SWEDEN Trends and Developments Contributed by: John Neway Herrman, Erik Ålander, Dahae Roland and Agne Lindberg, Advokatfirman Delphi AB
Tech Law in Sweden: An Overview Sweden’s technological landscape is undergo - ing significant change, marked by increasing regulatory demands on both public and private entities as a result of sweeping EU legislation on AI, cybersecurity and data management. At the same time, Sweden’s culture of digital innova - tion continues to thrive, driven by advancements in AI applications and a surge in investments in fintech solutions. Sweden also stands at the forefront of health data usage, demonstrating a robust readiness for upcoming EU regulations. This article delves into the commercial and legal dimensions of these digital advancements in the Swedish market, with a focus on sectors such as AI, health data, cybersecurity, protective secu - rity, the gaming industry, and fintech. AI’s Impact on Swedish Business and Law The AI Act was formally adopted by the Euro - pean Parliament in March 2024 and came into force on 1 August 2024. The AI Act employs a risk-based approach, categorising AI usage into levels of risk. Unacceptable uses of AI are pro - hibited, and high-risk uses are subject to specific obligations. Key provisions of the AI Act include transparency requirements for basic models, limitations on biometric identification systems, clarification of specific requirements for high- risk models, and enhanced rights for individuals. With the Act now in force, member states must begin implementing the necessary measures to align their national legislation with the regulation and ensure compliance. Obligations for unac - ceptable uses of AI will be applicable from Feb - ruary 2025, while the bulk of the Act’s provisions will apply from August 2027. In Sweden, the AI industry is undergoing rap - id growth and development. In line with this, the Swedish government has launched the AI Commission, an initiative aimed at harnessing
AI to strengthen Swedish welfare and enhance national competitiveness. This reflects the gov - ernment’s commitment to integrating AI across diverse sectors. A key player in this development is AI Sweden, the Swedish national centre for applied AI. With backing from the Swedish government, AI Swe - den collaborates with both public and private sector partners throughout the country. Its mis - sion is to accelerate the adoption and use of AI to boost Sweden’s competitiveness. Among its significant initiatives, AI Sweden introduced GPT-SW3, the first large Nordic language model, offering businesses and organisations access to this open model in order to integrate AI into their products and services. This development opens up substantial opportunities for technological advancement within the region. Another noteworthy initiative from AI Sweden is the Data Factory, designed to drive AI innova - tion. The Data Factory provides infrastructure and a collaborative environment for organisa - tions from various sectors to engage with AI Sweden’s team of technical, strategic and legal experts with the aim of supporting the accelera - tion of AI innovation. Despite these initiatives, Sweden has ranked rel - atively low in several international comparisons assessing a country’s capacity to leverage AI. In response, the Swedish AI Commission decided to bring forward the release of its report Färdplan för Sverige , releasing the report in November 2024 instead of summer 2025 as planned. While the report highlights that Sweden is well posi - tioned to use AI and has historically emerged as stronger through technological shifts, it empha - sises that this cannot be taken for granted. According to the report, society at large – and political leadership in particular – needs to drive
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