SWEDEN Law and Practice Contributed by: Niclas Rockborn, Rikard Sundstedt and Robin Entenza, Gernandt & Danielsson
Gernandt & Danielsson Hamngatan 2 Box 5747 114 87 Stockholm Sweden
Tel: +46 8 670 66 00 Email: info@gda.se Web: www.gda.se
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain The blockchain sector in Sweden is undergoing a fundamental transformation with 2026 marking the first year in which crypto-asset service providers are comprehensively subject to regulatory authorisa- tion requirements under Regulation (EU) 2023/1114. This regulation, known as MiCA (Markets in Crypto- Assets), comes at a time when other use cases of blockchain technology are simultaneously being explored and afforded legitimacy at unprecedented levels. While only a few years ago blockchain tech- nology and crypto-assets received no bespoke legal treatment under Swedish law, they now represent a distinct category of financial assets subject to rules comparable to those governing traditional financial activities (banking, payment services, investment ser- vices, etc). The clear market trend is that both super- visory authorities and larger financial institutions are shifting from a conservative stance towards a more open and welcoming approach to crypto-assets and blockchain technology. One example is the joint initia- tive by nine major European banks (including Swedish SEB) to launch a Euro-pegged stablecoin. A key regulatory milestone was reached in late 2025, when the transitional regime under MiCA expired, making it mandatory for crypto-asset service pro- viders to have submitted authorisation applications in order to continue their activities. This marked a clear shift from a largely unregulated environment to one subject to comprehensive licensing and supervi- sion. The coming year will therefore be a period for
recently authorised firms to demonstrate their ability to adapt to operating in a regulated environment, and for supervisory expectations to be articulated more concretely. In parallel with MiCA, the DLT Regulation (Regulation (EU) 2022/858) has introduced a pilot regime enabling the use of blockchain technology for trading and set- tlement of financial instruments. A Swedish legislative proposal (SOU 2023:102) was put forward in 2023, seeking to align Swedish law with the DLT Regulation by introducing provisions modelled on existing rules for book-entry financial instruments. The proposal has, however, been subject to delays and has not yet entered into force. These developments illustrate a broader trend in Sweden towards integrating block- chain-based financial services into the established regulatory framework, albeit at a pace that has not always kept up with the EU legislative agenda. For several years, the industry has been led by tradi - tional blockchain operations such as cryptocurrency exchanges. However, interest has grown in innova- tive uses of blockchain technology in other contexts, such as a means of collateral in lending arrangements and in crossovers and combined service offerings of token-based payment transactions and traditional payment transactions. In line with Sweden’s reputa- tion as a leading fintech market, Swedish compa- nies continue to explore blockchain applications that extend beyond conventional practices. 1.1.2 Regulatory Sandbox There are currently no regulatory sandboxes for block- chain technology in Sweden. The Swedish Financial Supervisory Authority (SFSA) has taken a clear posi-
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