Fintech 2026

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

Consumer lending is subject to the consumer protec - tion provisions in the Consumer Credits Act (CCA). The CCA implements, inter alia, the EU Directive on credit agreement for consumers. The rules include requirements for the provision of information prior to the conclusion of credit agreements, marketing infor - mation, credit assessment, documentation of credit agreements, interest and fees, the consumer’s right The CCA also includes rules on high-cost credits. These rules do not stem from the Consumer Credit Directive but rather from national Swedish legislation. The rules were introduced as a reaction to issues relat - ing to increasing indebtedness among consumers a result of so-called instant loans. These loans are easily accessible and can be taken out through, for instance, short message service (SMS); therefore, they have historically been marketed towards financially vulner - able consumers. of withdrawal, etc. High-Cost Credits When marketing high-cost credits, the creditor must separately disclose that the marketing relates to such credits. The creditor must also provide information on the risks relating to indebtedness and where the consumer may seek support with budget and debt- related matters. The new EU Consumer Credit Directive (Directive EU/2023/2225) is currently being implemented in Sweden, and a new Consumer Credit Act is proposed to enter into force in November 2026. Consumer Mortgages The provision or intermediation of mortgages to con - sumers requires authorisation in accordance with either the SBFBA or the MBA. These Acts, and the CCA, contain consumer protection provisions that Loan origination is regulated by the SBFBA and the CCA, and by regulations and guidelines issued by the SFSA and the Swedish Consumer Agency. Loans to consumers must be preceded by a credit - worthiness assessment to ensure that the consumer apply to consumer mortgages. 4.2 Underwriting Processes

has the ability to repay the loan. The CCA and the SFSA’s general guidelines regarding consumer cred - its contain extensive consumer protection provisions, including the requirement for good lending practices and detailed provisions for creditworthiness assess - ments. 4.3 Sources of Funds for Fiat Currency Loans The source of funds for loans varies between the dif - ferent market actors. The primary sources of funds for banks and credit market companies authorised under the SBFBA are deposits from the public and the issuance of various securities, including covered bonds. Other actors may utilise lender-raised capital as a source of funds, and lending-based crowdfund - ing platforms normally source funds via investments from consumers and/or private businesses. 4.4 Syndication of Fiat Currency Loans Larger banks in Sweden structure and arrange syndi - cated loans for corporate clients. Such loans could, for example, be arranged for company acquisitions or commercial real estate transactions. Peer-to-peer lending platforms, and other lending platforms, may diversify the individual loans provided on their platforms between several lenders or inves - tors to spread the risks for individual borrowers. 5. Payment Processors 5.1 Payment Processors’ Use of Payment Rails Payment processors may use existing payment rails or payment systems, or implement new ones. A com - pany that wishes to provide payments services must be authorised in accordance with the PSA, the SBFBA or the EMA. 5.2 Regulation of Cross-Border Payments and Remittances Sweden currently lacks an explicit regulatory frame - work for cross-border payments and remittances. However, tax provisions may apply dependent on the specific nature of each transaction.

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