Spelinspektionen urges reforms to tackle illegal gambling in Sweden

The Swedish gambling regulator Spelinspektionen has presented a detailed report to the national government outlining new proposals aimed at limiting access to online gambling services operated without a Swedish licence. The recommendations reflect ongoing regulatory concerns about enforcement gaps within the current legal framework and seek to strengthen oversight while reducing exposure to unlicensed operators.

The report arrives at a time when policymakers in Sweden are considering amendments to the national gambling legislation, particularly the Swedish Gambling Act. The proposed changes focus on redefining what constitutes illegal gambling activity in the country, with the objective of making enforcement more practical and consistent.

Background to the regulatory review

The latest proposals build on a legislative review conducted by Marcus Isgren, who previously examined the effectiveness of Sweden’s gambling laws. In September, Isgren recommended removing what has been referred to as the “directional criterion,” a legal standard that has historically shaped how regulators determine whether an operator falls under Swedish jurisdiction.

Under the existing framework, enforcement action can only be taken against gambling operators that are demonstrably targeting Swedish consumers. Indicators of such targeting include the use of the Swedish language, acceptance of Swedish krona as a payment method or marketing activities directed at Swedish audiences.

While this approach was initially designed to balance market openness with consumer protection, regulators have indicated that it has created practical limitations. In many cases, operators without a Swedish licence can still be accessed by individuals in Sweden without overtly targeting the market, which complicates enforcement efforts.

Proposed shift to a participation-based model

To address these limitations, Isgren proposed replacing the directional criterion with a “participant criterion.” Under this revised approach, gambling activity would be considered as taking place in Sweden if individuals located within the country are able to participate, regardless of whether the operator actively targets them.

Spelinspektionen has expressed support for this shift, noting that it would provide a clearer and more enforceable legal standard. By focusing on actual access rather than intent, regulators would be better positioned to address the presence of unlicensed operators within the Swedish market.

Technical measures to block Swedish users

A central component of the regulator’s report involves outlining practical, technology-based measures that gambling operators could implement to prevent access from Sweden. The authority describes its recommendations as “technology-neutral,” meaning that operators would have flexibility in how they achieve compliance, provided that the intended outcome is met.

Geo-blocking and access restrictions

Among the most prominent measures is geo-blocking, which restricts access based on a user’s geographic location. This method is widely used across digital industries and can serve as a first line of defence against cross-border access.

In addition to geo-blocking, the regulator suggests implementing clear “stop messages” that inform users they are not permitted to access the service from Sweden. These messages would act as both a deterrent and a compliance signal.

The report also notes that access should be denied in cases where a user’s geographic location cannot be reliably determined. Furthermore, operators are encouraged to deploy safeguards against attempts to bypass restrictions through technical tools such as virtual private networks.

Registration and account controls

The regulator proposes several measures related to account creation and user registration. For example, Sweden should not be available as a selectable country during the sign-up process. If a user attempts to register using a Swedish address, postal code or telephone number with the +46 country code, the system should automatically reject the application.

These controls are intended to ensure that unlicensed operators do not inadvertently accept Swedish customers through standard onboarding processes. The report emphasizes that such measures should apply consistently to both new and existing accounts.

Payment restrictions and financial safeguards

Financial transactions represent another key area of focus. The regulator recommends blocking payments that involve Swedish financial infrastructure. This includes preventing bank transfers and card payments linked to systems requiring Swedish electronic identification, as well as transactions involving Swedish bank accounts identified by IBAN codes beginning with “SE.”

By restricting payment channels, regulators aim to reduce the practical ability of Swedish players to engage with unlicensed platforms, even if they are technically accessible.

Contractual and marketing limitations

Beyond technical solutions, Spelinspektionen also highlights the importance of contractual clarity. Gambling operators are encouraged to explicitly exclude individuals located in Sweden from their terms and conditions. While such provisions alone are not considered sufficient, they form part of a broader compliance framework.

In addition, operators are advised to avoid marketing practices that could indirectly attract Swedish users. This includes refraining from advertising in channels or formats that are likely to reach audiences within Sweden.

The regulator has made it clear that a combination of contractual, technical and operational measures is necessary. Reliance on terms and conditions without corresponding technical enforcement would not meet the expected standard.

Consistency and enforcement expectations

A recurring theme throughout the report is the need for consistency. Spelinspektionen stresses that all preventive measures should be applied uniformly across an operator’s platform. This includes ensuring that restrictions are enforced for both newly created accounts and those that already exist.

The authority also signals that partial compliance may not be sufficient. For example, implementing geo-blocking without corresponding payment restrictions or registration controls could leave gaps that undermine the overall objective.

Broader implications for the gambling sector

The proposed changes are likely to have broader implications for the international online gambling sector. Operators that currently rely on cross-border accessibility without targeting specific jurisdictions may need to reassess their compliance strategies.

For licensed operators within Sweden, the reforms could help create a more level playing field by reducing competition from unlicensed entities. For regulators, the shift toward a participation-based model may enhance the effectiveness of enforcement actions.

At the same time, the proposals reflect a careful balance between regulatory oversight and technological neutrality. By outlining outcomes rather than prescribing specific tools, the framework allows for adaptability as technology evolves.

Conclusion

The report presented by Spelinspektionen represents a significant step in Sweden’s ongoing effort to refine its gambling regulatory framework. By addressing the limitations of the current directional criterion and proposing a more practical participant-based approach, the authority aims to close existing enforcement gaps in a measured and legally grounded manner.

The emphasis on technical safeguards, financial controls and consistent application highlights a comprehensive strategy designed to reduce access to unlicensed gambling services without overreliance on any single method. Importantly, the proposals are framed in a way that minimizes ambiguity and supports clearer compliance expectations for operators.

If adopted, these measures could strengthen consumer protection in Sweden while reinforcing the integrity of the licensed market. The approach also signals a broader trend among regulators toward more outcome-focused frameworks that prioritize accessibility and enforceability over intent-based assessments.

FAQs

What is the main goal of Sweden’s new gambling proposals?
The goal is to limit access to unlicensed gambling platforms and strengthen enforcement under national law.

What is the directional criterion in Swedish gambling law?
It is a rule that requires proof that an operator targets Swedish users before enforcement can occur.

Why is the directional criterion considered problematic?
It makes enforcement difficult because operators can still be accessed without directly targeting Sweden.

What is the participant criterion?
It defines gambling as taking place in Sweden if individuals in the country can participate.

How would geo-blocking help prevent access?
Geo-blocking restricts users based on their physical location and prevents access from Sweden.

What role do payment restrictions play in the proposals?
They aim to block financial transactions between Swedish users and unlicensed operators.

Can operators rely only on terms and conditions to block users?
No, technical measures must also be implemented to ensure effective compliance.

Will existing accounts be affected by these rules?
Yes, the measures are expected to apply to both new and existing user accounts.

How might this impact international gambling companies?
Companies may need to adopt stricter compliance measures to avoid regulatory risks.

Does the proposal specify exact technologies to be used?
No, it is technology-neutral and allows operators flexibility in implementation.