SWEDEN Trends and Developments Contributed by: Ulrica Salomon, Johanna Elveland, Christian Wennergren and Matteus Romare, Cirio Advokatbyrå AB
At the end of 2025, MCF published a proposal for revised regulations that would expand the scope of activities covered by the Swedish FDI Act. In addi - tion to introducing an anti-circumvention provision – ensuring that fragmented operations across multiple small entities within a corporate group do not exempt those entities from the screening obligations – the proposed regulations broaden the range of covered activities, reflecting the heightened security situation. The new regulations will enter into force on 15 July 2026. By way of example, the chapter on essential services in manufacturing includes traditional heavy industry and materials, such as cement, concrete and bitumen. Transactions that were previously considered ordinary industrial transactions will through the new regulations trigger a notification obligation in Sweden. The expansion of protection-worthy activities will likely result in an even greater number of transactions being subject to notification obligations. As the new regula - tions broaden the scope, reviews under the Swedish FDI Act will become an increasingly critical compo - nent of the transaction process for a broad range of companies and industries. Since FDI proceedings affect transaction timing and, to some extent, deal certainty, it is important to assess regulatory risks at an early stage and, in multi-jurisdictional deals involv - ing sensitive sectors, to prepare for parallel assess - ments as national FDI rules vary between jurisdictions.
It could also be noted that, in general, there is a ten - dency to include a broader scope of transactions under different notification obligations in Sweden. New forms and guidelines reduce the documentation burden for intra-EU investments In May 2026, the ISP introduced a new notification form and updated guidelines under the FDI Act, streamlining the process and reducing the documen - tation burden, particularly for intra-EU investments. For such investments, certain previously mandatory information is no longer required. As of 1 July 2026, it is mandatory to use the new form. Conclusion The latest developments confirm the SCA’s commit - ment to preserving competitive markets through active and increasingly efficient merger control enforcement. While most cases continue to be cleared in Phase I, the SCA has demonstrated its readiness to conduct thorough in-depth assessments in more complex cases and to enforce competition rules even where notification thresholds are not met. Looking ahead, the proposed amendments to the Swedish Competition Act and the expanding scope of the FDI Act signal a broadening of the regulatory land - scape. For businesses seeking to invest or expand in Sweden, proactive planning and a thorough under - standing of both competition law and FDI considera - tions remain essential.
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