SWEDEN Law and Practice Contributed by: Stefan Widmark, Hans Eriksson and Petter Larsson, Westerberg & Partners
9.4 Restrictions on Advertising Under the Swedish Gambling Act, all marketing of gambling services must be “moderate” ( måttfullhet) . In essence, this means that advertisements for gam- bling services must be designed with additional cau- tion 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 conflict- ing statements as to how the assessment should be carried out in practice. In addition to the moderation requirement, the follow- ing 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 regis- try. 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 gam- ble. In physical premises where gambling services are provided and in marketing (except for radio advertising), contact information for an organisa- tion 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.
9.5 Sanctions/Penalties In minor matters within its mandated field, the Swed- ish Consumer Agency may issue injunctions, subject to a fine, requiring the cessation of certain market- ing 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. 10. Acquisitions and Changes of Control 10.1 Disclosure Requirements 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 cor- porate and financial documentation. 10.2 Change of Corporate Control Triggers Any changes to the direct or indirect ownership of a licence holder or the key personnel mentioned in 10.1 Disclosure Requirements must be reported to the SGA within 14 days of the decision that will trig- ger the change. To process such notifications, a fee of SEK1,000 must be paid to the SGA. 10.3 Passive Investor Requirements As described in 10.1 Disclosure Requirements , indi - rect owners of the licence holder (ie, those with 10% or more of the shares or voting rights) are also subject to disclosure requirements.
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