Fintech 2026

SWEDEN Law and Practice Contributed by: Robert Karlsson, Helena Rönqvist, Caroline Landerfors and Vilma Slättegård, Magnusson Law

Magnusson Law Strandvagen 1 PO Box 7413 SE-103 91 Stockholm Sweden Tel: +46 8 463 75 00

Email: info@magnussonlaw.com Web: www.magnussonlaw.com

1. Fintech Market 1.1 Evolution of the Fintech Market General

New Legislation The EU has placed great emphasis on promoting innovation within the Union. The regulatory intensity is largely driven by its approach to digital governance, balancing innovation with fundamental rights and fair market conditions. Since 2020, the EU has been work - ing on a digital finance package, which includes legis - lative proposals on open finance such as a framework for financial data access (FiDA) and modernising the third Payment Service Directive (PSD3), the Digi - tal Operational Resilience Act (DORA) and the new framework for crypto-assets, the Markets in Crypto- Assets Regulation (MiCA). Another important piece of EU legislation that will potentially have a major impact on the Swedish fin - tech market is the AI Act. The Association noted in its annual market report in 2024 that 73% of fintech com - panies in 2023 were using AI. The AI Act will be fully applicable from August 2026; however, some parts of the regulation, such as the prohibition of AI systems with an unacceptably high risk and the regulation of general-purpose AI, is already applicable. In addition, work is underway in Sweden on a supplementary national AI law, and the law proposal is expected to be published in 2026.

Sweden has a thriving fintech market and is consid - ered to be one of Europe’s largest fintech communi - ties. It was estimated in 2021 that there were a total of 509 fintech companies in Sweden. These include Klarna and iZettle within the payment and transfer cat - egory, and Zmarta and Lendo within the capital debt and equity category, amongst others. Some charac - teristics of the market that have helped the develop - ment of the fintech market are solid banks with strong liquidity, a high degree of digitalisation and a strong talent supply. The Economic Landscape As with many industries, the fintech industry in Swe - den has been affected by the war in Europe and its consequences over the past few years. The COVID-19 pandemic contributed to the contin - ued high interest in investing in fintech companies due to the accelerated digital development that took place during that period. In 2021, there was also an increased interest in raising capital through IPOs on one of the Swedish trading platforms. However, the Swedish FinTech Association (the “Association”) stat - ed in their annual report that, although the market was focusing on growth in 2021, during 2022 the demands on profitability increased, and companies were hav - ing issues raising capital. The Association stated that 2023 would also likely be a year of ups and downs for industry participants on the Swedish fintech market, but also that harder times can lead to new innovations on the market.

2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models

The Swedish fintech industry includes a wide range of business models. The main areas in which Swed - ish fintech companies operate, and which currently dominate the Swedish fintech industry, are:

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