SWEDEN Trends and Developments Contributed by: Ulrica Salomon, Johanna Elveland, Christian Wennergren and Matteus Romare, Cirio Advokatbyrå AB
Cirio Advokatbyrå AB Box 3294, 103 65 Stockholm Visitors Biblioteksgatan 9, 111 46 Stockholm Sweden Tel: +46 852 791 600 Email: contact@cirio.se Web: www.cirio.se
The Swedish Competition Authority (“SCA”) contin - ues to enforce its merger control regime while actively improving procedural efficiency. This article provides an overview of the latest cases and developments, including remedies on the postal market, the SCA’s first below-threshold enforcement under the Tow - ercast doctrine, and a decision to extend a review deadline without the parties’ consent. The article also addresses legislative developments in merger control and foreign direct investment screening. Please note that all amounts stated in EUR in this arti - cle have been converted from SEK using the Euro - pean Central Bank’s average exchange rate for the previous financial year (EUR/SEK 11.0663). Merger Control Activity Consistent levels of notifications, continued scrutiny and improved review efficiency Merger control activity in Sweden remained stable in 2025, continuing the trend observed in recent years. SCA reviewed a total of 95 concentrations during the year, of which 93 were cleared without measures in Phase I. This compares to 92 concentrations reviewed in 2024 (including 3 Phase II cases) and 85 in 2023 (including 2 Phase II cases). At the same time, the SCA continued to enhance their efficiency in its review process. Phase I reviews were, on average, concluded within 16 business days in 2025, compared to 20 business days in 2024. Moreover, 40% of Phase I reviews were cleared within ten business days, a significant increase from 22% in 2024. Together, the figures indicate a consistently
active merger control regime with improvements in procedural efficiency. That said, in more complex cases, the SCA contin - ues to conduct thorough, in-depth assessments, and two cases were referred to Phase II during 2025. The SCA’s scrutiny is further reflected in their readiness to extend review deadlines, including, for the first time, doing so without the parties’ consent. The SCA also, in the first case of its kind in Sweden, investigated a below-threshold concentration as a potential abuse of dominant position. Extensive remedies on the postal market The most noteworthy Phase II review in 2025 con - cerned PostNord Strålfors AB’s (Strålfors) acquisition of 21 Grams Holding AB (21 Grams). Strålfors submit - ted proposed remedies on several occasions, and the SCA, with the parties’ consent, repeatedly extended the review deadline. The final proposal of remedies was submitted on 7 April 2025 and ultimately accept - ed by the SCA. The final remedies included, among other things, a functional separation in which Strålfors is, in certain areas, organisationally separated from PostNord Group AB’s (PostNord) distribution operations, and its decision-making remains independent of the rest of the PostNord group. In addition, Strålfors’ conduct is regulated in several aspects, inter alia, an obliga - tion to offer postage optimisation services on FRAND terms, ensuring that other intermediaries can continue to access these services following the acquisition.
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