Gaming Law 2024 Comparisons

In 2019 the Swedish gambling market underwent a comprehensive re-regulation, witnessing the introduction of a licensing system, the curtailment of the traditional state-owned lotteries, and the creation of the current regulator: the Swedish Gambling Authority (SGA).

Since then, the chief aim of Swedish gambling legislation and regulatory activity has been to improve market channelisation, that is, the share of the market that is licensed. In turn, this aim has prompted a range of legislation seeking to expand the regulator’s powers, and expand the scope of the licensing system.

Accordingly, on 1 July 2023 a B2B licensing system entered into force, requiring any actor that produces, provides, installs or alters gambling software for a gambling operator active on the Swedish market to hold a license.

Another significant legal reform has been an increase in the tax rate applicable to gambling, rising from 18 to 22%, in force since 1 July 2024.

The scope of the SGA’s regulatory powers has been a topical issue. In a significant piece of recent litigation, the Administrative Court of Appeal is set to consider the SGA’s targeting factors, specifically whether the use of Swedish e-banking software BankID is sufficient for a game offering to fall within the Gambling Act and the SGA’s jurisdiction. The Court’s ruling will be significant to determine the future scope of the SGA’s jurisdiction and regulatory activity.

Recent litigation in the Administrative Court of appeal has also considered the meaning of “turnover” and its relationship to the proper approach to calculating sanction fees issued by SGA.

In a currently proposed Bill, the SGA would be afforded AML powers by being able to compel actors to submit relevant information. The same Bill proposes to effect a complete ban on land-based casinos in Sweden, thereby shutting down the state-owned Casino Cosmopol.

When holding an online commercial gambling licence, a gambling operator may offer the following games: online slot machines, online bingo and online casino games. Online lottery products are reserved for the state-owned gambling operators and not-for-profit organisations.

When holding an online betting licence, a gambling operator may offer the following types of games in addition to traditional sports betting: betting on fantasy sports, betting exchanges, betting on virtual events and betting on the outcome of a lottery.

Fantasy sports gambling can, depending on the various skill elements present within the game, be considered as a game of chance or skill. Fantasy sports that are deemed to be games of skill are not regulated by the Gambling Act.

Betting may be offered in betting shops and through agents. Other than betting, land-based gambling is normally reserved for the state monopolies, which operate land-based casinos and lotteries. Non-profit organisations (including political parties) may offer land-based bingo and sell lottery tickets.

The key statutes relating to the Swedish gambling market are:

• the Swedish Gambling Act (2018:1138);
• the Gambling Tax Act (2018:1139); and
• the Gambling Ordinance (2018:1467).

Furthermore, the Act (2017:630) on Measures against Money Laundering and Financing of Terrorism, the Swedish Marketing Act (2008:486), the General Data Protection Regulation, the Consumer Services Act (1985:716) and the Act on Payment Services (2010:751) also play key roles in relation to specific branches of the gambling market.

Regulatory publications by relevant authorities are also important; including the National Board for Consumer Disputes (Allmänna Reklamationsnämnden) or the Swedish Consumer Agency (Konsumentverket).

On 1 January 2021, new regulations counteracting match fixing entered into effect: the SGA’s regulations and general advice on restrictions and prohibitions of results (including match fixing) in sports and reporting suspected manipulation. This legislation introduces regulations concerning sanctions for violating sporting rules; such as, yellow cards, red cards, penalties and disqualifications. Additionally, a ban is introduced on offering betting services on football in the lower leagues or non-international friendlies, whilst new guidelines for reporting potential match fixing are brought into effect.

As mentioned above, on 1 July 2023 a B2B licensing system entered into force, requiring any actor that produces, provides, installs or alters gambling software for a gambling operator active on the Swedish market to hold a licence.

Lotteries are defined as any gambling wherein the outcome is completely based on chance. This definition therefore extends not only to traditional lotteries, but also to scratch cards.

Betting is defined as an activity in which the participant has the chance to win a prize when a stake is placed on the outcome of some future event. All forms of sports betting and betting on the outcome of lotteries fall under this definition.

Casino games are defined as all types of roulette, dice games, card games and similar games. Additionally, all forms of slot machines are deemed to be casino games.

Pyramid schemes include gambling where winnings derive from the bets of future participants and where the likelihood of winning depends on the number of participants who subsequently join. These types of games are prohibited by the SGA.

Land-based gambling is defined as gambling carried out on relevant physical premises. The key relevant physical premises are land-based casinos, amusement parks or restaurants holding a gambling licence and whereupon gambling takes place, or land-based betting.

Online gambling denotes any form of gambling that takes place by means of electronic online communication, such as online commercial gambling or online betting.

To promote or provide unauthorised gambling or gambling without the necessary licence, whether intentionally or through gross negligence, is a criminalised offence under the Swedish Gambling Act.

Furthermore, if an actor takes measures that are likely to affect the outcome of a game that is subject to a licensing requirements by the Gambling Act, this is considered cheating and/or match fixing and is sanctioned by imprisonment up to two years.

Penalties for the operation of unlawful gambling or the promotion of unlawful gambling range from fines to imprisonment for up to two years. If a crime has been committed internationally, or is deemed sufficiently serious, the offences are punishable by imprisonment for a maximum of six years.

Pursuant to reforms enacted on 1 July 2023, the SGA is now empowered to issue injunctions against actors who breach relevant sections of the Gambling Act (and additional provisions), as opposed to simply reporting the matter to the police.

On 1 December 2024 reforms to the Gambling Ordinance will enter into force which confer upon licensed gambling operators the right to manage and exchange information pertaining to suspected match fixing.

As of 11 November 2024, the Swedish Government has proposed that Sweden ratify the Macolin convention, a Council of Europe Treaty on match fixing in sports. The SGA has welcomed this proposal.

The SGA is the authority appointed to evaluate and approve licence applications, as well as the agency holding general responsibility over all gambling operations that are regulated under the Swedish Gambling Act. Due to the Gambling Act being a framework law, this empowers the SGA to publish extensive regulations to further clarify the provisions of the Act.

The SGA oversees compliance with this Act, as well as the regulations and guidance that have been issued pursuant to the Act. Under its supervision, the SGA can investigate licence holders as well as issue fines and warnings. As a final measure, an operator’s licence can also be revoked.

With regards to the marketing and advertisement aspects of the gambling market, the Consumer Agency is the relevant supervising authority. Similarly, the Tax Agency is responsible for ensuring that the relevant taxes are declared and paid by market actors.

The SGA is empowered to draft and issue regulations spanning a host of issues under its regulatory powers, ranging from AML requirements to the licence fee payable for a given licence. This follows from the fact that the Gambling Act is a framework regulation.

The SGA’s regulation of the gambling market is limited to gambling which falls within the jurisdiction and scope of the Gambling Act. Online gambling only falls within the scope of the Gambling Act if it is deemed to be targeted towards the Swedish market. This assessment, which is therefore central to the SGA’s regulatory reach, is determined by the following criteria:

• use of Swedish language on the website in question;
• customer service available via a Swedish phone number;
• the operator’s use of a payment service providers (PSPs) that are either largely, or solely used by Swedish customers; and
• the use of e-verification systems used largely or solely by Swedish customers (eg, BankID).

Note that a significant piece of litigation has turned on the issue of whether the SGA can exercise authority over a PSP that it purports to be targeting the Swedish market on the basis that it offers BankID to an unlicensed gambling operator. As of 11 November 2024, the case is due to be heard by the Supreme Administrative Court, in a ruling which will be critical in determining the future scope of the SGA’s regulatory powers, and therefore strategy.

See 3.7 Recent or Forthcoming Legislative Changes and 4.2 Regulatory Approach.

Seven types of licence exist, two of them regulating the competitive market, as follows.

• Licences reserved for the state monopoly’s four land-based casinos, land-based slot machines and lotteries.
• Licences for games reserved that are publicly beneficial (such as charities) – these licences can include land-based bingo, lotteries and pool betting at horse racing tracks.
• Licences for land-based commercial gambling – these licences include specific casino games, card-based tournaments and slot machines provided in amusement parks or establishments that hold a licence to serve alcohol.
• Licences for commercial online gambling, including online casino games, online bingo and computer-simulated slot machines.
• Licences for online and land-based betting – these licences include betting on future events, including betting on electronically simulated events (fantasy sports) and betting on the outcome of a lottery. Offering betting on the outcome of a lottery requires consent from the party providing the lottery. Betting on occasions where the majority of participants are under 18 years of age, interval betting and betting on events that are offensive or inappropriate are prohibited.
• Licences for gambling on ships in international traffic – these licences include gambling on slot machines and casino games.
• Licences for the provision of B2B gaming software. The licensing requirement extends to all businesses that produce, provide, install or edit gaming software. This licence was introduced on 1 July 2023.

Licences are readily available in the competitive market, including online commercial gambling and land-based gambling operated on board ships in international waters or within amusement parks and hotels or restaurants with a permit to serve alcohol.

The various licences available are outlined in section 4.3 Types of Licences.

Licences can be, and are normally, issued for a period of five years. However, the SGA holds full discretion to limit the licence period and has done so in several instances. Historically, the reasons to limit an operator’s duration of a licence have been solvency issues within the applying company, evidence of previous regulatory breaches in other jurisdictions, and where operators apply for multiple licences through various subsidiaries.

Annex A

An Annex A form is to be completed by every person associated with the licence application, including the key personnel within the applicant company, the board of directors of the applicant company, the board of directors of all qualified owners (holding ownership of 10% or more), and by the ultimate beneficial owners if holding a qualified ownership. The following due diligence documents must be appended to an Annex A:

• a certified copy of ID (passport);
• employment history for the past ten years; and
• a copy of their criminal history.

Annex B

An Annex B form is to be filled in by all qualified owners (legal entities) of the applicant company. The following due diligence documents should be appended to an Annex B:

• a certificate of registration; and
• financial statements for the past year.

Note that service provides located outside the EEA are required to have a representative domiciled in Sweden.

The timescale of a licence application varies from case to case, mainly depending on how complete an application is and the regulatory and financial status of the company and its owners. A complete application submitted by gambling operators with strong finances and an otherwise uncomplicated history or group structure should be processed within two to three months.

The relevant fees collected by the SGA relating to the licence application of a private operator are the following:

(a) licence for commercial online gambling – SEK230,000;

(b) licence for betting – SEK230,000;

(c) joint application for (a) and (b) – SEK230,000;

(d) – B2B licence – SEK120,000;

(e) renewal of a licence under (a) to (c) – SEK300,000; and

() amendment of a licence under (a) to (c) – SEK150,000.

The fixed annual fees are as follows:

• licence for state lottery – SEK700,000;
• licence for land-based casino – SEK3,500,000;
• licence for land-based slots (state reserved) – SEK2,500,000;
• licence for commercial land-based gambling – SEK2,400; and
• licence for commercial online gambling or betting – SEK30,000–SEK500,000.
• B2B licences – SEK3,000

Regarding annual fees for commercial online gambling or betting, the fee is calculated depending on the operator’s expected turnover:

• annual turnover of less than SEK10 million – SEK30,000;
• annual turnover of SEK10 million to SEK20 million – SEK60,000;
• annual turnover of SEK20 million to SEK50 million – SEK120,000;
• annual turnover of SEK50 million to SEK100 million – SEK240,000;
• annual turnover of SEK100 million to SEK200 million – SEK300,000;
• annual turnover of SEK200 million to SEK500 million – SEK400,000; and
• annual turnover of more than SEK500 million – SEK500 billion.

During the first two years since the re-regulations on 1 January 2019, licence holders for online commercial gambling and/or betting have paid a fixed fee of SEK450,000 per licence.

State-owned operators can obtain a licence to provide land-based commercial gambling. Such gambling takes place mainly through land-based casinos, of which a maximum of four may exist, with the exception of operators obtaining licences to offer various casino games at amusement parks, on ships in international traffic and in hotels and restaurants with a permit to serve alcohol.

Licences for games reserved for publicly beneficial causes can include permission to operate land-based bingo, lotteries and pool betting at horse racing tracks.

As of July 1 2023, licensees must report physical gambling premises to the SGA via a form on the SGA’s website.

To our knowledge, there are no recent or forthcoming changes to report in this area.

Gambling operators satisfying the criteria outlined in the Gambling Act may apply for online commercial gambling and/or betting licences.

On 1 July 2023, reform to the Gambling Act was passed making B2B licences mandatory in Sweden for any actor that produces, provides, installs or alters gambling software in relation to a gambling operator active on the Swedish market.

Affiliates and the marketing provided by affiliates are not directly regulated by the Swedish Gambling Act. Affiliates and operators marketing products targeting the Swedish market are regulated by the Swedish Marketing Act.

However, operators and affiliates must adhere to certain provisions within the Swedish Gambling Act, the most important being that it is illegal to direct marketing towards players who have opted to self-exclude themselves from gambling using the national self-exclusion register. In addition, an affiliate can be seen as promoting unlawful gambling if offering its services to an operator without a Swedish licence directing its offering to the Swedish market.

White-label solutions are accepted and regulated under the Swedish Gambling Act. The company providing the white-label solution will act as the licence holder, thus holding the liability and responsibility laid out in the Gambling Act and Marketing Act.

The SGA may, under certain conditions, order an internet service provider to issue a warning notice that is clearly displayed to visitors to a website that provides gambling without the necessary licence under the Swedish Gambling Act. The notice shall inform visitors that the party providing the gambling service does not hold a licence in Sweden and is not under Swedish supervision and that the gambler is liable for taxes on their winnings.

As of 1 July 2023, licences are required for B2B gaming solutions.

The Swedish Gambling Act introduces the concept of “duty of care”, which has a central role within the licensing system. Duty of care includes all RG measures taken by the licence holder in order to protect the player from excessive gambling, including both those that the licence holder is explicitly required to take and those not explicitly codified in any provisions. The licence holder is expected to have policy in place for detecting and handling problem gambling. Accordingly, the player must be provided with tools to help reduce gambling where necessary.

Since these requirements span several regulations, there has been some debate regarding the actual material content of the duty of care; however, the framework is laid out in the Swedish Gambling Act. In short:

• the licence holder must ensure that social and health protection considerations are taken into account in the licensees’ gambling operations in order to protect players from excessive gambling and help them reduce their gambling when this is called for;
• the duty of care involves counteracting excessive gambling through continuous monitoring of gambling behaviour; and
• a licence holder must present an action plan detailing how this duty of care shall be fulfilled.

In addition to this, in September 2021, the SGA released guidance on how licensed operators should model their ongoing work with responsible gambling. An example of what should be done is as follows.

Operators must monitor and analyse player profiles and their behaviour, including the following:

• players’ active game time and length of login sessions;
• whether a player is chasing losses;
• what types of games are chosen; and
• cancelled withdrawals, and failed deposits.

After carrying out a risk assessment based on the factors above (and other additional factors that an operator has implemented in its responsible gambling work), it must reach out to the players to prevent problem gambling.

The full report on the responsibility guidance is available on the SGA website.

In accordance with the duty of care, it is mandatory for players to set a maximum deposit limit. The player must be able to set daily, weekly and monthly limits. Increases in the limits must take effect after 72 hours, whereas decreases to limits must take effect immediately.

If a player raises a limit to exceed SEK10,000 per month, the operator must contact the player in order to fulfil their duty of care. Furthermore, players must receive regular notifications regarding their account history, including winnings, losses, login times and any additional information the operator wants to share.

The player must also be given notifications about the option to log out or continue gambling with the purpose of counteracting excessive unwanted gambling. Additionally, players will receive a message upon logging into their account containing information regarding accumulated losses during the past 12 months, limits and responsible gambling measures.

Players will have access to self-exclusion tools for the purpose of excluding themselves from specific types of games, for a duration ranging from 24 hours to indefinitely. Additionally, there will be information and links to the national self-exclusion register, Spelpaus, through which players can exclude themselves from all gaming with all Swedish licence holders.

There has been a string of recent cases where the SGA has subjected operators to investigations and fines following alleged breaches of duty of care or AML requirements. In a case handed down in May 2024, a District Court found that operators are obliged to take voluntary steps to limit customers’ gambling where certain indicators of problematic gambling arise Liability may arise if an operator fails to act with sufficient haste.

As of 1 October 2024, the SGA has been granted new powers in relation to oversight of operators’ RG and duty of care. Under its new powers the SGA is able to specify what operators’ plans to fulfil their customer duty of care must entail.

The provision of gambling in Sweden is subject to the Act (2017:630) on Measures against Money Laundering and Financing of Terrorism, which has implemented Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the "Fourth AML Directive").

Additionally, the SGA has issued regulations, guidelines and regular advice on the prevention of money laundering and the financing of terrorism (LIFS 2018:11).

In addition to this, in September 2021 the SGA released a guidance for how licensed operators should model their ongoing work through risk assessments to counteract money laundering and terrorist financing.

The general risk assessment of clients goes through the following stages:

• registration – ID and verification, source of wealth and politically exposed persons (PEP-) control;
• risk assessment of the person;
• customer knowledge through ongoing verification of funds;
• monitoring of transactions; and
• reports to the financial police when discovering potential money laundering.

The full report on the responsibility guidance is available on the SGA website.

Customer due diligence shall be performed:

• when a business relationship is established;
• on single transactions that amount to EUR2,000 (or equivalent value in different currency) or more; and
• on transactions that are below EUR2,000 (or equivalent value in different currency) that the operator realises are connected, and that have a combined amount of at least EUR2,000.

The SGA deems a business relationship to exist at the point at which a customer registers with an online gambling operator. Due diligence is therefore required in relation to all online customers before they can engage in gambling.

Consistent with the Fourth AML Directive, Swedish AML regulations require gambling operators to implement a risk-based assessment of customers, which should be used to assess the risk of money laundering and terrorist financing; action should be taken accordingly.

Pursuant to the Act (2017:630) on Measures against Money Laundering and Financing of Terrorism, all operators must carry out a general risk assessment. The general risk assessment is to be regarded as a key component of a gambling operator’s AML work and shall include how a gambling operator’s products and services may be used to launder money or finance terrorism, and thereafter the risk is assessed on a case-by-case basis.

The SGA has provided operators with general advice as to which factors may constitute high or low risk:

• high risk involves the possibility of anonymous gaming, games where players play against each other, use of new payment and distribution technologies, play at a distance, or cross-border games; and
• low risk – low intensity of transactions, small scale (turnover), low profit repayment, or low stake and profit levels.

All licence holders shall hold policy and measures in place to counteract money laundering and terrorist financing. It is therefore imperative that there are close connections between the general assessment and other routines. Such routines must, at a minimum, include the following:

• monitoring and reporting;
• measures for consumer knowledge and due diligence;
• training of employees; and
• compliance and internal control management.

In a Bill that is currently being proposed, it is proposed that the SGA should be granted wider AML regulatory powers, by being able to force market actors to submit certain relevant forms of information. If passed, the law would enter into force 1 July 2025.

The supervision of marketing and advertisement of gambling products and services is divided between, and handled by, the SGA and the Consumer Agency.

The SGA handles marketing that is specifically tied to gambling operations, such as information about specific games, bonuses and campaigns, and sponsorships.

The Consumer Agency oversees marketing not directly involved with gambling operations, such as moderate marketing, marketing targeting underage persons, direct marketing to persons and general rules flowing from by the Marketing Act.

Marketing is defined in the Marketing Act as “advertising and other business activities intended to promote the sale of and access to products, including a trader’s act, omission or other measure or conduct before, during or after the sale or delivery of products to consumers or traders”.

Provisions regulating gambling products and services are found in Chapter 15 of the Swedish Gambling Act. Additionally, general marketing rules and regulations are found in the Marketing Act (2008:486), which is based on Directive 2005/29EC of the European Parliament concerning unfair business-to-consumer commercial practices in an internal market.

Additionally, there are important sources of information that assist when interpreting the marketing regulations:

• preparatory works to the Gambling Act (prop. 2017/18:220);
• case law from the Patent and Market Court;
• guidelines and general advice given by the Swedish Consumer Agency;
• guidelines and general advice given by the Consumer Ombudsman; and
• marketing guidelines issued by Swedish gambling trade associations.

Advertisement and marketing targeting Swedish citizens without the possession of a gambling licence is a criminal offence.

Advertisements and other forms of marketing may not be aimed specifically at people under the age of 18, nor directly target players who have registered with the Spelpaus self-exclusion registry. However, if a player has closed a player account with a licence holder, marketing can still be aimed at this player if consent has been given.

Commercial game notices must contain clear information about the minimum age to play. Where games are conducted and in connection with commercial announcements about games, with the exception of radio announcements, the licensee must ensure that contact information is also provided of an organisation that provides information about, and support in connection with, gaming problems.

When a licence holder enters into a sponsorship agreement, it must ensure that its logos and the names of gaming products or gaming services do not appear on products intended for use by persons under 18 years of age.

Bonuses are defined as a discount or similar financial incentive that is directly linked to gambling, and these are severely restricted in Sweden. The SGA has introduced a broad definition of what is to be considered a bonus, thereby prohibiting the following under the Gambling Act:

• rewards and gifts to customers;
• prizes, such as cash or prizes in free games;
• non-cash prizes in tournaments;
• VIP incentives; and
• ongoing cashbacks and free spins.

Bonuses must only be issued to a player once per licence holder. Furthermore, licence holders must inform the player, using clear language, of the terms and conditions of the bonus offering. Payment of a bonus shall be made as soon as the terms and conditions laid out have been met, and the same bonus offerings shall be made on the same terms for all players receiving the bonus offering.

Upon failure to comply with the provisions of the Marketing Act under the supervision of the Consumer Agency, the Consumer Agency may initiate an action at the Patent and Market Court. The action may pursue the following remedies:

• a prohibitory injunction coupled with fines; and/or
• fines for market disturbance.

To our knowledge, there are no recent or proposed changes regarding advertisement in relation to the Swedish gambling market.

Any legal entity directly or indirectly owning 10% or more shares or voting rights of a licence holder must submit an Annex B form.

All board members and key personnel of such a company must submit an Annex A form, as well as any person owning 10% or more of the shares or voting rights in the licence holder.

Any changes to ownership, the board, management, or personnel shall be reported to the SGA within 14 days, to be accompanied by a fee of SEK1,000 for physical persons, and SEK3,000 for legal persons.

The trigger in relation to changes in corporate control is as stated in 10.1 Disclosure Requirements, ie,10% direct or indirect ownership of the licence holder.

See 10.1 Disclosure Requirements.

To our knowledge there have been no relevant developments in this area.

The SGA can enforce the Gambling Act directly through decisions against gaming operators. The SGA also has the power to take action against gambling operators under the Act (2017:630) on Measures against Money Laundering and Terrorist Financing. The various types of decisions the SGA can impose on gambling operators are listed in 11.2 Sanctions.

Decisions from the SGA can be appealed to the Administrative Court.

Appealed decisions are not enforceable until the decisions have entered into force, which happens when a decision or judgment can no longer be appealed. The exception to this is if the SGA deems it necessary to have the decision be applicable in the interim.

The SGA has a number of sanctions at its disposal in the event that licence holders fail to comply with the Swedish Gambling Act and its provisions. The SGA can abstain from interventions and sanctions if it deems the offence to be minor or excusable, providing the licence holder rectifies the matter.

The primary sanctions available to the SGA are as follows (in hierarchical order):

• order the licence holder to rectify the breach;
• issue prohibitory injunctions;
• change the licence conditions, such as shortening the licence duration;
• issue a complaint, which could be coupled with a financial penalty ranging from SEK5,000 to 10% of the annual gross gaming revenue;
• issue a warning, which could be coupled with a financial penalty ranging from SEK5,000 to 10% of the annual gross gaming revenue; and
• revoke the licence of the licence holder.

Since the removal of the monopoly and the creation of a licensed market for online gambling, the SGA has issued sanctions mainly due to illicit bonus offerings, the offering of betting products on games in which the majority of participants are minors, failure to comply with AML regulations and failure to comply with responsible gambling measures.

The actions taken, and ongoing supervisory cases, have been due to offences in the following areas:

• illicit bonus offerings;
• offering betting products on games in which the majority of participants are minors;
• failure to comply with AML regulations;
• failure to comply with responsible gambling measures, mainly failure to fully comply with Spelpaus legislation;
• illicit sponsorship;
• gambling at land-based state-operated casinos;
• casinos in restaurants; and
• gambling on ships in international waters.

See 11.2 Sanctions.

To our knowledge there have been no relevant developments in this area.

Gambling tax shall be paid monthly to the Swedish Tax Agency. Licence holders shall pay tax at a rate of 22% of the gross gambling revenue (stakes – winnings paid out – bonuses given). This figure was raised from a previous tax rate of 18%, on 1 July 2023.

See 12.1 Tax Rate by Sector.

Personal licences do not exist within the Swedish regulatory framework for gambling. Licences are granted to gambling operators and, as of 1 July 2023, B2B operators.

See 13.1 Types of Authorisations and Licences.

See 13.1 Types of Authorisations and Licences.

See 13.1 Types of Authorisations and Licences.

See 13.1 Types of Authorisations and Licences.

See 13.1 Types of Authorisations and Licences.