SWEDEN Trends and Developments Contributed by: Richard Engblom, Per Josephson, Anna Cumzelius and Amin Bell, Harvest Advokatbyrå
Introduction In recent years, the Swedish financial sector has been subject to several new regulations as well as supervisory activities affecting the market and the financial institutions conducting busi - ness operations in Sweden. In this respect, three specific areas will be highlighted. Firstly, the sustainable finance framework has been in focus for quite some time and continues to be a main area of relevance, not only from a regulatory standpoint, but also from a business perspective. Secondly, recent court rulings on credit assess - ments have highlighted the requirements for creditors to obtain sufficient information when granting consumer loans. Lastly, the Swedish Financial Supervisory Authority (SFSA) has continued to exercise a high degree of supervisory oversight, leading to the imposition of significant sanctions and the adoption of evolving practices within the finan - cial market. The Sustainable Finance Regulatory Framework Sustainability practices in Sweden Sweden has a long history in sustainable finance, as demonstrated by the pervasive commitment among its financial institutions to integrate sus - tainability principles into their daily operations and corporate identities. In the asset management sector, fund manag - ers have voluntarily disclosed their funds’ sus - tainability profiles, responding to the growing consumer appetite for sustainable asset man - agement. However, since the implementation of the Sustainable Finance Disclosure Regulation (SFDR) on 10 March 2021, the integration of
even more stringent sustainability considerations into investment processes for financial products, particularly funds, has progressed at a relatively moderate pace. As the regulatory landscape is quite complex, asset managers have struggled with correctly implementing and handling the disclosure requirements. The banking sector in Sweden has long been attuned to sustainability, evident in products like green mortgages and sustainability-linked loans. In recent years, banks have significantly expanded their sustainability departments, mir - roring a broader industry trend. Despite these efforts, a discernible gap remains between the asset management sector and the loan opera - tions of Swedish banks in terms of sustainabil - ity integration. The surge in customer interest in “green” banking solutions extends beyond pri - vate customers, indicating both a need for fur - ther improvements and the potential to generate The SFSA has long prioritised sustainability issues, and the introduction of the SFDR has further propelled the SFSA to take a leading role in international efforts aimed at standardising reporting for all companies (ie, not only finan - cial institutions). Even though sustainability was not explicitly mentioned as a prioritised area for supervision in 2024, it is evident that the SFSA has continued to focus on this. For example, in March 2024, the SFSA made a public statement saying that financial market participants must accelerate their sustainability efforts. The statement particularly emphasised the need for improved competency in sustain - ability issues at all organisational levels, better risk identification related to climate change, and stronger board engagement, acknowledging that business value in this area. Activities by the regulator
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