Gaming Law 2025

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

• 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. 4.9 Ongoing Annual Fees The following annual fees apply for the different com- mercial 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 ‒ (a) up to five sites ‒ SEK3,000; (b) six to ten sites ‒ SEK20,000; (c) 11-100 sites ‒ SEK40,000; or (d) more than 100 sites ‒ SEK850,000; and • gambling arranged on vessels ‒ SEK6,000 for each vessel. 4.10 Personal Licensing Personal licensing is possible and is subject to the same general requirements as for legal entities (see 4.6 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 busi- ness obligations; or • have committed serious crimes.

• 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 cer- tain land-based casino games (not full-scale casino operations) may be granted to: (a) operators of hotels and restaurants authorised to serve alcohol; (b) operators of amusement parks; and (c) operators of ships in international waters. As set out in 4.3 Types of Licences , commercial operators may apply for commercial online gambling licences and commercial online betting licences. 6.2 B2B Licences (Suppliers, Software, Etc) B2B licences are mandatory in Sweden for all entities producing, amending, providing, or installing gam- bling software for gambling operators on the Swed- ish 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. 6.3 Affiliates 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 gen- eral restrictions therein. For example, any use of affili- ates must acknowledge the marketing restrictions, including the prohibition on direct marketing towards players who have registered for self-exclusion. 6. Online Gambling 6.1 B2C Licences In terms of liability, affiliates are subject to the restric- tions on illegal aiding and abetting of unlicensed gam- bling towards the Swedish market and thus have a responsibility to ascertain that the necessary licences are held by their business partners.

5. Land-Based Gambling 5.1 Premises Licensing

The licensing requirements correspond to the general requirements for gambling operations (see 4.6 Appli- cation Requirements ). The available land-based licences are as follows.

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