Gaming Law 2025 Comparisons

In September 2025, the Swedish government presented a report including a proposal to change the scope of the Swedish Gambling Act. In summary, the report suggests that an accessibility-based licence obligation be implemented as opposed to the current regime, which is based on the vague concept of whether the gambling services are directed towards the Swedish market. The proposal has been widely applauded by the current licence holders, who hope that it will form an important piece of the puzzle to effectively shut down unlicensed gambling in Sweden. If adopted, unlicensed foreign operators will in practice be required to implement geo-blocking of their services in relation to Sweden to avoid providing illegal gambling services under Swedish law. The amendments are proposed to come into effect on 1 January 2027.

The report also includes proposals to extend the concept of liability for contributory illegal gambling, particularly in relation to payment service providers (PSPs), which may also become subject to a rule of presumption that payments issued by Swedish residents are related to gambling in Sweden. If adopted, this will facilitate supervision and put additional pressure on PSPs.

Further, the government has also presented a proposal to prohibit all gambling on credit. Currently, operators are prohibited from offering credit themselves but may still allow credit card payments from payment service providers and banks. The proposed change will in essence prohibit operators from both allowing and contributing to gambling funded by credit, and will come into effect on 1 April 2026 if adopted.

Online betting, bingo, poker, and casino games are permitted for licensed commercial operators. Online lotteries are reserved for state-owned businesses.

According to the legislative bill, fantasy sports generally qualify as betting and require a licence. The Swedish Gambling Authority (SGA) has held that an online football manager game involving prizes constituted provision of betting services within the meaning of the Gambling Act.

Social games without any bets or winnings/prizes do not require a licence.

From 1 January 2026, the provision of full-scale land-based casino services will be prohibited, even for the state-owned operator. This marks the end of full-scale casinos in Sweden.

Commercial operators may, under certain conditions, obtain a licence for land-based betting, casino games that are not held in casinos, and goods gambling machines. Non-profit entities may obtain licences for land-based bingo and lotteries.

The two key legislative acts governing the Swedish gambling market are the Swedish Gambling Act (2018:1138) and the Swedish Gambling Ordinance (2018:1467).

In addition, the following legislation should be mentioned:

• the Gambling Tax Act (2018:1139);
• the Act on Measures Against Money Laundering and Financing of Terrorism (2017:630);
• the Swedish Marketing Act (2008:486); the Consumer Services Act (1985:716); and
• the EU General Data Protection Regulation (GDPR);

According to Chapter 2, Section 1 of the Gambling Act, gambling is defined as lotteries, betting, combination games and pyramid schemes.

The Swedish Gambling Act includes no legal definition of land-based gambling; however, according to the legislative bill of the Gambling Act, land-based gambling is defined as games between a player and a gambling operator that take place in a physical setting.

According to Chapter 2, Section 1 of the Gambling Act, online gambling is defined as any form of gambling provided through electronic means of communication and played by a player or multiple players and the party that provides the gambling.

Under Chapter 19, Section 1 of the Gambling Act, anyone that intentionally or through gross negligence provides unauthorised gambling services or gambling services without a licence may be found guilty of unlawful gambling operations (unlawful gambling).

Further, and under Chapter 19, Section 2 of the Gambling Act, anyone that intentionally or by way of gross negligence aids and abets participation in such unlawful gambling may be found guilty of promotion of unlawful gambling. For both crimes, there will not be any sentencing for minor infractions.

According to Chapter 19, Section 4 of the Gambling Act, anyone who takes inappropriate actions to manipulate the outcome of a game that is subject to licence requirements under the Gambling Act may be found guilty of cheating.

Unlawful gambling, aiding and abetting of unlawful gambling and cheating may entail fines or imprisonment for up to two years. In serious cases, sentences of up to six years’ imprisonment could be handed down. When assessing whether a case of cheating is serious, particular attention is paid to whether the offence was conducted as part of a crime that was:

• carried out systematically;
• widespread; or
• of a particularly dangerous nature.

The SGA is the authority appointed to grant gambling licences and acts as the regulator in relation to compliance with the Gambling Act, the Gambling Ordinance and the regulations issued by the SGA.

As regards marketing of gambling services, the Swedish Consumer Agency conducts separate supervision, and the Swedish Tax Agency is the supervising authority when it comes to payment of the relevant taxes.

The Gambling Act is drafted as a framework regulation which, in turn, mandates the SGA to issue regulations on matters including responsible gambling requirements, annual fees, technical requirements, and the specific games covered under each licence category, etc. Due to the nature of this area of law, combined with the SGA’s limited practice of issuing regulations on many fundamental matters, Swedish gambling law has become heavily reliant on case law.

In general, and in line with most Swedish authorities, the SGA’s supervisory approach is entirely reactionary as the regulator does not issue preliminary decisions on specific matters. However, the growing number of published guidance documents on, for example, AML and RG issues, may, in time, help to reduce the number of supervisory interventions required.

The following main types of licences exist in Sweden, with the final five available to commercial operators.

• Licences reserved for the state monopoly ‒ these cover land-based slot machines and lotteries.
• Licences for games reserved for publicly beneficial entities (such as charities) ‒ these games 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 goods gambling machines provided in amusement parks or establishments that hold a licence to serve alcohol.
• Licences for commercial online gambling ‒ these include 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 events 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.

Licences are readily available and unlimited 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.

Licences can 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 the duration of an operator’s licence have been uncertain solvency issues within the applying company, evidence of previous regulatory violations in other jurisdictions, and where operators apply for multiple licences through various subsidiaries.

Licences may only be granted to those who:

• are deemed to have the knowledge, experience and organisation required to run the operations;
• are expected to run the operations in compliance with regulations and other statutes that govern the operation; and
• are otherwise deemed fit to run the operations.

Applicants must submit general information about the business and structure, along with information on key personnel within the applicant company, members of the board of directors of the applicant company and all qualified owners (holding 10% or more of ownership), as well as the ultimate beneficial owners holding a qualified position, including:

• certified copies of ID (passport);
• employment history for the past ten years; and
• criminal history certificates.

Further, for all qualified owners (legal entities) of the applicant company, the following due diligence documents must be submitted:

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

Service providers located outside the European Economic Area (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 applicant and its owners. A complete application submitted by gambling operators with strong finances and an otherwise uncomplicated history or group structure should normally be expected to be processed within two to three months.

If an application for renewal is filed four months prior to expiry, the licence will automatically be extended pending the examination of the renewal application.

The following application fees apply to licences available to commercial (ie, non-state-owned) operators in Sweden:

• commercial online gambling licence – SEK230,000;
• commercial land-based gambling licence – SEK230,000;
• joint application for commercial online and land-based gambling licence – SEK230,000;
• gambling software licence (B2B licence) – SEK120,000; and
• licence for gambling on vessels in international waters – SEK230,000.        

The following annual fees apply for the different commercial licence categories:

• commercial online gambling and online betting licence holders ‒ SEK264,000 for each licence; 
• B2B licence holders ‒ SEK16,500;
• licence for land-based casino games and goods gambling machines ‒
1. up to five sites ‒ SEK3,000;
2. six to ten sites ‒ SEK20,000;
3. 11-100 sites ‒ SEK40,000; or
4. more than 100 sites ‒ SEK850,000; and
• gambling arranged on vessels ‒ SEK6,000 for each vessel.

Personal licensing is possible and is subject to the same general requirements as for legal entities (see4.6 Application Requirements). Further, the applying individual must not:

• be bankrupt;
• be under 18 years of age;
• have a legal guardian;
• have, to a substantial extent, failed to fulfil its business obligations; or
• have committed serious crimes.

The licensing requirements correspond to the general requirements for gambling operations (see4.6 Application Requirements).

The available land-based licences are as follows.

• Charities/non-profit entities may obtain licences for land-based bingo, lotteries, and pool betting at horse racing tracks.
• As regards commercial operators, licences for certain land-based casino games (not full-scale casino operations) may be granted to:

1. operators of hotels and restaurants authorised to serve alcohol;
2. operators of amusement parks; and
3. operators of ships in international waters.

As set out in4.3 Types of Licences, commercial operators may apply for commercial online gambling licences and commercial online betting licences.

B2B licences are mandatory in Sweden for all entities producing, amending, providing, or installing gambling software for gambling operators on the Swedish market.

Strict umbrella arrangements for single entities within a company group are not available. In situations where multiple entities in a company group are involved in the manufacturing and development of the gambling software, the SGA will, however, normally accept a single licence arrangement if the licensee has control of the design and content and fully holds the title to the gambling software.

The use of affiliates is well established in the Swedish Gambling Market but is not specifically regulated by the Swedish Gambling Act but is subject to the general restrictions therein. For example, any use of affiliates must acknowledge the marketing restrictions, including the prohibition on direct marketing towards players who have registered for self-exclusion.

In terms of liability, affiliates are subject to the restrictions on illegal aiding and abetting of unlicensed gambling towards the Swedish market and thus have a responsibility to ascertain that the necessary licences are held by their business partners.

A licence holder may, under certain conditions, contract an affiliate (or a non-associated entity) to carry out operative work or functions in its business operations, provided that the licence holder remains responsible for the services in relation to its customers.

Except for certain gambling services (eg, casino business and slot machines), a joint licence may be sought together with another service provider that is authorised to provide gambling services within the EEA.

White-label arrangements are accepted and will require the entity providing the white-label product to apply for a gambling licence.

The SGA may order internet service providers to include a warning notice clearly displayed on a gambling website that does not hold a Swedish licence. The notice shall include information that the operations are conducted without a licence in Sweden, are not subject to Swedish supervision, and that potential winnings are subject to tax.

All licence holders are subject to RGrequirements. This includes a general “duty of care” to:

• ascertain that social and health considerations are observed;
• counteract excessive gambling; and
• help gamblers reduce their gambling when there is reason to do so.

All licence holders must adopt an action plan for how the duty of care obligation will be complied with. The duty of care obligation includes responsibility for monitoring all customers and, in the event of excessive gambling, licence holders may need to apply restrictions and limitations; for example, by contacting the customer and/or limiting deposit limits and/or gambling time, or ultimately suspending the customer. Both feedback and restrictions should be applied at an early stage to limit the potential harm that may be caused by excessive gambling.

The central RG requirements of the Gambling Act are as follows.

• Licence holders must make it possible for customers to limit or suspend themselves from gambling – in practice, this is conducted by use of the suspension registry, which is operated by the SGA.
• People under the age of 18 are not permitted to gamble.
• Licence holders are not permitted to provide credit nor to imply such is on offer.
• Except for non-profit gambling operations, bonus offers are only allowed the first time the customer participates in gambling with the licence holder.

Moreover, the SGA has provided a guide featuring examples of how signs of excessive gambling can be identified, and which individualised measures the SGA expects licence holders to take when customers show signs of excessive gambling. Factors to consider in this regard are:

• gambling patterns – active gambling time, chasing losses, types of games, increased deposit limits, interrupted withdrawals, deposit failures;
• contact with the licence holder – claims to win back losses, agitated behaviour, mentioning of financial problems; and
• other factors – previous self-exclusion, age (ages 18 to 24 considered high-risk).

In addition to the RG requirements in the Gambling Act, the SGA has issued RG regulations in LIFS 2018:2, which includes certain deposit, loss and session limits. 

The following RG management tools are required to be implemented for all Swedish licence holders:

• obligation for the player to set a deposit limit, and possibility to set daily, weekly and monthly limits – any increase in the limit will be effective after 72 hours, but any decrease of the limit will have to be implemented immediately;
• mandatory contact with any player increasing the limit in excess of SEK10,000 per month;
• mandatory notification requirements on customer account data, including winnings, losses, session times, limits, possibilities to log out, and general RG information; and

• mandatory self-exclusion tools and a hyperlink to the Spelpaus national self-exclusion register in relation to all games for a minimum of 24 hours up to indefinite exclusion. 

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”) is the central AML legislation.

Further, the Regulation (2009:92) on Measures Against Money Laundering and Financing of Terrorism includes additional regulations on AML issues.

Moreover, the SGA has issued regulations on the prevention of money laundering and the financing of terrorism (LIFS 2019:2).

Lastly, in the spring of 2025, the SGA published updated AML guidance, which includes useful recommendations on the fundamental regulatory requirements, such as registration verification, risk assessments and KYC protocols.

All gambling operations in Sweden are subject to the restrictions in the Act on Measures Against Money Laundering and Financing of Terrorism.

The SGA has also issued binding regulations on AML measures in SIFS 2019:2 and published guidance on how licence holders should work to counteract money laundering and terror financing. In short, the following safety measures should be conducted:

• customer due diligence measures;
• monitoring and reporting;
• processing of personal data;
• aptitude testing of staff;
• compliance and internal control; and
• model risk management procedures, if such models are used.

If the licence holder is part of a corporate group, there are special provisions on group-wide procedures, which include a requirement for parent companies to establish procedures that apply to the entire group.

The SGA and the Swedish Consumer Agency jointly supervise the marketing restrictions of gambling services on the Swedish market. In brief, the SGA supervises marketing issues that relate directly to gambling operations such as bonus campaigns, etc. The Consumer Agency supervises the compliance with general marketing restrictions for gambling services – for example, the requirement of moderate marketing of gambling services.

The Swedish Public Prosecutor’s Office enforces criminal matters.

Under the Swedish Marketing Act, the concept of marketing is defined 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”. In case law, the concept of advertising has been given an extensive interpretation.

The key legal provisions governing advertisement of gambling products and services are set out in the Swedish Marketing Act and in Chapter 15 of the Swedish Gambling Act.

Under the Swedish Gambling Act, all marketing of gambling services must be “moderate” (måttfullhet). In essence, this means that advertisements for gambling services must be designed with additional caution and should not come across as aggressive or overly outreaching. In particular, advertisements may not insinuate that certain games are free if they require a bet, or that they are risk-free, etc.

At the time of writing (November 2025), there is no case law from the appellate courts on the issue of moderate gambling marketing and the few first instance court judgments include somewhat conflicting statements as to how the assessment should be carried out in practice.

In addition to the moderation requirement, the following specific regulatory restrictions on advertising of gambling services apply.

• Advertisements for gambling services may not be directed at people under the age of 18 nor people who have registered with the self-exclusion registry. If a customer has closed their account with the licence holder, direct marketing is only allowed if consent has been provided from the customer.
• Advertisements for gambling services must contain clear information about the minimum age to gamble. In physical premises where gambling services are provided and in marketing (except for radio advertising), contact information for an organisation that provides information about and support for gambling problems must be provided.
• When entering into sponsorship agreements, licence holders must ensure that logos and names of gaming products or services do not appear on products intended for people under the age of 18.
• Except for non-profit businesses, bonus offers are only allowed when the customer gambles with the licence holder for the first time. In case law, the concept of a bonus has been given a broad interpretation that includes rewards, gifts, (non-monetary) prizes, VIP incentives, cashbacks and free spins.

In minor matters within its mandated field, the Swedish Consumer Agency may issue injunctions, subject to a fine, requiring the cessation of certain marketing activities. In severe cases, the Agency will instead seek such injunctions before the Patent and Market Court and the Patent and Market Court of Appeal. The Swedish Consumer Agency may also request that the courts issue a marketing fine.

Within its separate parallel field, the SGA may order that the licence conditions be amended and issue:

• injunctions or corrective orders, subject to a fine; or
• remarks, warnings, and sanction fees.

In exceptionally severe cases, the SGA may also revoke gambling licences with immediate effect. It is possible to appeal such decisions and, where relevant, request a stay of execution to suspend the immediate effect.

All entities and individuals that directly or indirectly hold 10% or more of the shares or voting rights in a licence holder are subject to approval from the SGA and need to provide documentation on their board members and management personnel, along with corporate and financial documentation.

Any changes to the direct or indirect ownership of a licence holder or the key personnel mentioned in10.1 Disclosure Requirementsmust be reported to the SGA within 14 days of the decision that will trigger the change. To process such notifications, a fee of SEK1,000 must be paid to the SGA.

As described in10.1 Disclosure Requirements, indirect owners of the licence holder (ie, those with 10% or more of the shares or voting rights) are also subject to disclosure requirements.

The SGA has a mandate to enforce the restrictions on gambling set forth in the Swedish gambling regulations and the Act on Measures Against Money Laundering and Terrorist Financing. The enforcement is carried out under administrative law and the decisions can be appealed to the Administrative Court of Linköping. If leave to appeal is granted, such judgments may, in turn, be appealed to the Administrative Court of Appeal in Jönköping and then ultimately to the Supreme Administrative Court. Except for certain cases, the legal effect of the SGA’s decisions is suspended until it has become final – that is, upon the expiry of the appeal deadline or when all appeal possibilities have been exhausted.

Depending on the severity of the violation of the Gambling Act or the applicable licence obligations, the SGA has a mandate to:

• order the licence holder to remedy the matter (subject to a fine);
• issue an injunction (subject to a fine);
• order that the licence conditions be amended;
• issue a remark, which could be combined with a sanction fee,
• issue a warning, which could be combined with a sanction fee; or
• fully revoke the licence of the licence holder.

If a licence holder fails to provide any information that it is obligated to provide under the Gambling Act, the SGA may issue a delayed payment fine of up to SEK100,000.

The SGA may refrain from ordering a sanction if:

• the violation is considered minor or excusable;
• the licence holder has remedied the matter; or
• any other authority has issued sanctions owing to the violation and such sanction is deemed sufficient.

The powers of enforcement vested with the Swedish Consumer Agency are regulated under administrative law. However, the Agency’s decisions are appealed to the Patent and Market Court and Patent and Market Court of Appeal, and such cases are normally administered under the Swedish Code of Civil Procedure.

In cases involving criminal offences, the Swedish Public Prosecutor’s Office is the appointed enforcement authority. Such enforcement is conducted under general criminal procedural law, which vests the prosecutor with more far-reaching remedies in comparison with the administrative remedies available to the SGA and the Swedish Consumer Agency.

The SGA’s supervision and use of sanctions have primarily been focused on issuing warnings and sanction fees rather than using injunction orders to address violations of the Gambling Act, which has led to extensive regulatory litigation in the administrative court system.

In the last couple of years, the SGA has had a particular focus on supervising AML and RG issues but has also broadened its focus to target payment service providers and B2B operators due to aiding and abetting of unlicensed operators with connections to the Swedish market.

The Swedish Consumer Agency has been rather passive in its supervision of the field of gambling since 2019 but has enforced two matters concerning the moderate marketing requirement. The Patent and Market Court issued injunctions subject to a fine in both cases, neither of which was appealed to the appellate court.

As mentioned in11.2 Sanctions, the SGA may issue sanction fees and delayed payment fines.

Depending on the violation, different calculation methods for the fine applies.

For violations of the Gambling Act, fines are set between SEK5,000 and 10% of the GGR for the preceding year.

For payment service providers that fail to comply with their payment blocking restrictions, fines are set between SEK5,000 and SEK10 million.

For AML violations, the cap for the sanction fee is limited to the highest of the following three alternatives:

• 10% of your GGR for the previous year;
• twice the profit attributable to the violation (normally difficult to distinguish); or
• 1 MEUR (Meta Uranus).

Gambling services are currently subject to a tax rate of 22% of the monthly profit – ie, the difference between the total bets minus the total payouts. Only bets and payouts that concern the Swedish market should be included.

Players’ gambling winnings from licensed operators are tax-free in Sweden. Conversely, winnings that stem from unlicensed operators are subject to tax.