Swedish Gambling Act Review returns new proposals

The memorandum has been produced by Marcus Isgren following a review of the Act, and it has received backing from state operator Svenska Spel. **Key points:

• Proposal would expand the scope of enforcement from covering operators illegally targeting Sweden to operators that don't prevent Swedish accessibility

• It also suggests companies providing financial and administrative services would shoulder more liability for operators' illegal activity in Sweden

• Svenska Spel has given the proposal its support**

Marcus Isgren has been investigating the Swedish Gambling Act since early 2025 and trying to establish where it ought to be strengthened and amended.

He has now presented the country's Ministry of Finance with his proposals for the 2018 legislation, the contents of which has been welcomed by Svenska Spel, the Swedish state-owned gambling company.

The proposals centre around two key modifications in language, the first of which shifts the ‘directional criterion’ to a ‘participant criterion,’ meaning that the scope of the act’s application would cover platforms that are playable in Sweden rather than just platforms that are shown to be actively targeting Swedish players.

Instances of the Swedish gambling regulator, Spelinspektionen, taking enforcement action against operators are often justified through descriptions of a platform’s use of the Swedish language or marketing that explicitly referred to the country.

This type of evidence would no longer be the lowest bar for action if Isgren’s proposals are enshrined in law – instead an operator would be expected to take proactive steps to ensure its platforms didn’t allow participation of Swedes.

Anna Johnson, Svenska Spel CEO, has said: “We have long been concerned that the regulations surrounding illegal gambling need to be tightened. This is about improved protection for consumers, but also about safeguarding trust in the entire Swedish gambling market.”

Another direction in which the act’s scope would be expanded relates to the current ban on promotion of participation in illegal gambling.

The new memorandum suggests this should now include the provision of payment solutions and other similar financial or administrative services to illicit gambling companies.

It proposes that anyone working for a service such as those, who is facilitating payments to or from a gambling business, must assume that the platform’s players are in Sweden and therefore the operator needs to be fully licensed.

Good to know: Sweden's self-exclusion tool Spelpaus is also set to be strengthened with the introduction of new operator obligations that would see them forced to implement more stringent identification processes

In early September 2025, Spelinspektionen estimated that channelisation into the regulated market stood at around 85%, falling below the 90% target.

Providing the proposal is approved and takes force from 1 January 2027, as per the suggested timeline, the wider scope of the Gambling Act could empower the authorities to hit that target.

Johnson adds: “It is absolutely necessary to continue with more measures to combat illegal gambling.”

Swedish online gambling trade association, BOS, has also thrown its weight behind the proposals – Secretary General of BOS, Gustaf Hoffstedt, said: "I foresee the Government shortly submitting a bill to the Riksdag in accordance with the investigation's proposal. Good job Mr. Investigator and with the hope of equally good job from the government and the Riksdag to now proceed with legislation on the matter. Unlicensed gambling in Sweden must be smoked out."