Gaming Law 2025

SWEDEN Law and Practice Contributed by: Stefan Widmark, Hans Eriksson and Petter Larsson, Westerberg & Partners

• 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, includ- ing 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 busi- nesses that produce, provide, install or edit gaming software. 4.4 Availability of Licences Licences are readily available and unlimited in the competitive market, including online commercial gam- bling 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. 4.5 Duration of Licences 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 pre- vious regulatory violations in other jurisdictions, and where operators apply for multiple licences through various subsidiaries. 4.6 Application Requirements 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 owner- ship), 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 docu- ments must be submitted: • a certificate of registration; and • financial statements for the past year. Service providers located outside the European Eco- nomic Area (EEA) are required to have a representative domiciled in Sweden. 4.7 Application Timing 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 appli- cation 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. 4.8 Application Fees The following application fees apply to licences avail- able to commercial (ie, non-state-owned) operators in Sweden: • commercial online gambling licence – SEK230,000; • commercial land-based gambling licence – SEK230,000;

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