating to a special authorisation requirement and specific supervisory provisions for companies from countries outside the EEA that wish to provide core banking-related services from a branch in Sweden, which are scheduled to enter into force on 11 January 2027.

Implementation of the CCD2

Furthermore, during 2026, certain amendments to the Swedish consumer credit legislation are also expected to be adopted to implement CCD2. Proposed amendments to the Consumer Credit Act (konsumentkreditlag (2010:1846)), which sets out consumer protection rules for the credit market, have been presented in an official government report.

In brief, the most noteworthy proposed legislative amendments in the report are: 

• requirements for credit providers and credit intermediaries to further disclose the terms, costs, interest rates and fees for credit in a clear and easily understandable manner;
• further restrictions on misleading and aggressive marketing;
• the introduction of an extended right of withdrawal from credit agreements;
• more comprehensive credit assessment requirements to ensure that borrowers are able to repay their loans; and
• the introduction of rules on credit limits and potential repayment requirements to counteract excessive borrowing.

In accordance with the timeframe set in CCD2, the legislative amendments are proposed to enter into force on 20 November 2026.