SWEDEN Law and Practice Contributed by: Corinne Ekman, Mikael Nagy and Joacim Kanstedt, Gernandt & Danielsson Advokatbyrå KB
tors and promoting effective management of the fund’s investments. 2.3 Fund Regulation Swedish venture capital funds are typically reg - ulated under the Alternative Investment Fund Managers Act (the “AIFM Act” ), which imple - ments the European Union’s AIFM Directive (the AIFMD). The AIFM Act governs authorisations and operations for alternative investment fund managers in Sweden, under the supervision of the Swedish Financial Supervisory Authority. Exemptions apply under EU frameworks such as EuVECA and ELTIF. EuVECA allows eligible managers to market venture capital funds target - ing early-stage SMEs across the EU, while ELTIF supports long-term investments in infrastructure and sustainable projects within the EU, acces - sible to both professional and retail investors within the EU. 2.4 Particularities Sweden is recognised as the Nordic region’s most active and mature venture capital ecosys - tem, with a strong tech focus. The Swedish VC fund environment remains dynamic and contin - ues to evolve in response to both local innova - tion and global investment trends. Reflecting Sweden’s broader ESG focus and strong innovative culture, Sweden has several dedicated impact funds such as: • Norrsken VC – Europe’s largest early-stage generalist impact fund and early investor in Northvolt and Einride, which targets compa - nies addressing societal challenges through technology; • Industrifonden – a government-controlled Nordic evergreen fund with USD600 million in assets under management, which backs
early-stage technology and life science com - panies with international potential; • Summa Equity – investing in start-ups aligned with the UN Sustainable Development Goals; • Vargas Holding – is not a traditional VC fund but a long-term greenfield impact investor that identifies, validates, finances, launches and scales impact companies from scratch, including Stegra, Polarium, Northvolt and Aira, focusing on high-impact sectors such as clean energy, mobility and sustainable mate - rial; and • Impact Invest and Trill Impact – employ a private equity strategy to achieve significant and measurable impacts while also delivering financial returns. Sweden also maintains a long-standing tradition of government involvement in venture capital with government-controlled funds such as: • Almi Invest – which is recognised as one of Sweden’s most active early-stage investors; • Industrifonden – which operates as a founda - tion that invests in Swedish companies with international growth potential and focuses on advanced technologies addressing significant societal challenges; • Saminvest – which serves as a fund-of-funds investor aimed at stimulating the private ven - ture capital market; • Energimyndigheten Holding AB – the Swed - ish Energy Agency’s investment company, which collaborates with InnoEnergy to invest in innovations relating to energy. These government-controlled funds have played a crucial counter-cyclical role, particularly during periods of global downturn or tightening capital markets.
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