Sweden Takes Aim at Unlicensed Gambling with New Legislative Proposal

Sweden’s government is set to introduce significant changes to its Gambling Act, targeting the persistent issue of unlicensed gambling. On September 22, 2025, the Swedish Ministry of Finance released a memorandum proposing essential updates to the Gambling Act (Spellagen). This initiative aims to address the challenges of platforms that operate in a grey area between licensed and unlicensed markets.

Despite the anticipation surrounding this update, experts caution that the proposed changes may not completely resolve the deeper issues of illegal gambling that have plagued Sweden for years. The proposed amendments, crafted by Marcus Isgren, an investigator for the Ministry of Finance, are geared towards strengthening the regulatory infrastructure surrounding Swedish gambling.

Scheduled to take effect on January 1, 2027, these changes would mark the most significant overhaul of Sweden’s gambling regulations since the market’s re-regulation in 2019. The proposal redefines which gambling services fall under Swedish jurisdiction, expands the regulatory tools available to authorities, and shifts the onus of compliance from the state to the gambling operators themselves.

For a market that has seen declining channelisation since the 2019 re-regulation, this update could signify a pivotal moment. Anna Johnson, CEO of Svenska Spel, the state-operated gambling enterprise, lauded the report alongside other key industry players. She remarked that the suggested regulations are much-needed to tighten the reins on illegal gambling, emphasizing consumer protection and the integrity of Sweden’s gambling market as fundamental to the industry’s operations.

Echoing this sentiment, a representative from Spelinspektionen, Sweden’s Gambling Authority, praised the government’s review. They noted that the proposal aligns well with the authority’s ongoing efforts to amend the scope of the Gambling Act concerning online gambling, thus enhancing the ability to combat unlicensed operations effectively.

Gustaf Hoffstedt, CEO of the industry trade body BOS, expressed a cautious optimism. While he acknowledged that the legislative process might delay the law’s implementation until at least 2027, he remained patient, recalling the frustrating initial years when little progress was made. Hoffstedt views the shift towards a participation-based model as a promising step, although he remains skeptical that the reform will significantly reduce the flow of Swedish players to unlicensed sites.

Hoffstedt believes that the deeper issue lies not in legal enforcement but in the appeal of the licensed market. He argues that Sweden’s licensed sector lacks the allure necessary to retain players, particularly in a fast-paced industry driven by innovation and incentives. Offshore platforms tend to offer more attractive bonuses, a wider array of games, and quicker payouts, making it difficult for the regulated market to compete.

He observes that while Sweden can maintain control over physical products like alcohol due to its tangible nature, digital gambling is a different beast altogether. With hundreds of unlicensed sites just a smartphone away, consumers can easily bypass regulations. Hoffstedt warns that merely erecting legal barriers through DNS blocking or payment restrictions will not suffice.

In response to the proposed amendments, the focus shifts from determining whether a gambling site targets Swedish users to assessing if individuals in Sweden actively participate in the games. Under the new law, even sites without explicit Swedish branding must implement robust measures to block access for Swedish residents. Failure to do so could subject them to legal action.

The amendment outlines several key enforcement shifts:

– Operators must implement effective measures to prevent participation by Swedish residents.

– To avoid jurisdiction, operators must demonstrate the implementation of exclusion measures.

– The promotion ban on unlicensed gambling will extend to various intermediaries.

– Payment intermediaries must assume Swedish participation unless proven otherwise.

– Criminal liability provisions will explicitly cover unlicensed gambling and its promotion.

Despite the regulatory ambitions, Hoffstedt warns against complacency. Sophisticated unlicensed operators can mimic legitimate branding, misleading even well-intentioned consumers. He urges for broader public awareness campaigns, similar to those in Denmark, to educate consumers about unlicensed gambling risks.

While the proposed law could represent a significant shift in Sweden’s gambling regulatory landscape, its ultimate impact remains uncertain. Without concurrent efforts to enhance the attractiveness of the licensed market, even the most stringent legislation might fail to seal the leaks to the unlicensed market.

As Sweden approaches its general election in September 2026, the political will for further reform will be tested. Hoffstedt remains hopeful, but cautious, stating, “The proof of the pudding is in the eating.” As the debate continues, the Swedish government faces the challenge of balancing rigorous enforcement with fostering a competitive and appealing legal gambling market.

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