SWEDEN Trends and Developments Contributed by: John Neway Herrman, Erik Ålander, Dahae Roland and Agne Lindberg, Advokatfirman Delphi AB
The Swedish Central Bank’s ( Riksbanken ) e-kro - na project is another significant initiative, explor - ing a blockchain-based digital currency. Pilot phases have examined the feasibility of inte - grating the e-krona into banking systems and enabling offline transactions. In 2024, the work on the technical e-krona pilot was completed and the Central Bank is now focusing on funda - mental design and policy issues for a possible e-krona while urging the legislator to begin the legislative work as soon as possible in order to avoid excessive lead times if the Swedish parlia - ment ( Riksdagen ) were to approve the issuing of the e-krona. Open finance – PSD3, FIDA and PSR The evolution from open banking under PSD2 to open finance under proposed frameworks such as PSD3, the Payment Services Regula - tion (PSR), and Financial Data Access Regula - tion (FIDA) marks a significant shift. PSD2, which opened payment account data to third-party providers, spurred competition in payments but did not extend to other financial services. The proposed FIDA framework aims to address this limitation, enabling broader financial data access and unlocking innovation across the financial sector. A 2023 report by the SFSA high - lights Sweden’s early adoption of open financial services, driven by a highly digitised financial industry, fintech innovation, and widespread use of mobile e-IDs. However, competition in pay - ment initiation services underscores the need for FIDA to expand opportunities beyond payments. Gaming Industry: Trends and Legal Challenges In recent years, Swedish game developers have witnessed growth in the number of companies involved and their revenue, workforce and gen - der diversity, despite facing challenges like a
persistent skills shortage. According to the 2024 report by the trade organisation, The Swedish Games Industry, the industry’s domestic revenue increased by 6.4%. However, the growth is tem - pered by the increasingly strong euro against the SEK, converting to a slight decrease to EUR3 billion. Including subsidiaries abroad, the total industry revenue was EUR7.9 billion, which converts to a 4.5% increase in SEK. The sec - tor employed over 9,000 people in Sweden and approximately 16,000 abroad. Gaming companies in Sweden must navigate various legal considerations, including compli - ance with consumer protection laws, ensuring clear information, warranties and product qual - ity for digital content. Adherence to the GDPR, which imposes strict rules on collecting and processing personal data, as well as copyright and intellectual property laws, is essential. It has become increasingly crucial for gaming companies to adhere, in particular, to IP rights, driven by the rapid growth of AI-powered tools and technologies that facilitate content creation, modification and distribution. Additionally, gaming companies seeking to raise capital in the EU must comply with the EU Foreign Subsidies Regulation (FSR), applicable since 12 July 2023. The FSR aims to ensure fair competition between European and non-Euro - pean companies by monitoring significant trans - actions and public procurement procedures to address distortions in competition arising from subsidies granted by non-EU countries to com - panies in the EU single market. Health Data Usage: Sweden Leads the Way The sharing of health data holds significant potential within precision medicine. While the EU is in the midst of adopting legislation to regulate health data through the European Health Data
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