SWEDEN Law and Practice Contributed by: Stefan Widmark, Hans Eriksson and Petter Larsson, Westerberg & Partners
1. Introduction 1.1 Current Outlook and Recent Changes In September 2025, the Swedish government pre- sented 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 cur- rent 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 Swe- den. If adopted, unlicensed foreign operators will in practice be required to implement geo-blocking of their services in relation to Sweden to avoid provid- ing 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 resi- dents are related to gambling in Sweden. If adopted, this will facilitate supervision and put additional pres- sure on PSPs. Further, the government has also presented a propos- al to prohibit all gambling on credit. Currently, opera- tors 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.
According to the legislative bill, fantasy sports gener- ally qualify as betting and require a licence. The Swed- ish 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. 2.2 Land-Based Gambling 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 Swed- ish gambling market are the Swedish Gambling Act (2018:1138) and the Swedish Gambling Ordinance (2018:1467). In addition, the following legislation should be men- tioned: • 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 Con- sumer Services Act (1985:716); and • the EU General Data Protection Regulation (GDPR); 3.2 Definition of Gambling According to Chapter 2, Section 1 of the Gambling Act, gambling is defined as lotteries, betting, combi- nation games and pyramid schemes. 3. Legislative Framework 3.1 Key Legislation
2. Jurisdictional Overview 2.1 Online Gambling
Online betting, bingo, poker, and casino games are permitted for licensed commercial operators. Online lotteries are reserved for state-owned businesses.
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