Sweden is set to amend its Gambling Act following a report by investigator Marcus Isgren, proposing changes to close loopholes and target unlicensed operators.

An analysis of the Proposed Swedish Gaming Act Amendments (Ds 2025:23) is shared by our lawyer Illia Ivanko:

The proposed amendments to the Swedish Gaming Act, scheduled for January 1, 2027, represent the most significant tightening of the regulatory framework since the market was re-regulated in 2019. The central aim is to eliminate the unlicensed “grey market.”

Here are the key takeaways for your business:

The end of the grey market: reverse solicitation is no longer a defense.
The current requirement to prove an operator is “targeting” Sweden is being replaced. The new rule is simple and absolute: if a person physically located in Sweden can access and play on your platform, you are subject to Swedish law and require a Swedish license. The long-standing operator defense of “reverse solicitation” (i.e., the player came to us, we did not solicit them) is now legally irrelevant. Passively accepting Swedish players is no longer a viable strategy.
Proactive blocking becomes mandatory for unlicensed operators.
The burden of compliance now falls squarely on the operator. To remain outside the scope of Swedish law, you must implement robust and effective technical measures, such as IP-based geoblocking, to actively prevent players in Sweden from accessing your services. Failure to do so means you are operating illegally.
Liability extends deep into the supply chain.
For payment providers, affiliates, platform suppliers, and other vendors the risk of working with unlicensed operators has increased.

Payment Providers can no longer rely on the defense that their service is “generic” and not gambling-specific. Knowingly processing payments for an operator accessible in Sweden (without a license) constitutes illegal promotion. The new “presumption rule” forces them to assume Swedish residents are playing from Sweden unless proven otherwise, making compliance checks on merchants critical.
For affiliates and other suppliers the same logic applies. Promoting or providing services to an unlicensed operator accessible in Sweden will be a direct violation of the law.

A shift to powerful indirect enforcement. While direct prosecution of foreign individuals remains challenging, the primary enforcement strategy will be to isolate non-compliant operators. Expect Spelinspektionen to aggressively target payment channels and B2B technology partners, making it commercially unviable for unlicensed operators to function in the market.

What this means for the industry

The market is moving towards a clear dichotomy. Operators face a stark choice: obtain a Swedish license and comply with its stringent requirements, or completely and effectively withdraw from the Swedish market.

For unlicensed operators: Continuing to accept Swedish players without a license will become a high-risk activity, exposing you not only to action from Spelinspektionen but also making it significantly harder to secure payment and software partners.
For licensed operators: This is positive news. The changes will enhance channelization by reducing competition from the unlicensed market, leading to a more stable and fair competitive landscape.
For all suppliers: A thorough due diligence of your operator clients is now more critical than ever. Your compliance framework must be updated to identify which of your clients are accessible in Sweden and verify they hold the necessary license. Continuing to service non-compliant operators carries direct legal and financial risk.

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