Fintech 2026

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

according to the regulations that apply to such mod - els. For example, consumer lending businesses will normally charge customers interest and various fees, while asset management services may charge the customers transaction fees, advisory fees, commis - sion fees or fees for premium features. Most regulated fintech companies will be subject to extensive disclosure requirements relating to compen - sation. During the last few years, the SFSA has focused its supervisory activities on certain compensation mod - els, particularly on those that involve third-party com - mission, which are believed to have inherent conflicts of interest. There has also been a focus on lending business models involving consumer loans with high cost and high interest, which has led to the introduc - tion of a cost and interest rate ceiling in Sweden. 2.4 Variations Between the Regulation of Fintech and Legacy Players Fintech companies and legacy players that conduct the same type of regulated businesses will, in general, be subject to the same regulations. However, legacy players often have more extensive and complex business models, which subjects them to more regulatory requirements. Consequently, fin - tech companies can benefit from less regulatory requirements by providing more streamlined busi - ness models or a more limited number of products and services. On the other hand, many rules and regulations that apply to fintech business models were not construct - ed with fintech industry participants in mind, but rath - er based on the more traditional business models of legacy players. This has caused challenges for fintech companies when applying such rules and regulations to their more streamlined and tech-based business models. 2.5 Regulatory Sandbox The SFSA has not implemented a regulatory sandbox that allows fintech companies to live test innovations or business models in a sandbox environment.

Instead, the SFSA has instituted the Innovation Cent - er, which aims to provide information and offer guid - ance to companies that want to provide innovative products and services on the Swedish market. The Innovation Center arranges seminars and industry meetings on innovation in the financial sector. Within the framework of the Innovation Center, the SFSA co-operates with, among others, the Swedish central bank, the BIS Innovation Hub Nordic Centre, Vinnova, the Swedish Authority for Privacy Protec - tion (the “Privacy Protection Authority”), the Swed - ish Fintech Association, Stockholm Fintech Week and AI Sweden. The Innovation Center is also active in international groups with innovation focus within the European Banking Authority (EBA), the Europe - an Insurance and Occupational Pensions Authority (EIOPA), the European Securities and Markets Author - ity (ESMA), the International Organization of Securities Commissions (IOSCO) and the European Forum for Innovation Facilitators. The Privacy Protection Authority provides in-depth guidance to innovation projects in the form of dia - logue-based guidance, in which the Authority high - lights grey area issues regarding data protection and privacy. The Privacy Protection Authority refers to this approach as a regulatory sandbox and states that the method can reduce uncertainty among innovation actors and contribute to privacy-friendly innovation, which in turn can lead to sustainable digitalisation. To participate, a declaration of interest must be sub - mitted to the authority in advance, and the potential participants shall meet certain criteria. The Swedish Companies Registration Office, the Swedish Tax Agency, the Swedish Public Employment Service and the Privacy Protection Authority have initi - ated work on a pilot AI regulatory sandbox. The pro - ject has been ongoing for the past two years and four interim reports have been published since the start of the pilot. The aim of the project is, among other things, to increase knowledge about how AI regulatory sand - boxes should be established and function in Sweden.

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